SHAMANNA REDDY ,BANGALORE vs. INCOME TAX OFFICER, WARD-4(1)(3), BANGALORE

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri George George K & Shri Chandra Poojarind Shri Laxmi Prasad Sahuassessment Year : 2018-19 Shri. Shamanna Reddy, Vs. Ito, C/O. Chowdeshwari Rice Building, Ward – 4(1)(3), Opp. Hi Look Bakery, Bengaluru. Kasavanahalli, Sarjapur Road, Bengaluru – 560 035. Pan : Ccwpr 8342 E Appellant Respondent Assessee By : Shri. Siddesh Nagaraj Gaddi, Ca Revenue By : Dr. Nischal, Addl. Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 20.02.2024 Date Of Pronouncement : 20.02.2024

section 282 of the Income-tax Act, 1961 read with rule 127 of the Income-tax Rules. 8. The learned CIT(A) and AO has erred in initiating the re- assessment proceeding u/s. 148 which is based on the incorrect assumption that the appellant had sold non-agriculture land. Addition of Rs. 52,99,000/- 9. The Learned

UDAYA SOUHARDA CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-5(1)(1), BANGALORE

In the result, the appeal of assessee is hereby allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

282. 9.4 Going through the above stated judgment of Hon’ble Supreme Court, we note the assessee i.e. Totgars, Co-Operative Sales Society Ltd at the relevant time (A.Y. 1991-92 to 1999-2000) was engaged in two activities viz marketing of agricultural produce of its members and providing credit facilities to them. The assessment

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-12 , BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

282,818 ITA Nos.1980 to 1982/Bang/2018 M/s. Harman Connected Services Corporation India Pvt. Ltd., Bangalore Page 29 of 38 31.2 The definition of export turnover for the purpose of section 10A of the Act is given in explanation (2)(i)(b) to section 10A of the Act and the same reads as follows: “the consideration in respect of export

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

282,818 ITA Nos.1980 to 1982/Bang/2018 M/s. Harman Connected Services Corporation India Pvt. Ltd., Bangalore Page 29 of 38 31.2 The definition of export turnover for the purpose of section 10A of the Act is given in explanation (2)(i)(b) to section 10A of the Act and the same reads as follows: “the consideration in respect of export

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

282,818 ITA Nos.1980 to 1982/Bang/2018 M/s. Harman Connected Services Corporation India Pvt. Ltd., Bangalore Page 29 of 38 31.2 The definition of export turnover for the purpose of section 10A of the Act is given in explanation (2)(i)(b) to section 10A of the Act and the same reads as follows: “the consideration in respect of export

SREE CAUVERY SOUHARDA CREDIT SAHAKARI SANGHA NIYAMITHA,BENGALURU vs. INCOME TAX OFFICER WARD 1(1)(1), BENGALURU

Bench: Shri Waseem Ahmed & Shri Soundararajan K

282. ITA No.1854 & 1855/Bang/2025 Page 7 of 23 10.4 Going through the above stated judgment of Hon’ble Supreme Court, we note the assessee i.e. Totgars, Co-Operative Sales Society Ltd at the relevant time (A.Y. 1991-92 to 1999-2000) was engaged in two activities viz marketing of agricultural produce of its members and providing credit facilities to them

SHRI. SHANTHISAGAR CO OP CREDIT SOCIETY LIMITED,HUBLI vs. INCOME TAX OFFICER, WARD-2(1), HUBLI

In the result, the appeal of the assessee is hereby partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

capital which are not immediately required to be lent to the members and invested with the bank for short period to earn interest. Then such interest will qualify as income attributable to the banking business or providing credit facility to the members. Therefore, it was asked to the assessee to furnished details regarding whether the deposited with the SUCO Bank

SRI MUNIRAJU KEMPANNA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(4), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

282 and recently in 'Ultratech Cement Ltd. & Ors. Vs. State of Rajasthan& Ors. in Civil Appeal No.2773/2020 decided on 17/07/2020. Accordingly, we do not find any merit in additional ground raised by assessee and the same is dismissed. 25. On merits of the case, Ld.AR placed reliance on following decisions vide paper book filed on 24/09/2020 before this Tribunal

SRI MUNIRAJU KEMPANNA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(4), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

282 and recently in 'Ultratech Cement Ltd. & Ors. Vs. State of Rajasthan& Ors. in Civil Appeal No.2773/2020 decided on 17/07/2020. Accordingly, we do not find any merit in additional ground raised by assessee and the same is dismissed. 25. On merits of the case, Ld.AR placed reliance on following decisions vide paper book filed on 24/09/2020 before this Tribunal

SRI MUNIRAJU KEMPANNA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(4), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

282 and recently in 'Ultratech Cement Ltd. & Ors. Vs. State of Rajasthan& Ors. in Civil Appeal No.2773/2020 decided on 17/07/2020. Accordingly, we do not find any merit in additional ground raised by assessee and the same is dismissed. 25. On merits of the case, Ld.AR placed reliance on following decisions vide paper book filed on 24/09/2020 before this Tribunal

SRI MUNIRAJU KEMPANNA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(4), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

282 and recently in 'Ultratech Cement Ltd. & Ors. Vs. State of Rajasthan& Ors. in Civil Appeal No.2773/2020 decided on 17/07/2020. Accordingly, we do not find any merit in additional ground raised by assessee and the same is dismissed. 25. On merits of the case, Ld.AR placed reliance on following decisions vide paper book filed on 24/09/2020 before this Tribunal

SRI MUNIRAJU KEMPANNA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(4), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

282 and recently in 'Ultratech Cement Ltd. & Ors. Vs. State of Rajasthan& Ors. in Civil Appeal No.2773/2020 decided on 17/07/2020. Accordingly, we do not find any merit in additional ground raised by assessee and the same is dismissed. 25. On merits of the case, Ld.AR placed reliance on following decisions vide paper book filed on 24/09/2020 before this Tribunal

SRI MUNIRAJU KEMPANNA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(4), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

282 and recently in 'Ultratech Cement Ltd. & Ors. Vs. State of Rajasthan& Ors. in Civil Appeal No.2773/2020 decided on 17/07/2020. Accordingly, we do not find any merit in additional ground raised by assessee and the same is dismissed. 25. On merits of the case, Ld.AR placed reliance on following decisions vide paper book filed on 24/09/2020 before this Tribunal

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(3), BENGLAURU vs. SHRI KEMPAREDDY GOVINDRAJU, DOMLUR, BENGALURU

In the result the appeals of the assessee in ITA No’s 1022 to 1024/ Bang/ 2024, for the Assessment Years 2014-15, 2015-16 and 2016-17 are allowed and the appeals of the Revenue in ITA Nos

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

section 133(6) from the Lokayukta by the AO and he observed that there is difference in the jewellery declared. Therefore, the information received from the Lokayukta is part and parcel of the incriminating documents found during the course of search. The assessee has not explained the apparent discrepancies in his own statements on affidavit before the statutory authorities

VIJAYA BANK EMPLOYEES CO-OPERATIVE CREDIT SOCIETY,BANGALORE vs. THE INCOME TAX OFFICER, WARD 7(2)(3), BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishiassessment Years 2022-23 Appellant / Assessee Vijaya Bank Employees Cooperative Credit Society, R No 1, 67, Ii Floor, K H Road Shantinagar Bangalore 560027 Karnataka Respondent The Income Tax Officer, Ward 7 (2) (3) Bmtc Building Koramangala Bangalore 560095 Pan Aaaav4696A For Appellant Shri Prasanna N Uralal Advocate For Respondent Shri Ganesh R Ghale, Advocate Date Of Hearing 04-11-2025 Date Of Pronouncement 15-12-2025 O R D E R

282 (SC). Such interest income could not be said to be attributable to the activities of the society, namely, carrying on the business of providing credit facilities to its members. Therefore, the interest income detailed at the table below is brought to tax under section 56 of the Income-tax Act, 1961. 1. Interest on SB accounts

SRI. D. K SHIVAKUMAR ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

Section 69A of the Act.The addition is made out on basis of loose sheets of documents, which does not come under the ambit of ‘books of entry’ or as ‘evidence’ under the Indian Evidence Act. Reliance is placed on following decisions: 57  CBI Vs. V.C. Shukla (1998) 3 SCC 410  Common Cause and others Vs. Union of India

CONTINENTAL AUTOMOTIVE COMPONENTS INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX,CIRCE-2(1)(1), BANGALORE

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

282-284 of the paperbook. IT(TP)A No.390/Bang/2021 Page 13 of 55 Tata Elxsi Ltd. 15.1 The ld. AR submitted that the company is functionally dissimilar to the Assessee given that it is engaged in embedded product design, industrial design and engineering, animation and visual effects and visual computing labs and systems integration services. Further the software development

DCIT, CENTRAL CIRCLE, BELLARI vs. M/S. NAVODAYA EDUCATION TRUST, RAICHUR

In the result, the appeal of the revenue is partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2009-10

282 (Amritsar - Trib.), Amritsar Bench of ITAT has held that where assessee-society was engaged in imparting education as a learning centre of a University i.e. PTU, since object of assessee was charitable in nature within meaning of section 2(15), a part of semester fee paid by PTU to assessee could not be regarded as commission: and, assessee'' claim