NABHIRAJ RATNA BALRAJ BY LEGAL HEIR B.R.RAKESH,BANGALORE vs. INCOME-TAX OFFICER, WARD-7(2)(1), BANGALORE

In the result the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

36. The Ahmedabad Bench of the Tribunal, in the case of Dharamshibhai Somani v. ACIT [(2016) 161 ITD 627 (Ahd. – Trib.)(SMC)](ITA No. 1237/Ahd/2013; AY 2008- 09; order dated 30.9.2016)(Ahd Trib SMC) held that - The present amendment, being an amendment to remove an apparent incongruity which resulted in undue hardships to the taxpayers, should be treated as retrospective

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

Accordingly, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

xii) Further section 10AA being part of chapter III is essentially a exemption section though Post amendment, such exemption is available in form of deduction from profits and gains derived from the undertaking, the interpretation needs to be done strictly as held in the case of Commissioner of Customs (Import) vs. Dilip Kumar and company & Others (SC) Civil appeal number

M/S. TATA ELXSI LIMITED., ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri George George K. & Shri Chandra Poojari

xii) Further section 10AA being part of chapter III is essentially a exemption section though Post amendment, such exemption is available in form of deduction from profits and gains derived from the undertaking, the interpretation needs to be done strictly as held in the case of Page 13 of 39 ITA Nos.927, 974 & 975/Bang/2023 Tata Elxsi Ltd., Bangalore Commissioner

M/S. TATA ELXSI LIMITED,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

36 observed as under:\n\"34. As noted earlier, the Apex Court in the case of Mahendra Mills\n(supra) has neither considered the scope of deduction under Chapter VI-A nor the\nsaid decision can be read to mean that by disclaiming current depreciation the\nassessee can claim enhancement deduction under any other provision in the Act.\nTherefore, reliance

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY, CENTRAL CIRCLE, BELLARY vs. M/S VIRGO PROPERTIES PRIVATE LIMITED, CHENNAI

In the result, appeal filed by the Revenue is dismissed

36,07,036/- to the Profit & Loss\nAccount. While doing so, the AO did not verify the appellant's claim of cost of\nacquisition and cost of improvement as contained in the Explanation-1 to\nSection 147 which is reproduced as below:\n\"Explanation 1.- Production before the Assessing Officer of account books or\nother evidences from which material evidence

SRI DINESH DEVRAJ RANKA,BENGALURU vs. ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE-8,, BENGALURU

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2011-12

section 36 have not been fulfilled. For ready reference the relevant portion of the said subsection is reproduced below. In making any deduction for a bad debt or part thereof; the following provisions shall apply - no such deduction shall be allowed unless such debt or part thereof has been taken into account in computing the income of the assessee

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

36. tax [Appeals] - 15, Bengaluru, passed under Section 250 of the Act dated 31/01/2025 for the impugned assessment year 2016-17, in so far as it is against the Appellant is opposed to law, weight of evidence, probabilities, facts and circumstances of the Appellant’s case. The appellant denies himself liable to be assessed on a total income 37. determined

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

36. tax [Appeals] - 15, Bengaluru, passed under Section 250 of the Act dated 31/01/2025 for the impugned assessment year 2016-17, in so far as it is against the Appellant is opposed to law, weight of evidence, probabilities, facts and circumstances of the Appellant’s case. The appellant denies himself liable to be assessed on a total income 37. determined

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

36. tax [Appeals] - 15, Bengaluru, passed under Section 250 of the Act dated 31/01/2025 for the impugned assessment year 2016-17, in so far as it is against the Appellant is opposed to law, weight of evidence, probabilities, facts and circumstances of the Appellant’s case. The appellant denies himself liable to be assessed on a total income 37. determined

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

36. tax [Appeals] - 15, Bengaluru, passed under Section 250 of the Act dated 31/01/2025 for the impugned assessment year 2016-17, in so far as it is against the Appellant is opposed to law, weight of evidence, probabilities, facts and circumstances of the Appellant’s case. The appellant denies himself liable to be assessed on a total income 37. determined

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

xii. The learned CIT(A) erred in not taking note that the onus was on the department and the AO to demonstrate that the entries in the disputed diary or seized material have resulted in materialised transactions giving rise to income of the assessee on the facts and circumstances of the case. ITA Nos.1021 to 1024/Bang/2024 ITA Nos.1290 to 1292/Bang/2024

WIPRO GE HEALTHCARE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

section 37 of the I T Act. 17.'The Learned AO/DRP erred in disallowing the written off receivables and advances of Rs. 1,63,36,390/- without objectively considering the explanation offered by the assessee. 18. The Learned AO / DRP erred in disallowing the following proyisions for expenses amounting to Rs. 41,76,13,362/- on an entirely unsustainable reason

HEWLETT PACKARD INDIA SALES PVT. LTD.,,BANGALORE vs. JCIT, BANGALORE

In the result, the appeal filed by the assessee stands allowed for statistical purposes and appeal filed by the revenue stands partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

gains of business or profession",— (a) in the case of any assessee— ******* (ia) thirty per cent of any sum payable to a resident, on which tax is deductible at source under Chapter XVII-B and such tax has not been deducted or, after deduction, has not been paid on or before the due date specified in sub-section (1

JCIT, BANGALORE vs. M/S HEWLETT - PACKARD INDIA SALES PRIVATE LIMITED, BANGALORE

In the result, the appeal filed by the assessee stands allowed for statistical purposes and appeal filed by the revenue stands partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

gains of business or profession",— (a) in the case of any assessee— ******* (ia) thirty per cent of any sum payable to a resident, on which tax is deductible at source under Chapter XVII-B and such tax has not been deducted or, after deduction, has not been paid on or before the due date specified in sub-section (1

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

1). It is well known fact that companies use sports event as a platform to advertise their range of products as it has a very high viewership. Any such incurring of expenditure is ostensibly for promotion of business only and hence, no disallowance is called for. Accordingly, Grounds No.7 to 7.3 in ITA No.1044/Del/2014 pertaining

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

xii. The ld. A.R. submitted that the proviso to section 2(15) is applicable only if a charitable trust has its activities in the nature of ‘advancement of any other object of general public utility’. xiii. The ld. A.R. therefore submitted that the proviso to section 2(15) finds no force under the facts and circumstances of the case

WIPRO GE HEALTHCARE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.291/Bang/2022 Assessment Year: 2017-18

xii) The AO/TPO/DRP erred in considering the following comparables overlooking/rejecting the objections made by the assessee 1) Deccan Dental Depot Pvt Ltd 2) Covidien Healthcare India Pvt Ltd 3) Vinod Medical Systems Pvt Ltd 4) Indian Hospitex Systems Pvt Ltd 5) India Medtronic Pvt Ltd 6) Sandor Medicaids Pvt Ltd 7) Iris Healthcare Technologies Pvt: Ltd 8) Medicept Dental India