NORTHERN OPERATING SERVICES PRIVATE LIMITED,ARGON SOUTH TOWER vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 5 (1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2020-21 M/S. Northern Operating Services Pvt. Ltd., Vs. Dcit, 2Nd Floor Rmz Ecopace, Circle – 5(1)(1), Campus 1C, Bengaluru. Sarjapur Outer Ring Road, Bellandur, Bengaluru – 560 103. Pan : Aaccn 1652 J Appellant Respondent Assessee By : Ms. Divya Motwani, Ca. Revenue By : Shri. D. K. Mishra, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 26.09.2024 Date Of Pronouncement : 27.09.2024

Gains from Business / Profession”. Expenses prescribed under sections 32 to 36 of the Act are not allowed for deduction under section 37 of the Act if it is not incurred for the purpose of business. Finance Bill, 2014, introduced explanation to section 37 of the Act deeming CSR expenditure to be an expenditure as not being incurred for the purpose

INFOSYS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by the assessee is partly allowed and the\nappeal filed by the revenue is dismissed

Bench: Shri Waseem Ahmed\Nand\Nshri Keshav Dubey\N\N\Nita No. 881/Bang/2023\N Assessment Year: 2019-20\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nvs.\N\Ndy. Commissioner Of Income Tax\Ncircle - 3(1)(1)\Nbmtc Building, 80 Feet Road\Nkoramangala, Bangalore – 560095\Nkarnataka\N\Nrespondent\N\Nita No. 245/Bang/2024\N Assessment Year: 2019-20\N\Njt. Commissioner Of Income Tax (Osd)\Ncircle - 3(1)(1)\Nroom No. 241, 2Nd Floor\Nbmtc Building, 80 Feet Road\N6Th Block, Koramangala\Nbangalore - 560095\Nkarnataka\N\Nvs.\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nrespondent\N\Nassessee By\Ndepartment By\N\Nsri Padam Chand Khincha – Ca\Nsmt. Srinandini Das – Cit - Dr\N\Ndate Of Hearing\Ndate Of Pronouncement:\N\N09.05.2025\N06.08.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Cross Appeals Are Filed Against The Order Of Ld. Commissioner Of\Nincome Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short \"Ld.\Ncit(A)/Nfac] Vide Din & Order No. Itba/Nfac/S/250/2023-24/1056786183(1) Dated 05.10.2023 Passed U/S.250 Of The Income Tax\Nact, 1961 (In Short “The Act\") For The A.Y.2019-20.\N\Npage 2 Of 34\N\N2. The Assessee Has Raised The Following Grounds Of Appeal: - \N\N\"1.\N\Ngeneral Ground\N\N1.

80G of the Act ignoring that in instant case assessee has\nnot satisfied conditions set out in said section to get the said deduction'?\n\n6.\nThe CIT(A) erred in allowing the claim of Rs.276,67,93,689/- as\ndeduction from overseas revenue on account of state taxes paid outside India.\n\n7.\nThe CIT(A) erred in considering

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU, BENGALURU vs. INFOSYS LIMITED, BENGALURU

In the result, appeal filed by the assessee is partly allowed and the appeal filed by the revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

80G of the Act ignoring that in instant case assessee has not satisfied conditions set out in said section to get the said deduction'? 6. The CIT(A) erred in allowing the claim of Rs.276,67,93,689/- as deduction from overseas revenue on account of state taxes paid outside India. 7. The CIT(A) erred in considering the amount

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

section 80G of Rs. 4,05,98,408/- and 80IAB of Rs. 585,09,09,819/-. The case was selected for scrutiny and notice u/s 143(2) was issued and other statutory notices were issued to the assessee and assessee also responded to the notices. The assessee claimed exemption u/s 10AA being profit of SEZ units. The total income also

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

capital gain tax can be levied. " 53. Concluded at page 12 para 21 as under: "27. In the result, we hold that sub-section 115JB as it stood prior to its amendment by virtue of Finance Act, 2012, would not be applicable to a banking company. We answer the question No. 2 in favour of the assessee and against

CITY HOSPITAL CHARITABLE TRUST ,MANGALORE vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: Na

capital expenditure applied during the year as application of income u/s. 11(1) of the Act as well as accumulation of 15% of income from such property which shall not be included in the total income. On going through the Income & Expenditure A/c for last 3 years reproduced by the ld. CIT(E) we take a note of the fact

DR. T M A PAI FOUNDATION ,UDUPI vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: Na

capital expenditure applied during the year as application of income u/s. 11(1) of the Act as well as accumulation of 15% of income from such property which shall not be included in the total income. On going through the Income & Expenditure A/c for last 3 years reproduced by the ld. CIT(E) we take a note of the fact

ACADEMY OF LIBERAL EDUCATION REGD ,SULLIA vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: Na

capital expenditure applied during the year as application of income u/s. 11(1) of the Act as well as accumulation of 15% of income from such property which shall not be included in the total income. On going through the Income & Expenditure A/c for last 3 years reproduced by the ld. CIT(E) we take a note of the fact

ACADEMY OF GENERAL EDUCATION,UDUPI vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: Na

capital expenditure applied during the year as application of income u/s. 11(1) of the Act as well as accumulation of 15% of income from such property which shall not be included in the total income. On going through the Income & Expenditure A/c for last 3 years reproduced by the ld. CIT(E) we take a note of the fact

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

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

Bench: Chandra Poojari & Smt. Beena Pillai

capital gain tax can be levied. " 53. Concluded at page 12 para 21 as under: ITA Nos. 391, 392 & 663/Bang/2023 Page 13 of 31 "27. In the result, we hold that sub-section 115JB as it stood prior to its amendment by virtue of Finance Act, 2012, would not be applicable to a banking company. We answer the question

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2(1)(1), BANGALORE vs. CANARA BANK, BANGALORE

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

Bench: Chandra Poojari & Smt. Beena Pillai

capital gain tax can be levied. " 53. Concluded at page 12 para 21 as under: ITA Nos. 391, 392 & 663/Bang/2023 Page 13 of 31 "27. In the result, we hold that sub-section 115JB as it stood prior to its amendment by virtue of Finance Act, 2012, would not be applicable to a banking company. We answer the question

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

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

Bench: Chandra Poojari & Smt. Beena Pillai

capital gain tax can be levied. " 53. Concluded at page 12 para 21 as under: ITA Nos. 391, 392 & 663/Bang/2023 Page 13 of 31 "27. In the result, we hold that sub-section 115JB as it stood prior to its amendment by virtue of Finance Act, 2012, would not be applicable to a banking company. We answer the question

M/S. INDUS TRUST ,BENGALURU vs. ACIT, CIRCLE-2(2)(1), BENGALURU

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

80G of the Act\nshould be granted as the payment was not incurred for any personal or\nnon-business purpose. Hence, disallowance under section 37(1) of the\nAct was unwarranted.\n6.5 It was also pointed out that the AO disallowed the claim\nmechanically without disputing the genuineness of the payment, the\nidentity of the recipient, or the actual application

ADDITIONAL COMMISSIONER OF INCOME TAX,SPECIAL RANGE - 1 , BANGALORE vs. M/S. BANGALORE METRO RAIL CORPORATION LIMITED, BANGALORE

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

section 30 to 36 of the Act not being in the nature of capital expenditure or personal expenditure of the assessee laid out are expended wholly and exclusively for the purpose of business or profession and the assessee shall be allowed in computing the income chargeable under the head “profit and gains of business or profession”. The main thrust

M/S. BANGALORE METRO RAIL CORPORATION LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1)(2), BANGALORE

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

section 30 to 36 of the Act not being in the nature of capital expenditure or personal expenditure of the assessee laid out are expended wholly and exclusively for the purpose of business or profession and the assessee shall be allowed in computing the income chargeable under the head “profit and gains of business or profession”. The main thrust

M/S. BANGALORE METRO RAIL CORPORATION LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1)(2), BANGALORE

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

section 30 to 36 of the Act not being in the nature of capital expenditure or personal expenditure of the assessee laid out are expended wholly and exclusively for the purpose of business or profession and the assessee shall be allowed in computing the income chargeable under the head “profit and gains of business or profession”. The main thrust

M/S. BANGALORE METRO RAIL CORPORATION LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(2), BANGALORE

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

section 30 to 36 of the Act not being in the nature of capital expenditure or personal expenditure of the assessee laid out are expended wholly and exclusively for the purpose of business or profession and the assessee shall be allowed in computing the income chargeable under the head “profit and gains of business or profession”. The main thrust

M/S. BANGALORE METRO RAIL CORPORATION LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(2), BANGALORE

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

section 30 to 36 of the Act not being in the nature of capital expenditure or personal expenditure of the assessee laid out are expended wholly and exclusively for the purpose of business or profession and the assessee shall be allowed in computing the income chargeable under the head “profit and gains of business or profession”. The main thrust