IBM GLOBAL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), BANGALORE

In the result, the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2000-2001

80J in relation to the profits and where such sale proceeds are credited to gains of the industrial undertaking; and a separate account maintained for the (iv) in computing the depreciation allowance purpose by the assessee with any bank under section 32, the written down value of outside India with the approval of the any asset used for the purposes

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

section-80J. In our view, since the expression of wider import, namely, "attributable to'', has been used, the legislature intended to cover receipts from sources other than the actual conduct of the business of generation and distribution of electricity.' 8. Therefore, the word "attributable to" is certainly wider in import than the expression "derived from". Whenever the legislature wanted

INCOME TAX OFFICER,WARD-1, HOSPET vs. GAYATRI PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA, HOSPET, HOSPET

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

gains derived from the conduct of the business of generation and distribution of electricity. In this connection, it may be pointed out that whenever the legislature wanted to give a restricted meaning in the manner suggested by the learned Solicitor General, it has used the expression \"derived from\", as for instance, in Section 80J. In our view, since the expression

INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU, BENGALURU vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED, BENGALURU

In the result both the appeals of the Revenue as well as\nCos of the Assessee for the Asst

gains derived from the\nconduct of the business of generation and distribution of electricity. In\nthis connection, it may be pointed out that whenever the legislature\nwanted to give a restricted meaning in the manner suggested by the\nlearned Solicitor General, it has used the expression "derived from", as\nfor instance, in Section 80J. In our view, since the expression

INCOME TAX OFFICER, WARD 1, UDUPI, UUPI vs. KAMBADAKONE RYTARA SEVA SAHAKARI SANGHA LTD, UDUPI

gains derived from the\nconduct of the business of generation and distribution of electricity. In\nthis connection, it may be pointed out that whenever the legislature\nwanted to give a restricted meaning in the manner suggested by the\nlearned Solicitor General, it has used the expression "derived from", as\nfor instance, in Section 80J. In our view, since the expression

INCOME TAX OFFICER, WARD-1, UDUPI vs. KAMBADAKONE RYTARA SEVA SAHAKARI SANGHA LTD, UPPUNDA

gains derived from the\nconduct of the business of generation and distribution of electricity. In\nthis connection, it may be pointed out that whenever the legislature\nwanted to give a restricted meaning in the manner suggested by the\nlearned Solicitor General, it has used the expression \"derived from\", as\nfor instance, in Section 80J. In our view, since the expression

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME-TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section 80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity."\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section 80J.\nIn our view, since the expression of wider import, namely,\n\"attributable to\", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word \"attributable to\" is certainly wider in\nimport than the expression \"derived from\". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section 80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK ,BENGALURU vs. INCOME-TAX OFFICE, WARD-5(2)(1), BENGALURU

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section 80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

section 80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity."\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD- 5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section 80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. THE INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section 80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section 80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity."\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section 80J.\nIn our view, since the expression of wider import, namely,\n\"attributable to\", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from

JAMMANAHALLY PRATHAMIKA KRISHI PATTINA SAHAKARA SANGHA,BALLUPET vs. INCOME TAX OFFICER, WARD-2, HASSAN

In the result ITA No. 192/Bangalore/2025 filed by the assessee is allowed

Bench: Shri Prashant Maharishi

section-80J. In our view, since the expression of wider import, namely, "attributable to'', has been used, the legislature intended to cover receipts from sources other than the actual conduct of the business of generation and distribution of electricity.' 8. Therefore, the word "attributable to" is certainly wider in import than the expression "derived from". Whenever the legislature wanted

JAMMANAHALLY PRATHAMIKA KRISHI PATTINA SAHAKARA SANGHA,SAKLESHPUR vs. INCOME TAX OFFICER, WARD -2, HASSAN

In the result ITA No. 192/Bangalore/2025 filed by the assessee is allowed

Bench: Shri Prashant Maharishi

section-80J. In our view, since the expression of wider import, namely, "attributable to'', has been used, the legislature intended to cover receipts from sources other than the actual conduct of the business of generation and distribution of electricity.' 8. Therefore, the word "attributable to" is certainly wider in import than the expression "derived from". Whenever the legislature wanted

PRIMARY AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU -3, BENGALURU

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2020-21

section-80J. In our view, since the expression of wider import, namely, "attributable to'', has been used, the legislature intended to cover receipts from sources other than the actual conduct of the business of generation and distribution of electricity.' 8. Therefore, the word "attributable to" is certainly wider in import than the expression "derived from". Whenever the legislature wanted