JURIMATRIX SERVICES INDIA PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 4(3)(1), BENGALURU

In the result, appeal of the assessee is dismissed

Bench: Shri Waseem Ahmed\Nand\Nshri Keshav Dubey\Nita No.92/Bang/2025\N Assessment Years:2018-19\Njurimatrix Services India Pvt. Ltd.\Ng4, Aspen Building\Nmanyata Embassy Business Park\Nhebbal\Nbangalore 560045\Npan No: Aabcj6157D\Nappellant\Nacit\Nvs. Circle 4(3)(1)\Nbangalore\Nrespondent\Nappellant By : Sri K.R. Girish, A.R.\Nrespondent By : Ms. Neha Sahay, D.R.\Ndate Of Hearing : 21.04.2025\Ndate Of Pronouncement: 15.07.2025\Norder\Nper Keshav Dubey:\Nthis Appeal At The Instance Of The Assessee Is Directed Against\Nthe Order Of The Ld. Pcit Dated 30.03.2023 Vide Din & Order No.\Nitba/Rev/F/Rev5/2022-23/1051648832(1) Passed U/S 263 Of\Nthe Income Tax Act, 1961 (In Short “The Act”) For The Assessment\Nyear 2018-19.\N2. The Assessee Has Raised The Following Grounds Of Appeal:\Ngeneral Grounds Of Appeal\N1.

34,00,732 was taxable under\nsection (\"u/s\") 115JB of the Act and tax including interest thereon totaling to Rs\n1,18,08,674 was paid.\nSubsequently, the Company received notices u/s 143(2) and section 142(1) of the\nAct calling for certain information/details. The information called for was furnished\nfrom time to time. Thereafter the Learned Assessing Officer

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

34 and accordingly we inclined to condone the delay and admit the appeal for adjudication on merits. 16. The Ground No 1 is general in nature and does not require any adjudication. 16.1 The Ground No 2 deals with disallowance under section 14A read with rule 8D. The brief facts of the case are as under- During the year

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.

10,92,957/- on\n\nPage 19 of 34\n\naccount of foreign tax credit in respect of taxes presently under dispute with\nAustralian Tax Authorities) in respect of income on which the deduction\nunder section 10AA of the Act has been claimed.\n\n11.1 The AO disallowed the foreign tax credit related to incomes\neligible for deduction under section

SHRI. VIRUPAXAPPA SIDDAPPA UDNUR,BENGALURU vs. INCOME TAX OFFICER, WARD-9(2), BENGALURU

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

Bench: Shri Chandra Poojariassessment Year: 2009-10

Section 234D of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts of the case. The Appellant craves leave of this Hon'ble Income Tax 6. Appellate Tribunal to add, alter, delete or substitute

NAVODAYA EDUCATION TRUST,RAICHUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY

In the result, the appeal of the assessee is dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2015-16

section 154, the action of the AO in rejecting the rectification application was to be upheld. 34. We have heard both the parties and perused the material on record. As per CBDT Circular No.7/2018, the Commissioner could condone the delay in filing Form 10

AUGUST JEWELLERY PRIVATE LIMITED,BENGALURU vs. D.C.I.T., CIRCLE 1(1)(1), BENGALURU, BENGALURU

section 68 of the Act, @ 10% of the tax and\nsurcharge which comes to Rs.4,37,34,600.\n34.\nThe assessee, being aggrieved, filed appeal on 08/10/2024 with a\ndelay of 70 days. During the appellate proceedings, the learned NFAC\nrejected the assessee's prayer for condonation of delay

BANGALORE METRO RAIL CORPORATION LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranassessment Year : 2009-10 Bangalore Metro Rail Corporation Ltd., Dcit, Vs. 3Rd Floor, Bmtc Complex, Circle – 11(2), K H Road, Shanti Nagar, Bengaluru. Bengaluru-560 027. Pan : Aaacb 4881 D Appellant Respondent Assessee By : Shri. A. Shankar, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 01.04.2022 Date Of Pronouncement : 19.04.2022 O R D E R Per N V Vasudevan

34,673/-.” 10. Aggrieved by the order of the CIT(A), the assessee has filed appeal before the Tribunal. 11. As far as the application for condoning delay in filing this appeal is concerned, it has been submitted in an affidavit in support of the application for condonation of delay that the assessee was subjected to wrong professional advice

AUGUST JEWELLERY PVT LTD,BENGALURU vs. D.C.I.T., CIRCLE 1(1)(1), BENGALURU, BENGALURU

section 68 of the Act, @ 10% of the tax and\nsurcharge which comes to Rs.4,37,34,600.\n34.\nThe assessee, being aggrieved, filed appeal on 08/10/2024 with a\ndelay of 70 days. During the appellate proceedings, the learned NFAC\nrejected the assessee's prayer for condonation of delay

AUGUST JEWELLERY PVT LTD,BENGALURU vs. D.C.I.T., CIRCLE 1(1)(1), BANGALORE, BANGALORE

section 68 of the Act, @ 10% of the tax and\nsurcharge which comes to Rs.4,37,34,600.\n34.\nThe assessee, being aggrieved, filed appeal on 08/10/2024 with a\ndelay of 70 days. During the appellate proceedings, the learned NFAC\nrejected the assessee's prayer for condonation of delay

M/S. CANDOR BUSINESS SOLUTIONS PRIVATE LIMITED,BENGALURU vs. INCOME TAX OFFICER, WARD-2(1)(1),, BENGALURU

In the result, the appeal by the assessee is allowed

Bench: Shri Chandra Poojariassessment Year : 2013-14

condonation petition explaining the reason for delay in filing this appeal as follows:- Page 2 of 15 “AFFIDAVIT I Smt. Umadevi S Y, aged 49 years, residing at Hampi Nagar, Bengaluru, do hereby swear on oath as under that 1. I am a Director of the Appellant Company, namely, Candor Business Solutions Private Limited and am well aware

BASAVANNEPPA GULEDAKERI,HAVERI vs. INCOME TAX OFFICER, WARD-2, HAVERI

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

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

section 115BBE of the Act even though the said provisions are applicable from 01.04.2017 i.e financial year 2017-18.” 3. At the outset, the ld. A.R. of the assessee submitted that there is an actual delay of 49 days in filing the appeal before this Tribunal, however the assessee in his condonation application had inadvertently mentioned the delay

ASST.C.I.T., BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

TEJAS NETWORKS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

M/S TEJATS NETWORKS LIMITED ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL , BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

TEJAS NETWORKS LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

M/S. TEJAS NETWORKS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged