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

36(1)(vii) iii-iv CSR Expenditure Revenue appeal vii-viii RBI penalty Revenue appeal ix Club Expenses Revenue appeal 5. At the outset, the Ld. DR submitted that there is a delay of 109 days in filing the revenue’s appeal before this Tribunal. The revenue has filed condonation petition dated 04.09.2023 seeking the delay to be condoned

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

36(1)(vii) iii-iv CSR Expenditure Revenue appeal vii-viii RBI penalty Revenue appeal ix Club Expenses Revenue appeal 5. At the outset, the Ld. DR submitted that there is a delay of 109 days in filing the revenue’s appeal before this Tribunal. The revenue has filed condonation petition dated 04.09.2023 seeking the delay to be condoned

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.

36 - 04 March 2025\nComputation of delay in filing of appeal before CIT(A):\nDue date of filing appeal before Ld. CIT(A) - Where the appeal relates to any\nassessment or penalty, an appeal should be presented within 30 days from the\ndate of service of notice of demand relating to the assessment or penalty order.\nPage

SRI. ANNESH,UDUPI vs. INCOME-TAX OFFICER, WARD-1, CHIKMANGALUR

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojari

condonation of delay 4. Notice dated 01.12.2022 07.12.2022 No compliance 2.2 Finally, the ld. CIT(A) disposed of the appeal ex-parte by observing as under: “7. During the appellate proceedings, the appellant has only submitted submission in the form of 'Statement of Facts'. After that neither he has replied to hearing notices nor submitted any documentary evidence/information to prove

M/S. CONCORDE HOUSING CORPORATION PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

condone the delay for 4 days in both the appeals and admit the appeals for adjudication. ITA No.532/Bang/2024 (AY 2015-16): 2. Facts of the issue in this appeal are that the appellant, engaged in real estate project development in Bangalore and affiliated with various grot+ companies and firms, was subject to a search and seizure operation under Section

INCOME TAX OFFICER, WARD - 3(2)(3), BANGALORE vs. SRI MADE GOWDA THIBBE GOWDA, BANGALORE

In the result, the appeal of the revenue is dismissed and CO of the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2008-09

Condonation of delay if any. The Ground No. 2 of the Revenue's Appeal is liable to be dismissed since the Ld. CIT(A) was justified to hold that the AO did not have any information except information received from the Investigation Wing. 3. The Ground No.3 of the Revenue's Appeal is liable to be dismissed since the statement

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

viii) Further the scenario is also completely changed after insertion of section 80AB w.e.f 1/4/1981, and, therefore also the appellant's argument is not acceptable. As regards section 80 AB, it is also worthwhile to note that the decision in the cases of Distributors Baroda, Motilal Pesticides and Vijay Industries, the assessment years involved were

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

viii) Further the scenario is also completely changed after insertion of section 80AB w.e.f 1/4/1981, and, therefore also the appellant's argument is not acceptable. As regards section 80 AB, it is also worthwhile to note that the decision in the cases of Distributors Baroda, Motilal Pesticides and Vijay Industries, the assessment years involved were

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

36 of 86\nIT(TP)A Nos. 303 & 839/Bang/2022\n() Under 144C(5) of the I.T.Act, 1961 DRP IS ONLY REQUIRED TO ISSUE DIRECTIONS TO THE AO. The relevant sub-section is reproduced below\n(5) The Dispute. Resolution Panel shall, in a case where any objection is received under sub-section (2), issue such directions, as it thinks

SOCIETE GENERALE GLOBAL SOLUTION CENTRE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2018-19

36, the Appellant humbly wishes to pursue the following ground- 8. That the addition(s) of INR 4,26,84,797 towards 'net loss on derivative instruments' under ICDS VI (Changes in Foreign Exchange Rates) made in the intimation dated 10 June 2020 issued under section 143(1) of the Act is infructuous as the said addition

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

viii) Whether all the officers whose names are there in the panchanama are authorized or not. ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore Page 22 of 115 It was further contended that the learned assessing m) officer has to discharge the burden of proving that there is a valid initiation of search under section 132(1

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

viii) Whether all the officers whose names are there in the panchanama are authorized or not. ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore Page 22 of 115 It was further contended that the learned assessing m) officer has to discharge the burden of proving that there is a valid initiation of search under section 132(1

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

viii) Whether all the officers whose names are there in the panchanama are authorized or not. ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore Page 22 of 115 It was further contended that the learned assessing m) officer has to discharge the burden of proving that there is a valid initiation of search under section 132(1

PREM PRAKASH GUPTA ,BANGALORE vs. ITO, WARD-6(2)(2), BANGALORE

Appeal of the assessee stands dismissed as not admitted

Bench: Shri Prashant Maharishiassessment Year: 2017-18

section 250 of the Act before this Hon'ble Tribunal and hear the same on merits for the advancement of substantial cause of justice. 11. The appellant places reliance on the decision of the Hon'ble Jurisdictional High Court in the case of CIT & Another Vs. ISRO Satellite Center, in ITA No. 532 of 2008 and other batch of appeal

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

viii) Rental income from BSNL amounting to Rs.12,000 3.2. On facts and circumstances of the case and law applicable, the appellant is entitled for the claim of deduction under section 10AA of the Act on the above incomes included in the profits of eligible SEZ units. 4. Foreign tax credit relating to income eligible for deduction under section 10AA

STATE BANK OF INDIA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 16(2), BANGALORE

In the result, the appeal is allowed

Bench: Shri N.V. Vasudevan & Shri D.S. Sunder Singhassessment Year: 2013-14

delay in filing the appeal is condoned. 4. As far as merits of the appeal is concerned, the facts are that the assessee bank paid during the FY 2012-13 a sum of Rs.60,67,388 being interest on deposit to Karnataka Building & Other Construction Workers Welfare Board. The assessee did not deduct tax at source at the time

SHREE HANUMAN CREDIT SOUHARD SAHAKARI LIMITED,CHIKODI vs. PR. COMMISSIONER OF INCOME-TAX, HUBLI

In the result, the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2017-18

viii. The appellant prays and submits that the delay in filing this appeal was due to an inadvertent error and due to circumstances beyond the control of the appellant.” 6. We heard the rival submissions and perused the materials on record. We notice that the Hon’ble Supreme Court, in the case of Collector, Land Acquisition Vs. MST.Katiji

MR. SALEEM THANGAL KADER PLAKAD,INDIVIDUAL,UDUPI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MANGALURU

In the result, the appeals of the assessee are partly allowed

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

delay in filing the appeal is condoned. 3. The brief facts of the case are that the assessee filed income tax return u/s. 139(1) for all the 3 years. Search and seizure action was conducted u/s. 132 of the Act on 01.02.2017 in the business premises of Badagabettu Credit Co-operative Society Ltd., Udupi and documents were seized