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

10,92,957 in relation to income on which deduction under section 10AA was claimed) once the dispute is settled 5. Levy of interest under section 234B: 5.1. The levy of interest under section 234B is bad in law and liable to be quashed. 6. Prayer: 6.1. Based on the above grounds and other grounds adduced at the time

M/S HERBALIFE INTERNATIONAL INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-11(4), BANGALORE

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

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaranassessment Year :2008-09 M/S. Herbalife International India Vs. Dcit - 11(4), Private Limited, Bengaluru. Pardhanani Wilshire #14, Commissariat Road, Bengaluru – 560 025. Pan : Aaach 8025 R Appellant Respondent Assessee By : Shri. Nageshwar Rao, Advocate Revenue By : Shri. Sankar Ganesh K, Jcit(Dr)(Itat), Bengaluru Date Of Hearing : 27.12.2021 Date Of Pronouncement : 29.12.2021 O R D E R Per N. V. Vasudevanthis Is An Appeal Filed By The Assessee Against Order Dated 27.08.2018 Of Cit(A)-3, Bengaluru, Relating To Assessment Year 2008-09. The Grounds Of Appeal Nos.2 To 12 Raised By The Assessee Reads As Follows:

section 263 of the Act by an Order dated 17.03.2014. In this order, the CIT was of the view that the assessee had claimed depreciation at 100% on lease hold improvements of Rs.2,10

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

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

Section 10A, as amended by the Finance Act of 2003, granting the benefit of adjustment of losses and unabsorbed depreciation etc. commencing from ITA No.1222, 1516 & 1517/Bang/2017 Page 10

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

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

Section 10A, as amended by the Finance Act of 2003, granting the benefit of adjustment of losses and unabsorbed depreciation etc. commencing from ITA No.1222, 1516 & 1517/Bang/2017 Page 10

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

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

Section 10A, as amended by the Finance Act of 2003, granting the benefit of adjustment of losses and unabsorbed depreciation etc. commencing from ITA No.1222, 1516 & 1517/Bang/2017 Page 10

M/S. SJR ENTERPRISES PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Year: 2009-10

depreciation claim to the extent of Rs.5,82,576/-. However, the Assessee requested that as this mistake was apparent on the face of the record and was rectifiable by the O under section 154, the proceedings under section 263 should be dropped on this point. 2.2 As regards the aspect of incorrect allowance of deduction under section 80-IB(10

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 in relation to income on which deduction under\nsection 10AA was claimed) once the dispute is settled\n\n5.\n\nLevy of interest under section 234B:\n\n5. 1. The levy of interest under section 234B is bad in law and liable to be\nquashed.\n\n6.\n\nPrayer:\n\n6. 1. Based on the above grounds

DCIT, BANGALORE vs. M/S NOUS INFO SYSTEMS PVT. LTD.,, BANGALORE

In the result, the Revenue’s appeal is dismissed

Bench: Shri Vijay Pal Rao & Shri. S. Jayaramani.T.A No.63/Bang/2016 (Assessment Year : 2007-08) Deputy Commissioner Of Income Tax, Circle -5(1)(1), Bengaluru .. Appellant V. M/S. Nous Info Systems P. Ltd, No.1, 1St Main, 1St Block, Koramangala, Bengaluru 560 004 .. Respondent Pan : Aaacn4584B Assessee By : Shri. Ujwal Tiwari, Ca Revenue By : Shri. Vijaykumar N, Addl. Cit Heard On : 14.09.2016 Pronounced On : 11 .11.2016 O R D E R Per S. Jayaraman:

depreciation under Section 32(2) is to be set off. As deduction under Section 10-A has to be excluded

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

10. However, the AO rejected the assessee’s explanation. The AO found that the license soft-wares are classified as an intangible asset as per Appendix-1 of IT Rules and as per part-B of the appendix-1, the same is eligible to depreciate at 25%. The AO also referred to Accounting Standard 26-Intangible Assets which describes that

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

10. However, the AO rejected the assessee’s explanation. The AO found that the license soft-wares are classified as an intangible asset as per Appendix-1 of IT Rules and as per part-B of the appendix-1, the same is eligible to depreciate at 25%. The AO also referred to Accounting Standard 26-Intangible Assets which describes that

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

10. However, the AO rejected the assessee’s explanation. The AO found that the license soft-wares are classified as an intangible asset as per Appendix-1 of IT Rules and as per part-B of the appendix-1, the same is eligible to depreciate at 25%. The AO also referred to Accounting Standard 26-Intangible Assets which describes that

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

10, 2018, passed under section 143(3) read with section 144C(1) and section 92CD of the Income-tax Act, 1961 ('Act'), by the learned Assistant Commissioner of Income-tax, Circle - 4(1)(2), Bangalore ('ACIT'), be struck down as invalid, as the order is bad in law and on facts. 2. Reliance on the Draft Assessment Order

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

Section 40(a) of the Act has no application to depreciation claimed by the assessee. He relied on the following Case laws: PCIT v. Tally Solutions (P.) Ltd. (reported in [2021] 123 taxmann.com 21 (Karnataka)- para 10

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

Section 40(a) of the Act has no application to depreciation claimed by the assessee. He relied on the following Case laws: PCIT v. Tally Solutions (P.) Ltd. (reported in [2021] 123 taxmann.com 21 (Karnataka)- para 10

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-12 , BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

Section 40(a) of the Act has no application to depreciation claimed by the assessee. He relied on the following Case laws: PCIT v. Tally Solutions (P.) Ltd. (reported in [2021] 123 taxmann.com 21 (Karnataka)- para 10

KARNATAKA HOUSING BOARD ,BANGALORE vs. DCIT, EXEMPTIONS CIRLCE-1, BANGALORE

In the result, the appeals filed by the assessee is allowed with the above directions

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

10,68,604/-; vi) 'Deduction be allowed in respect of depreciation of Rs.37,48,862/-; vii) Delete additions on account of disallowance under section

KARNATAKA HOUSING BOARD ,BANGALORE vs. DCIT, EXEMPTIONS CIRLCE-1, BANGALORE

In the result, the appeals filed by the assessee is allowed with the above directions

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

10,68,604/-; vi) 'Deduction be allowed in respect of depreciation of Rs.37,48,862/-; vii) Delete additions on account of disallowance under section

THE ARCHDIOCESAN BOARD OF EDUCATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS) CIRCLE-1, BANGALORE

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

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadaleassessment Year : 2008-09 M/S. The Archdiocesan The Deputy Board Of Education, Commissioner Of Archbishop’S House, No. 75 Income Tax Vs. Millers Road, Benson Town, (Exemptions), Bangalore – 560 046. Circle – 1, Pan: Aabat5296P Bangalore. Appellant Respondent

10 of the case law compilation filed by ld. DR of revenue. The ld. DR of revenue also placed reliance on the judgment of Hon’ble Allahabad High Court rendered in the case of Ashok Kumar Dixit Vs. ITO as reported in [1992] 198 ITR 669 (All.). He also placed reliance on the judgment of Hon’ble Kerala High Court