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

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

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

11,02,609/-\nonly.\n22. During the assessment proceedings, the AO observed that the\nvaluation assigned to technology, business contracts and goodwill\nappeared artificial and unjustified. According to the AO, the Finacle and\nEdge-services business was primarily dependent on employees who were\ntransferred along with the business, and the skills, technical know-how\nand experience resided with such employees

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

11, 2003. Considering the above discussions, we are of the view that these are not the fit cases for initiation of the reassessment proceedings because the Assessing Officer failed to make out a case within the four corners of the provisions of section 147 of the Income-tax Act.” 69. The Hon’ble Delhi High Court in Commissioner of Income

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

11, 2003. Considering the above discussions, we are of the view that these are not the fit cases for initiation of the reassessment proceedings because the Assessing Officer failed to make out a case within the four corners of the provisions of section 147 of the Income-tax Act.” 69. The Hon’ble Delhi High Court in Commissioner of Income

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

D E R Per: Laxmi Prasad Sahu, A.M. These are cross appeals filed by the assessee and Revenue against the order of the CIT(A)-14, Bengaluru dated 31.12.2018 for AY 2015-16. 2. In ITA No. 321/Bang/2019 the assessee has raised the following grounds of appeal: - “1. The order of the learned Commissioner of Income Tax (Appeals

M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

D E R Per: Laxmi Prasad Sahu, A.M. These are cross appeals filed by the assessee and Revenue against the order of the CIT(A)-14, Bengaluru dated 31.12.2018 for AY 2015-16. 2. In ITA No. 321/Bang/2019 the assessee has raised the following grounds of appeal: - “1. The order of the learned Commissioner of Income Tax (Appeals

NEETA BHAMBHANI,BENGALURU vs. DCIT, (IT), CIRCLE-1(1), BENGALURU

In the result, I pass the following:-

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

11 of 24 8.1 Before proceeding further, it is apposite here to mention the relevant provisions of the Act as it stood then which are as follows- Time limit for notice. 149. (1) No notice under section 148 shall be issued for the relevant assessment year,- (a) if three years have elapsed from the end of the relevant assessment year

ARUN DURAISWAMY,MYSORE, KARNATAKA vs. ITO, INTL. TAXATION WARD 1(1), BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

11 of 23 Act does not arise at all. Thus, under the unamended Section 149(1)(b) of the Act, a notice under Section 148 of the Act could generally be issued within six years from the end of the relevant assessment year, provided the income escaping assessment amounted to or was likely to amount to one lakh rupees

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

1)\nTotal cost of acquisition (A+B+C+D)\nDevelopment cost for formation of layout (road, drainage, water supply, parks etc)\nBoard service charges at 10% on (F)\nInterest charged by the Board at 12.75% p.a on (F)\n(J)\nTotal cost of development (F+(+1)\n(K)\nTotal cost of acquisition and development |(E)- (J)]\n36. Once the total

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeal filed by the Revenue is allowed for statistical purpose

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahuthe Dy. Commissioner Of Vs Shri C. Gangadhara Murthy Income-Tax, No. 322, 3Rd A Corss, 2Nd Block Circle - 6(2)(1) 3Rd Stage, Basaveshwaranagar Bangalore . Bangalore 560079. Pan – Agipg 2668 N (Appellant) (Respondent)

D E R Per: L.P. Sahu, A.M. This is an appeal filed by the Revenue against the order of the ld. CIT(A), 6, Bengaluru in appeal ITA No. 107/R-9/CIT(A)-6/2014-15 dated 26.04.2018 for AY 2012-13 of the following grounds of appeal: - “1. The order of the CIT (Appeals) is opposed to law and the facts

THE KARNATAKA BANK LTD,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), MANGALURU

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

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranthe Karnataka Bank Ltd. Dcit, Circle - 2(1) Head Office, Mahaveera Circle Mangalore Vs. Kankanady Mangalore 575002 Pan – Aabct5589K Appellant Respondent Dcit, Circle – 2(1) The Karnataka Bank Ltd. Mangalore Head Office, Mahaveera Circle Vs. Kankanady Mangalore 575002 Pan – Aabct5589K Appellant Respondent Assessee By: Shri S. Ananthan, Ca & Smt. Lalitha Rameswaran, Ca Revenue By: Shri Mudavathu Harish Chandra Naik, Ca Date Of Hearing: 22.03.2022 Date Of Pronouncement: 26.05.2022 O R D E R Per: B.R. Baskaran, A.M. These Cross Appeals Are Directed Against The Order Dated 27-03-2018 Passed By Ld Cit(A), Mangaluru & They Relate To The Assessment Year 2014-15. 2. The Assessee Is A Banking Company Carrying On Banking Business. The Karnataka Bank Ltd.

D E R Per: B.R. Baskaran, A.M. These cross appeals are directed against the order dated 27-03-2018 passed by Ld CIT(A), Mangaluru and they relate to the assessment year 2014-15. 2. The assessee is a banking company carrying on banking business. The Karnataka Bank Ltd. 3. We shall first take up first the appeal filed

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

11,02,609/-\nonly.\n22.\nDuring the assessment proceedings, the AO observed that the\nvaluation assigned to technology, business contracts and goodwill\nappeared artificial and unjustified. According to the AO, the Finacle and\nEdge-services business was primarily dependent on employees who were\ntransferred along with the business, and the skills, technical know-how\nand experience resided with such employees

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

D E R PER KESHAV DUBEY, JUDICIAL MEMBER: These are cross appeals filed by the assessee as well as revenue which are against the orderdated 11/12/2023vide DIN & Order No. ITBA/NFAC/S/250/2023-24/1058652337(1) passed by the ld. CIT(A)/NFAC for the AY 2017-18 and order dated 06/11/2023 vide DIN & Order No.ITBA/NFAC/S/250/2023- 24/1057736394(1) passed

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

D E R PER BENCH: These appeals by the assessee in ITA Nos.294 to 296/Bang/2023 are directed against the order of NFAC, Delhi dated 12.1.2023 for the AYs 2018-19 to 2020-21 passed u/s 250 of the Income-tax Act,1961 ['the Act' for short]. The issue in all these appeals are common in nature except figures, hence, these

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

D E R PER BENCH: These appeals by the assessee in ITA Nos.294 to 296/Bang/2023 are directed against the order of NFAC, Delhi dated 12.1.2023 for the AYs 2018-19 to 2020-21 passed u/s 250 of the Income-tax Act,1961 ['the Act' for short]. The issue in all these appeals are common in nature except figures, hence, these

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

D E R PER BENCH: These appeals by the assessee in ITA Nos.294 to 296/Bang/2023 are directed against the order of NFAC, Delhi dated 12.1.2023 for the AYs 2018-19 to 2020-21 passed u/s 250 of the Income-tax Act,1961 ['the Act' for short]. The issue in all these appeals are common in nature except figures, hence, these

M/S. NIRMAL ENVIRO SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

D E R Per: Chandra Poojari, A.M. ITA No. 1148/Bang/2022 – AY 2019-20 This appeal by the assessee is directed against the order of the CIT(A)/NFAC, Delhi dated 18.11.2022 for AY 2019-20. 2. The facts are that for the assessment year under consideration the return of income was processed by the CPC and in the intimation issued

SRI PANATI VIDYANATH REDDY ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

D E R Per: Chandra Poojari, A.M. ITA No. 1148/Bang/2022 – AY 2019-20 This appeal by the assessee is directed against the order of the CIT(A)/NFAC, Delhi dated 18.11.2022 for AY 2019-20. 2. The facts are that for the assessment year under consideration the return of income was processed by the CPC and in the intimation issued