DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

3)", "Section 154", "Section 234B", "Section 234D", "Section 32(1)(iia)", "Section 2(29A)", "Section 147"], "issues": "Whether disallowance under Section 14A is valid without exempt income, whether additional depreciation

DINESH KUMAR SINGHI,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2011-12 is partly allowed

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

154 (PB-2 page 589) and also proceeding u/s 148 was initiated and the same stands closed in the absence of any further development (PB-2 page 591). The issue of notice u/s 148 was against law and however in the absence of any order the assessee has no grievance to pursue. The assessment came to be concluded u/s 153A

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

154 order, the ld. AO has enhanced the addition. He\nprayed that this appeal may also be remanded back to the ld. CIT(A)\nto consider together.\nThe ld. D.R. did not object for the issue to be remanded to the ld.\nCIT(A). Accordingly, we remand this issue back to the ld. CIT(A). It\nis directed 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

Section 92CC with the caption “Advance Pricing Agreement” provides through sub-section (1): `The Board, with the approval of the Central Government, may enter into an advance pricing agreement with any person, determining the arm's length price … in relation to an international transaction …’. Sub-section (2) gives the manner of determination of the ALP referred to in sub-section

SHRI. JITENDRA VIRWANI,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

154(Bom) = (2010-TIOL-146-HC-MUM- IT) after considering the decision of the Hon'ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Pvt. Ltd. 291 ITR 500 (SC) = (2007-TIOL-95-SC-IT) has held that even when an intimation is issued u/s. 143(1) of the Act, the validity of initiation of reassessment proceedings

SHRI. JITENDRA VIRWANI,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

154(Bom) = (2010-TIOL-146-HC-MUM- IT) after considering the decision of the Hon'ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Pvt. Ltd. 291 ITR 500 (SC) = (2007-TIOL-95-SC-IT) has held that even when an intimation is issued u/s. 143(1) of the Act, the validity of initiation of reassessment proceedings

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

154(Bom) = (2010-TIOL-146-HC-MUM- IT) after considering the decision of the Hon'ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Pvt. Ltd. 291 ITR 500 (SC) = (2007-TIOL-95-SC-IT) has held that even when an intimation is issued u/s. 143(1) of the Act, the validity of initiation of reassessment proceedings

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

154(Bom) = (2010-TIOL-146-HC-MUM- IT) after considering the decision of the Hon'ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Pvt. Ltd. 291 ITR 500 (SC) = (2007-TIOL-95-SC-IT) has held that even when an intimation is issued u/s. 143(1) of the Act, the validity of initiation of reassessment proceedings

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154