M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

17 to decide claims of all banks including the co-operative banks. Mr. U. U. Lalit, learned Senior Advocate appearing on behalf of the respondent ……………….. Co-operative banks transacting the banking ITA Nos.388 & 389/Bang/2023 Page 14 of 27 business are, therefore, covered by the RDB Act in terms of the meaning of "banking company" under Section 2(d

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

17 to decide claims of all banks including the co-operative banks. Mr. U. U. Lalit, learned Senior Advocate appearing on behalf of the respondent ……………….. Co-operative banks transacting the banking ITA Nos.388 & 389/Bang/2023 Page 14 of 27 business are, therefore, covered by the RDB Act in terms of the meaning of "banking company" under Section 2(d

M/S VOLVO INDIA PVT. LTD. vs. ACIT, BANGALORE

In the result, appeal of the Assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

section 32(1)(ii) of the Act. The basis of valuation is set out in para-11 of the valuation report of Bizworth in our view is in fact an intangible acquired by the Assessee and the basis of estimation of its value is reasonable and acceptable. We therefore direct that depreciation be allowed on this intangible treating

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

5) of Section 80-IA, which are also required to be read into Section 804B. [see Section 80-18(13)]. We may reiterate that Sections 801, 80-IA and 80-lB have a common scheme and if so read it is clear that the said sections provide for incentives in the form of deduction(s) which are linked to profits

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

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

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

BANGALORE INTERNATIONAL AIRPORT LTD.,,BANGALORE vs. DCIT, BANGALORE

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

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raobangalore International Airport Ltd. Administration Block, Bial, Devanahalli Bangalore-560 300. … Appellant Pan:Aabc8973D Vs. Deputy Commissioner Of Income-Tax, Circle 11(2), Bangalore. … Respondent & Deputy Commissioner Of Income-Tax, Circle 11(2), Bangalore. … Appellant Vs. Bangalore International Airport Ltd. Bangalore-560 300. … Respondent

d) the amount by way of provision for losses of subsidiary companies; e) or the amount or amounts of dividends paid or proposed ; or f) the amount or amounts of expenditure relatable to any income to which section 10 (other than the provisions contained in clause (38) thereof) or section 11 or section 12 apply; or g) the amount

DCIT, BANGALORE vs. M/S BANGALORE INTERNATIONAL AIRPORT LTD.,, BANGALORE

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

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raobangalore International Airport Ltd. Administration Block, Bial, Devanahalli Bangalore-560 300. … Appellant Pan:Aabc8973D Vs. Deputy Commissioner Of Income-Tax, Circle 11(2), Bangalore. … Respondent & Deputy Commissioner Of Income-Tax, Circle 11(2), Bangalore. … Appellant Vs. Bangalore International Airport Ltd. Bangalore-560 300. … Respondent

d) the amount by way of provision for losses of subsidiary companies; e) or the amount or amounts of dividends paid or proposed ; or f) the amount or amounts of expenditure relatable to any income to which section 10 (other than the provisions contained in clause (38) thereof) or section 11 or section 12 apply; or g) the amount

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

5) of Section 80-IA, which are also required to be read into Section 804B. [see Section 80-18(13)]. We may reiterate that Sections 801, 80-IA and 80-lB have a common scheme and if so read it is clear Page 14 of 39 that the said sections provide for incentives in the form of deduction(s) which

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

section 147 of the Income-tax Act.” 69. The Hon’ble Delhi High Court in Commissioner of Income-tax v. SPL'S Siddhartha Ltd. [2012] 345 ITR 223 (DELHI) held as under:- “8. Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other

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

section 147 of the Income-tax Act.” 69. The Hon’ble Delhi High Court in Commissioner of Income-tax v. SPL'S Siddhartha Ltd. [2012] 345 ITR 223 (DELHI) held as under:- “8. Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other

INFOSYS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1) , BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the order passed by the NFAC, Delhi dated 27/03/2024 in DIN No. ITBA/NFAC/S/250/2023-24/1063442931(1) for the assessment year 2016-17. 2. The assessee has raised the following grounds of appeal: “1. General around: 1.1. The learned Commissioner of Income Tax (Appeals), National Faceless

M/S UKN PROPERTIES PVT. LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year: 2011-12

D E R PER B.R. BASKARAN, ACCOUNTANT MEMBER: The appeal filed by the assessee is directed against the order dated 31.8.2016 passed by Ld. CIT(A)-7, Bengaluru and it relates to the assessment year 2011-12. 2. The grounds urged by the assessee give rise to the following issues:- a) Disallowance made u/s 14A of the Act. b) Disallowance

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

5 of 55 lease only provides the right to undertake mining activity in a specific area which would have to be acquired from its occupants. In this regard. She made reference to Section 24A of the Mines and Minerals (Development and Regulation) Act, 1957 (“MMDR Act”), relevant extract (He referred Page 173 of the Paper book of assessment year

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

5 of 55 lease only provides the right to undertake mining activity in a specific area which would have to be acquired from its occupants. In this regard. She made reference to Section 24A of the Mines and Minerals (Development and Regulation) Act, 1957 (“MMDR Act”), relevant extract (He referred Page 173 of the Paper book of assessment year

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

5 of 55 lease only provides the right to undertake mining activity in a specific area which would have to be acquired from its occupants. In this regard. She made reference to Section 24A of the Mines and Minerals (Development and Regulation) Act, 1957 (“MMDR Act”), relevant extract (He referred Page 173 of the Paper book of assessment year

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

5 of 55 lease only provides the right to undertake mining activity in a specific area which would have to be acquired from its occupants. In this regard. She made reference to Section 24A of the Mines and Minerals (Development and Regulation) Act, 1957 (“MMDR Act”), relevant extract (He referred Page 173 of the Paper book of assessment year

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

5 of 55 lease only provides the right to undertake mining activity in a specific area which would have to be acquired from its occupants. In this regard. She made reference to Section 24A of the Mines and Minerals (Development and Regulation) Act, 1957 (“MMDR Act”), relevant extract (He referred Page 173 of the Paper book of assessment year