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

depreciation on intangible assets. 78. At the outset, we note that the issues raised by the assessee in its grounds of appeals for the AYs 2020-21 & 2021-22 are identical to the issue raised by the assessee in ITA No. 290/Bang/2025 for the assessment year 2017-18. Therefore, the findings given in ITA No. 290/Bang/2025 shall also be applicable

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

section 234A to 234D of the Act which is consequential in\nnature and does not require any separate adjudication. Hence, the same\nare dismissed as infructuous.\n80. Coming to the issue raised through additional ground of appeal\nregarding allowances of foreign tax as business expenditure.\n81. At the outset, we note that the issues raised by the assessee

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER 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

234A and 234B was also disputed.\n5. The Ld.CIT(A) had adjudicated the grounds issue wise. As far as the\nlimitation ground raised by the assessee, the Ld.CIT(A) had relied on the\nletter furnished by the assessee on 17/07/2023 in which the assessee had\nprayed to decide the denial of exemption u/s. 11 of the Act based

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

234A and 234B was also disputed.\n5. The Ld.CIT(A) had adjudicated the grounds issue wise. As far as the\nlimitation ground raised by the assessee, the Ld.CIT(A) had relied on the\nletter furnished by the assessee on 17/07/2023 in which the assessee had\nprayed to decide the denial of exemption u/s. 11 of the Act based

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

section 234A to 234D of the Act which is consequential in\nnature and does not require any separate adjudication. Hence, the same\nare dismissed as infructuous.\n80.\nComing to the issue raised through additional ground of appeal\nregarding allowances of foreign tax as business expenditure.\n81.\nAt the outset, we note that the issues raised by the assessee

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

depreciation on such sum on the facts and circumstances of the case. 10. The appellant denies the liability to pay interest under section 234A

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

depreciation on such sum on the facts and circumstances of the case. 10. The appellant denies the liability to pay interest under section 234A

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

depreciation on such sum on the facts and circumstances of the case. 10. The appellant denies the liability to pay interest under section 234A

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

section 132(4) of the Act. No specific request for cross examination was made by the assessee. xvi. The quarterly and annual performance report submitted to SEZ the assessee declared that the unit has commenced production from the EOU only since 30/5/2006. From the about is clear that EOU was not established till 30/5/2006 and not entitled for deduction under

SHANKARANARAYANA CONSTRUCTIONS PRIVATE LIMITED,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2(4), C R BUILDINGS, QUEENS ROAD, BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned Commissioner of Income tax on which interest is levied are not discernible and are wrong on the facts of the case. 13. The Appellant craves leave to add, alter, amend, substitute, change and delete

SHANKARANARAYANA CONSTRUCTIONS PRIVATE LIMITED,SNS HOUSE, RESIDENCY ROAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned Commissioner of Income tax on which interest is levied are not discernible and are wrong on the facts of the case. 13. The Appellant craves leave to add, alter, amend, substitute, change and delete

SHANKARANARAYANA CONSTRUCTIONS PRIVATE LIMITED,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE 2(4), CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned Commissioner of Income tax on which interest is levied are not discernible and are wrong on the facts of the case. 13. The Appellant craves leave to add, alter, amend, substitute, change and delete

SHANKARANARAYANA CONSTRUCTIONS PRIVATE LIMITED,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2(4), C R BUILDINGS, QUEENS ROAD, BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned Commissioner of Income tax on which interest is levied are not discernible and are wrong on the facts of the case. 13. The Appellant craves leave to add, alter, amend, substitute, change and delete

MARVELL INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharym/S. Marvell India Private Limited 10Th Floor, Tower D & E Global Technology Park, Marathahalli Outer Ring Road Devarabeesanahalli Village Varthurhobli Bangalore 560 103 ………. Appellant [Pan: Aaecm5559R]

234A, INR.92,01,062 under section 234B and INR 9,20,335 under section 234C of the Act. 6. Penalty Proceedings 6.1. The learned AO has erred, in law and on facts, in initiating penalty proceedings under section 274 read with section 270A of the Act.” 3. The relevant facts in brief are that the Assessee is a company engaged

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, BANGALORE

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

depreciation of\nRs.37,48,862/-;\nvii) Delete additions on account of disallowance under section 43B\namounting to Rs.1,09,16,175/-;\nviii) Interest levied under section 234A

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

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

depreciation of\nRs.37,48,862/-;\nvii) Delete additions on account of disallowance under section 43B\namounting to Rs.1,09,16,175/-;\nviii) Interest levied under section 234A

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.

depreciation of Rs.37,48,862/-; vii) Delete additions on account of disallowance under section 43B amounting to Rs.1,09,16,175/-; viii) Interest levied under section 234A

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.

depreciation of Rs.37,48,862/-; vii) Delete additions on account of disallowance under section 43B amounting to Rs.1,09,16,175/-; viii) Interest levied under section 234A