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

section 234B of the Act which is consequential in nature and the same does not require any separate adjudication. Hence, the same is dismissed infructuous. 71. Coming to the issue raised through additional ground of appeal regarding allowances of foreign tax as business expenditure. 72. At the outset, we note that the issue raised by the assessee in its grounds

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1)(2), BANGALORE vs. M/S. BRINDAVAN BEVERAGES PRIVATE LIMITED, BANGALORE

In the result appeal filed by revenue stands dismissed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2008-09

section 234B and C while passing order giving effect to, assessee preferred appeal before the Ld.CIT(A). The Ld.CIT(A) after Page 4 of 16 considering the submissions, allowed the ground of assessee by holding as under: “5.2. Ground No.2 relates to the computation of interest u/s 234B and 234C of the Act, on account of certain additional income offered

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

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 on the\njudgment

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

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 on the\njudgment

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

section 234B of the Act which is consequential in nature\nand the same does not require any separate adjudication. Hence, the\nsame is dismissed infructuous.\n71. Coming to the issue raised through additional ground of appeal\nregarding allowances of foreign tax as business expenditure.\n72. At the outset, we note that the issues raised by the assessee in its\ngrounds

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

Section 234B of the Income Tax Act, 1961"], "issues": "Deductibility of software expenses as revenue expenditure, allowability of depreciation on intangible

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

depreciation on such sum on the facts and\ncircumstances of the case.\n\n10.\nThe appellant denies the liability to pay interest under section\n234A, 234B

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

depreciation on such sum on the facts and\ncircumstances of the case.\n10.\nThe appellant denies the liability to pay interest under section\n234A, 234B

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

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No:Aaajk0398K\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

depreciation cannot be claimed on capital asset which was claimed as application of income in a previous year.\n16. 3. On facts and circumstances of the case and law applicable, impugned addition of Rs.8,05,368 is bad in law and liable to be quashed.\n\n17. Interest under section 234B

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, 234B

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, 234B

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, 234B

BOSCH GLOBAL SOFTWARE TECHNOLOGIES PRIVATE LIMITED ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(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

depreciation or otherwise) in computing the income chargeable under the head "Profits and gains of business or profession" of any previous year.” 15.3 The relevant clause in present case is clause (iii) according to which any office appliance including the computer or computer software shall not be included in the “New asset” for purpose of this section. On careful perusal

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

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

KAWASAKI MICROELECTRONICS INC,BANGALORE vs. DDIT INTERNATIONAL TAXATION, BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Vijaypal Rao & Shri Jason P. Boaz

depreciation is disallowed resulting in an income, Kawasaki India, being a unit registered under the Software Technology Parks of India (STPI) Scheme and having satisfied the conditions prescribed under section 10A of the Act, is eligible to claim deduction under the aforesaid section. 6. The learned AO erred in levying interest of Rs.115.197 under sections 234B

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]

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 in design, development and testing

DCIT, BANGALORE vs. OUTSOURCE PARTNERS INTERNATIONAL PVT. LTD.,, BANGALORE

In the result, all appeals are partly allowed for statistical purposes

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazit(Tp)A Nos. & Appellant Respondent Assessment Years No.443/Bang/2016 M/S. Outsource Partners Dy. Commissioner Of 2011-12 International Pvt. Ltd., Income-Tax, Tower 2D, Phase I, Vikas Circle-5(1)(2), Telecom Ltd., Bangalore. Vrindavan Tech Village, Outer Ring Road, Devarabeesanahalli, Bangalore- 560087. Pan: Aaaco5734C No. 526/Bang/2016 Dy. Commissioner Of M/S. Outsource Partners 2011-12 Income-Tax, International Pvt. Ltd., Circle-5(1)(2), Pan: Aaaco5734C Bangalore. No.535/Bang/2017 M/S. Outsource Partners Assistant Commissioner Of 2009-10 International Pvt. Ltd., Income Tax, Pan: Aaaco5734C Circle-5(1)(2), Bangalore.

section 234B of the Income tax Act, 1961. IT(TP)A Nos.443,526/Bang/2016, No.535/Bang/2017 Page 4 of 35 The above grounds of appeal are mutually exclusive and without prejudice to each other. The Appellant craves leave to add, alter, amend or vary any of the above grounds either before or at the time of hearing as we may be advised

OUTSOURCEPARTNERS INTERNATIONAL PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, all appeals are partly allowed for statistical purposes

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazit(Tp)A Nos. & Appellant Respondent Assessment Years No.443/Bang/2016 M/S. Outsource Partners Dy. Commissioner Of 2011-12 International Pvt. Ltd., Income-Tax, Tower 2D, Phase I, Vikas Circle-5(1)(2), Telecom Ltd., Bangalore. Vrindavan Tech Village, Outer Ring Road, Devarabeesanahalli, Bangalore- 560087. Pan: Aaaco5734C No. 526/Bang/2016 Dy. Commissioner Of M/S. Outsource Partners 2011-12 Income-Tax, International Pvt. Ltd., Circle-5(1)(2), Pan: Aaaco5734C Bangalore. No.535/Bang/2017 M/S. Outsource Partners Assistant Commissioner Of 2009-10 International Pvt. Ltd., Income Tax, Pan: Aaaco5734C Circle-5(1)(2), Bangalore.

section 234B of the Income tax Act, 1961. IT(TP)A Nos.443,526/Bang/2016, No.535/Bang/2017 Page 4 of 35 The above grounds of appeal are mutually exclusive and without prejudice to each other. The Appellant craves leave to add, alter, amend or vary any of the above grounds either before or at the time of hearing as we may be advised