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

30,060,000/- Rs. 85,33,00,000/- contacts Goodwill Rs. 280,39,08,132/- Rs. 2016,21,78,480/- Total Rs. 412,05,36,132/- Rs. 3035,54,78,480/- 21. On the above identified intangible assets, the assessee claimed depreciation under section

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

30,060,000/- Rs. 85,33,00,000/- contacts Goodwill Rs. 280,39,08,132/- Rs. 2016,21,78,480/- Total Rs. 412,05,36,132/- Rs. 3035,54,78,480/- 21. On the above identified intangible assets, the assessee claimed depreciation under section

M/S SAMSUNG R & D INSTITUTE INDIA BANGALORE PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

In the result, the appeals filed by the assessee as per revised\ngrounds stands allowed and the appeals filed by the revenue\nstands dismissed for the years under consideration

30,207/- that was capitalised in the books\nof accounts and depreciation at 60% was claimed u/s. 32 of the\nact. During the course of the assessment proceedings, the Ld.AO\ndisallowed the depreciation of software by invoking the provisions\nof section

M/S. SAMSUNG R & D INSTITUTE INDIA BANGALORE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(1), BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

Bench: Smt Beena Pillai & Shri Waseem Ahmed

30,207/- that was capitalised in the books of accounts and depreciation at 60% was claimed u/s. 32 of the act. During the course of the assessment proceedings, the Ld.AO disallowed the depreciation of software by invoking the provisions of section

M/S. SAMSUNG R & D INSTITUTE INDIA BANGALORE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME- TAX, CIRCLE - 6(1)(1), BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

Bench: Smt Beena Pillai & Shri Waseem Ahmed

30,207/- that was capitalised in the books of accounts and depreciation at 60% was claimed u/s. 32 of the act. During the course of the assessment proceedings, the Ld.AO disallowed the depreciation of software by invoking the provisions of section

JOINT COMMISSIONER OF INCOME-TAX, SPECIAL RANGE-6, BANGALORE vs. M/S. SAMSUNG R & D INSTITUTE INDIA-BANGALORE PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

Bench: Smt Beena Pillai & Shri Waseem Ahmed

30,207/- that was capitalised in the books of accounts and depreciation at 60% was claimed u/s. 32 of the act. During the course of the assessment proceedings, the Ld.AO disallowed the depreciation of software by invoking the provisions of section

JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE - 6, BANGALORE vs. M/S. SAMSUNG R &D INSTITUTE INDIA- BANGALORE PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

Bench: Smt Beena Pillai & Shri Waseem Ahmed

30,207/- that was capitalised in the books of accounts and depreciation at 60% was claimed u/s. 32 of the act. During the course of the assessment proceedings, the Ld.AO disallowed the depreciation of software by invoking the provisions of section

JOINT COMMISSIONER OF INCOME -TAX, SPECIAL RANGE - 6, BANGALORE vs. M/S. SAMSUNG R & D INSTITUTE INDIA-BANGALORE PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

Bench: Smt Beena Pillai & Shri Waseem Ahmed

30,207/- that was capitalised in the books of accounts and depreciation at 60% was claimed u/s. 32 of the act. During the course of the assessment proceedings, the Ld.AO disallowed the depreciation of software by invoking the provisions of section

FINASTRA SOFTWARE SOLUTIONS (INDIA) PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri George George K. & Ms. Padmavathy S.It(Tp)A No. 268/Bang/2021 (Assessment Year: 2016-17)

30 provides deduction on repairs, municipal tax and insurance premiums. • Section 31, provides deduction on repairs and insurance of plant, machinery and furniture • Section 32 provides for depreciation

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

30,060,000/-\nRs. 85,33,00,000/-\ncontacts\nGoodwill\nRs. 280,39,08,132/- Rs. 2016,21,78,480/-\nTotal\nRs. 412,05,36,132/- Rs. 3035,54,78,480/-\n21. On the above identified intangible assets, the assessee claimed\ndepreciation under section 32 of the Act from F.Y. 2014-15 relevant to\nA.Y. 2015-16 till the year

JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE - 6, BANGALORE vs. M/S. SAMSUNG R & D INSTITUTE INDIA -BANGALORE PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the assessee as per revised\ngrounds stands allowed and the appeals filed by the revenue\nstands dismissed for the years under consideration

30,207/- that was capitalised in the books\nof accounts and depreciation at 60% was claimed u/s. 32 of the\nact. During the course of the assessment proceedings, the Ld.AO\ndisallowed the depreciation of software by invoking the provisions\nof section

JSW INDUSTRIAL GASES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(3)(1), BENGALURU, BENGALURU

In the result, appeal filed by the assessee is allowed

30 provides deduction on repairs, municipal tax and insurance premiums.\n• Section 31, provides deduction on repairs and insurance of plant, machinery and furniture\n• Section 32 provides for depreciation

FINASTRA SOFTWARE SOLUTIONS (INDIA) PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands allowed as indicated hereinabove

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No. 189/Bang/2022 Assessment Year : 2017-18 M/S. Finastra Software Solutions (India) Pvt. Ltd., 4Th To 6Th Floor, Virgo The Deputy Building, Bagmane Commissioner Of Constellation Income Tax, Business Park Outer Circle – 3 (1)(1), Ring Road, Vs. Bangalore. Dodanekundi, Bangalore. Pan: Aaack9067G Appellant Respondent : Smt. Tanmayee Rajkumar, Assessee By Advocate Revenue By : Ms. Neera Malhotra, Cit-Dr Date Of Hearing : 01-03-2023 Date Of Pronouncement : 31-05-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 27.01.2022 For A.Y. 2017-18 On Following Grounds Of Appeal: “1. The Impugned Final Assessment Order Dated 27.01.2022 Was Not Communicated In The Manner Prescribed Under The Income-Tax Act, 1961 & The Rules Made Thereunder & Therefore The Proceedings Are Null & Void.

30 provides deduction on repairs, municipal tax and insurance premiums.  Section 31, provides deduction on repairs and insurance of plant, machinery and furniture  Section 32 provides for depreciation

M/S. ALLEGIS SERVICES (INDIA) PRIVATE LIMITED,BANGALORE vs. COMMISSIONER OF INCOME TAX (APPEALS)- 1, BANGALORE

In the result appeal filed by assessee stands allowed

Bench: Shri. B. R. Baskaran & Smt. Beena Pillaiassessment Year : 2016 – 17

30 provides deduction on repairs, municipal tax and insurance premiums. • Section 31, provides deduction on repairs and insurance of plant, machinery and furniture • Section 32 provides for depreciation

NORTHERN OPERATING SERVICES PRIVATE LIMITED,ARGON SOUTH TOWER vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 5 (1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2020-21 M/S. Northern Operating Services Pvt. Ltd., Vs. Dcit, 2Nd Floor Rmz Ecopace, Circle – 5(1)(1), Campus 1C, Bengaluru. Sarjapur Outer Ring Road, Bellandur, Bengaluru – 560 103. Pan : Aaccn 1652 J Appellant Respondent Assessee By : Ms. Divya Motwani, Ca. Revenue By : Shri. D. K. Mishra, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 26.09.2024 Date Of Pronouncement : 27.09.2024

30 provides deduction on repairs, municipal tax and insurance premiums. • Section 31, provides deduction on repairs and insurance of plant, machinery and furniture • Section 32 provides for depreciation

M/S. INFINERA INDIA PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 3, BANGALORE

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

Bench: Shri George George K. & Shri B.R. Baskaranit(Tp)A No.2589/Bang/2019 Assessment Year: 2015-16

30 provides deduction on repairs, municipal tax and insurance premiums. • Section 31, provides deduction on repairs and insurance of plant, machinery and furniture • Section 32 provides for depreciation

M/S. FNF INDIA PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2016-17

30 provides deduction on repairs, municipal tax and insurance premiums. • Section 31, provides deduction on repairs and insurance of plant, machinery and furniture • Section 32 provides for depreciation

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

depreciation and investment allowance. Therefore, the term profits and gains are not synonymous with the term 'income'..... Reading of Section 80HH along with Section 80A would clearly signify that such a deduction has to be of gross profits and gains, i.e., before computing the income as specified in Sections 30