DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE vs. M/S LIFESTYLE INTERNATIONAL PVT LTD , BANGALORE

In the results appeal filed by assessee for assessment year

Bench: Shri Chandra Poojari & Smt Beena Pillai

7. The appellant craves leave to add, alter, amend and / or delete any of the grounds that may be urged.” 11. The Revenue is in appeal for assessment year 2011-12, on issues that were allowed by the Ld.CIT(A). 11.1 Ground No.2 of Revenue appeal is challenging 50% addition deleted by the Ld.CIT(A) in addition made under section

ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. LIFESTYLE INTERNATIONAL (P) LTD.,, BANGALORE

In the results appeal filed by assessee for assessment year

Bench: Shri Chandra Poojari & Smt Beena Pillai

7. The appellant craves leave to add, alter, amend and / or delete any of the grounds that may be urged.” 11. The Revenue is in appeal for assessment year 2011-12, on issues that were allowed by the Ld.CIT(A). 11.1 Ground No.2 of Revenue appeal is challenging 50% addition deleted by the Ld.CIT(A) in addition made under section

M/S.LIFESTYLE INTERNATIONAL PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE

In the results appeal filed by assessee for assessment year

Bench: Shri Chandra Poojari & Smt Beena Pillai

7. The appellant craves leave to add, alter, amend and / or delete any of the grounds that may be urged.” 11. The Revenue is in appeal for assessment year 2011-12, on issues that were allowed by the Ld.CIT(A). 11.1 Ground No.2 of Revenue appeal is challenging 50% addition deleted by the Ld.CIT(A) in addition made under section

M/S LIFESTYLE INTERNATIONAL PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the results appeal filed by assessee for assessment year

Bench: Shri Chandra Poojari & Smt Beena Pillai

7. The appellant craves leave to add, alter, amend and / or delete any of the grounds that may be urged.” 11. The Revenue is in appeal for assessment year 2011-12, on issues that were allowed by the Ld.CIT(A). 11.1 Ground No.2 of Revenue appeal is challenging 50% addition deleted by the Ld.CIT(A) in addition made under section

M/S.LIFESTYLE INTERNATIONAL PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE

In the results appeal filed by assessee for assessment year

Bench: Shri Chandra Poojari & Smt Beena Pillai

7. The appellant craves leave to add, alter, amend and / or delete any of the grounds that may be urged.” 11. The Revenue is in appeal for assessment year 2011-12, on issues that were allowed by the Ld.CIT(A). 11.1 Ground No.2 of Revenue appeal is challenging 50% addition deleted by the Ld.CIT(A) in addition made under section

CANARA BANK vs. CIT,

In the result, the appeal by the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raom/S.Canara Bank, Bsca Section, Head Office, J C Road, Bengaluru-560 002. Pan: Aaacc 6106 G … Appellant Vs. Commissioner Of Income-Tax, Ltu, Bengaluru. … Respondent

40A(7)(a) &(b) holds applicable to gratuity fund only and in respect of Pension fund the provision is not allowable even in case the same is a approved fund. Hence the transitional liability is held to bee prior period liability which the assessee itself has debited to the opening balance of the Revenue Reserve and is a liability which

GOPAL S. PANDITH vs. DCIT,

In the result, all the appeals of the assessee are partly allowed

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

B as consequential. The appellant crave leave of the Hon'ble Tribunal to raise such other ground or grounds at the time of hearing.” 34. Ground Nos.1 & 2 are regarding validity of assessment under Section 153A on the ground of non-grant of opportunity of hearing to the assessee for granting approval by the Joint Commissioner. This issue is identical

UNITED BREWERIES LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-7(1)(1), BENGALURU

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

b) of sub-section (2) of section 40A. 30. Before the Tribunal, the learned counsel for the Assessee submitted that the transaction with UEBF cannot be regarded as SDT, because by Finance Act, 2017 w.e.f. 01.04.2017, clause (i) of section 92BA was omitted from the statute and by virtue of omission of clause (i) from the statute, the proceedings already

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

7 of 38 measuring its exports receivables at exchange rate of US dollar on the balance sheet date. Admittedly the assessee has already done so. The AO has not disputed the same and such gain or loss has been allowed to the assessee. But the assessee has gone a step further and made additional claim in relation to same receivables

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-12 , BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

7 of 38 measuring its exports receivables at exchange rate of US dollar on the balance sheet date. Admittedly the assessee has already done so. The AO has not disputed the same and such gain or loss has been allowed to the assessee. But the assessee has gone a step further and made additional claim in relation to same receivables

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

7 of 38 measuring its exports receivables at exchange rate of US dollar on the balance sheet date. Admittedly the assessee has already done so. The AO has not disputed the same and such gain or loss has been allowed to the assessee. But the assessee has gone a step further and made additional claim in relation to same receivables

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.

depreciation and development rebate.  Section 35 grants deduction on expenditure for scientific research and knowledge extension in natural and applied sciences under agriculture, animal husbandry and fisheries. Payment to approved universities/research institutions or company also qualifies for deduction. In-house R&D is eligible for deduction, under this section.  Section 35CCD provides deduction for skill development projects, which constitute

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

b) where the same person or enterprise holds directly or indirectly, shares carrying not less than 26% of the voting power in each of such enterprise, is also not present. Further, it is necessary to appreciate the scheme of section 92A. A plain reading of this statutory provision makes the legal position quite clear. The, basic rule for treating

ACIT, MANGALORE vs. M/S CORPORATION BANK, MANGALORE

In the result, appeal of the revenue stands dismissed

Bench: Shri Rajpal Yadav & Shri Abraham P George

7 (Kerala), wherein it held:- "No doubt, payment of commission or brokerage in relation to sale or purchase of goods also would attract deduction of tax at source under section 194H of the Act. However, such situation arises only when there is involvement of services of a third 44 ITA Nos.1264 & 1352(B)/13 party on payment other than

HERBALIFE INTERNATIONAL INDIA PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

In the result, IT(TP)A No

Bench: Shri Vijay Pal Rao & Shri Jason P Boaz

depreciation on the said amount as per the provisions of Section 32(1)(ii) of the Income-tax Act, 1961 ('the Act') read with Rule 5(1) of the Income -tax Rules, 1962. 3. Disallowance of doubtful advances written off 3(a) On the facts and circumstances of the case and in law, the Ld AO and Ld DRP erred

M/S HERBALIFE INTERNATIONAL INDIA PVT. LTD.,,BANGALORE vs. ACIT,

In the result, IT(TP)A No

Bench: Shri Vijay Pal Rao & Shri Jason P Boaz

depreciation on the said amount as per the provisions of Section 32(1)(ii) of the Income-tax Act, 1961 ('the Act') read with Rule 5(1) of the Income -tax Rules, 1962. 3. Disallowance of doubtful advances written off 3(a) On the facts and circumstances of the case and in law, the Ld AO and Ld DRP erred

M/S. CISCO SYSTEMS CAPITAL (INDIA) PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX,SPECIAL RANGE-2, BANGALORE

In the result appeal filed by assessee stands allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

7% 50th Percentile 10.21% 65th Percentile 13.42% 2.4. The Ld.TPO thus proposed an adjustment of Rs.13,88,20,763/- by considering the ALP of assessee at 10.21% in relation to the Administrative Support Service. 2.5. Upon receipt of the Transfer Pricing order passed by the Ld.TPO, the Ld.AO passed the draft assessment order on 17/12/2018 under section 143(3) read

WORLD COURIER (INDIA) PVT LTD,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(2), BANGALORE

In the result, the appeal for AY 2014-15 is treated as allowed for statistical purpose while the appeal for AY 2012-13 is treated as partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

40a(ia) of the Income Tax Act, 1961 (‘the Act’). 3. The assessee is a company. It is a wholly owned subsidiary of World Courier (Group) Inc, USA. The assessee provides specialized courier services and supply chain services to domestic and overseas customers. For Assessment Year 2014-15, the assessee filed the return of income declaring total income of Rs.5