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 claimed on intangible assets. The grounds raised by the assessee on this issue are allowed. 37. Coming to issue raised through additional ground of appeal regarding allowances of foreign tax as business expenses under section 37 of the Act. ITA Nos.290 - 294/Bang/2025 Page 32 of 53 38. The relevant facts are that during the year under consideration, the assessee

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 claimed on intangible assets. The grounds raised by the assessee on this issue are allowed. 37. Coming to issue raised through additional ground of appeal regarding allowances of foreign tax as business expenses under section 37 of the Act. ITA Nos.290 - 294/Bang/2025 Page 32 of 53 38. The relevant facts are that during the year under consideration, the assessee

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 claimed on intangible assets. The grounds raised by the assessee on this issue are allowed. 37. Coming to issue raised through additional ground of appeal regarding allowances of foreign tax as business expenses under section 37 of the Act. ITA Nos.290 - 294/Bang/2025 Page 32 of 53 38. The relevant facts are that during the year under consideration, the assessee

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

41, to\nsubmit that if there is any conflict between the Act and the Rules, the\nAct must prevail.\n53.4 The learned AR further submitted that the mandate to quantify\nexpenditure was introduced only by amendment to the Rules with effect\nfrom 01.07.2016, without any corresponding amendment to section\n35(2AB) of the Act. Therefore, DSIR's role of quantification

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

depreciation and it reads thus:- “43. In sections 28 to 41 and in this section, unless the context otherwise requires

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

41, to\nsubmit that if there is any conflict between the Act and the Rules, the\nAct must prevail.\n53.4 The learned AR further submitted that the mandate to quantify\nexpenditure was introduced only by amendment to the Rules with effect\nfrom 01.07.2016, without any corresponding amendment to section\n35(2AB) of the Act. Therefore, DSIR's role of quantification

JAYARAMA REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRLCE-2(4), BENGALURU

sections": [ "132", "132(4)", "153A", "131", "32", "37", "38(2)", "40(a)(ia)", "194C", "194J", "41(1)", "24" ], "issues": "Whether the expenses and depreciation

M/S MINERA STEEL & POWER PVT LTD ,BELLARY vs. THE JOINT COMMISSIONER OF INCOME TAX BELLARY RANGE , BELLARY

In the result, the appeal of the assessee is partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2012-13

depreciation was at Rs.24.90/- crores, which translates into net profit margin of 12% approximately. However, the tax was payable under the provisions of section 115JB at Rs.5,03,41

FIBRES & FABRICS INTERNATIONAL PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, both the appeals are allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

depreciation is allowed. While section 41(2) provides for assessment of profit arising on sale of intangible depreciable assets, section

JAYARAMA REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), BENGALURU

In the result the appeal of the assessee is hereby partly allowed\nfor statistical purposes

sections": [ "132", "132(4)", "153A", "131", "41(1)", "40(a)(ia)", "194C", "194J", "32", "37", "38(2)", "24" ], "issues": "Whether the disallowance of expenses and depreciation

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

41 of 55 (b) such amount as is sufficient to reduce to nil the income (as computed before making the deduction under this section) of that previous year arising from the commercial exploitation whether or not such commercial exploitation is as a result of the operations or development referred to in sub-section (2) of any mine or other natural

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

41 of 55 (b) such amount as is sufficient to reduce to nil the income (as computed before making the deduction under this section) of that previous year arising from the commercial exploitation whether or not such commercial exploitation is as a result of the operations or development referred to in sub-section (2) of any mine or other natural

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

41 of 55 (b) such amount as is sufficient to reduce to nil the income (as computed before making the deduction under this section) of that previous year arising from the commercial exploitation whether or not such commercial exploitation is as a result of the operations or development referred to in sub-section (2) of any mine or other natural

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

41 of 55 (b) such amount as is sufficient to reduce to nil the income (as computed before making the deduction under this section) of that previous year arising from the commercial exploitation whether or not such commercial exploitation is as a result of the operations or development referred to in sub-section (2) of any mine or other natural

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

41 of 55 (b) such amount as is sufficient to reduce to nil the income (as computed before making the deduction under this section) of that previous year arising from the commercial exploitation whether or not such commercial exploitation is as a result of the operations or development referred to in sub-section (2) of any mine or other natural

JAYARAM REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

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

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

depreciation and expenses on cars on merit as well as on technical grounds. 31.1 At the outset, we note that the issues raised by the assessee in its grounds of appeal for the AY 2016-17 are identical to the issue raised by the assessee in ITA No. 705/Bang/2025 for the assessment year 2013- 14. Therefore, the findings given

ATOS IT SERVICES PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

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

Bench: Shri George George K. & Ms. Padmavathy S

depreciation on goodwill under section 32(1) of the Act.” IT(TP)A No.226/Bang/2021 Page 20 of 25 27. The assessee has made an addition of intangible assets for Rs.93,51,41

JAYARAMA REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

In the result the appeal of the assessee is hereby partly allowed\nfor statistical purposes

sections": [ "132", "153A", "132(4)", "131", "32", "37", "38(2)", "194C", "194J", "40(a)(ia)", "41(1)", "24" ], "issues": "Whether expenses and depreciation