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

B of the appendix-1, the same is eligible to depreciate at 25%. The AO also referred to Accounting Standard 26-Intangible Assets which describes that software which is not an integral part of related hardware is to be treated as intangible assets. The AO also referred the decision of ITAT in the case ITA Nos.290 - 294/Bang/2025 Page

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

B of the appendix-1, the same is eligible to depreciate at 25%. The AO also referred to Accounting Standard 26-Intangible Assets which describes that software which is not an integral part of related hardware is to be treated as intangible assets. The AO also referred the decision of ITAT in the case ITA Nos.290 - 294/Bang/2025 Page

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

41 of 64 a more vulnerable position than an assessee in whose case there was a full-fledged scrutiny assessment made under Section 143(3). Whether the return is put to scrutiny or is accepted without demur is not a matter which is within the control of assessee; he has no choice in the matter. The other consequence, which

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

41 of 64 a more vulnerable position than an assessee in whose case there was a full-fledged scrutiny assessment made under Section 143(3). Whether the return is put to scrutiny or is accepted without demur is not a matter which is within the control of assessee; he has no choice in the matter. The other consequence, which

M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

B” BENCH, BENGALURU Before Shri George George K., Judicial Member and Shri Laxmi Prasad Sahu, Accountant Member M/s. Bank of Baroda vs. Addl. CIT, LTU, (erstwhile Vijaya Bank) BMTC Building 7th Floor, Central Accounts 6th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 PAN – AAACVO3787 (Appellant) (Respondent) ACIT, Circle - 2(1)(1) vs. M/s. Bank of Baroda Room

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

B” BENCH, BENGALURU Before Shri George George K., Judicial Member and Shri Laxmi Prasad Sahu, Accountant Member M/s. Bank of Baroda vs. Addl. CIT, LTU, (erstwhile Vijaya Bank) BMTC Building 7th Floor, Central Accounts 6th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 PAN – AAACVO3787 (Appellant) (Respondent) ACIT, Circle - 2(1)(1) vs. M/s. Bank of Baroda Room

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

b) being a company, to which the second proviso to subsection (1) of section 129 of the Companies Act, 2013 (18 of 2013) is applicable, shall, for the purposes of this section, prepare its statement of profit and loss for the relevant previous year in accordance with the provisions of the Act governing such company: Provided that while preparing

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

B + C) 17,581.10 Add : Other current assets 1,260.00 (Net) Total 18,841.10 Add: Goodwill 4,340.90 Depreciation claim made before AO vide letter dated 15.10.2012 (also refer Addl. ground 21 of the present appeal) Total Consideration 23,182.00 32. Accordingly, the cost of acquisition of individual assets, forming part of RDB undertaking acquired by way of slump sale

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

b) of Income Tax Rules, the\nsubmission of Form 3CL issued by DSIR is mandatory for allowing\nweighted deduction under section 35(2AB) of the Act. Since the assessee\nfailed to furnish Form 3CL for the relevant year, the AO concluded that\nthe assessee was not eligible for weighted deduction at 150%.\nAccordingly, the AO disallowed the excess weighted deduction

M/S. BANGALORE ELECTRICITY SUPPLY COMPANY LTD.,,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2), BANGALORE

In the result, the appeal by the assessee is partly allowed and appeal of the ld

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

1) (vii) read with section 36 (2) of the act. This claim of the assessee is allowed based on the principles of the allowability of bad debts, which are otherwise allowable irrespective of the additional evidence submitted by the assessee. Accordingly, the learned assessing officer is directed to delete the disallowance of ₹ 83.59 Crores being ITA No.426 & 710/Bang/2023 Page

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE- 1(1)(1), BANGALORE, BMTC BUILDING, KORAMANGALA, BAQNGALORE vs. BANGALORE ELECTRICITY SUPPLY COMPANY LIMITED , BESCOM CORPORATE OFFICE

In the result, the appeal by the assessee is partly allowed and appeal of the ld

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

1) (vii) read with section 36 (2) of the act. This claim of the assessee is allowed based on the principles of the allowability of bad debts, which are otherwise allowable irrespective of the additional evidence submitted by the assessee. Accordingly, the learned assessing officer is directed to delete the disallowance of ₹ 83.59 Crores being ITA No.426 & 710/Bang/2023 Page

SHRI. JITENDRA VIRWANI,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, both the appeals by the assessee are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

b) to Explanation (2), the Assessing Officer must notice that the assessee has understated his income or has claimed excessive loss, deduction, allowance or relief in the return. The taking of such notice must be consistent with the provisions of the applicable law. The act of taking notice cannot be at the arbitrary whim or caprice of the Assessing Officer

SHRI. JITENDRA VIRWANI,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, both the appeals by the assessee are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

b) to Explanation (2), the Assessing Officer must notice that the assessee has understated his income or has claimed excessive loss, deduction, allowance or relief in the return. The taking of such notice must be consistent with the provisions of the applicable law. The act of taking notice cannot be at the arbitrary whim or caprice of the Assessing Officer

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

41 of 202 then only the assessee can have the benefit of tax credit in respect of the tax paid in foreign jurisdiction. In respect of exemption under section 10A, the income derived is not included in the total income. It is not charged to Income-tax. Therefore, section 90 of the Act has no application at all. ………. 52. Section

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

41 of 202 then only the assessee can have the benefit of tax credit in respect of the tax paid in foreign jurisdiction. In respect of exemption under section 10A, the income derived is not included in the total income. It is not charged to Income-tax. Therefore, section 90 of the Act has no application at all. ………. 52. Section

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

b) & (c) of the Act, and consequently the assumption of jurisdiction to make an assessment under section 153A of the Act is untenable in law. iv) The learned assessing officer failed to appreciate that a valid search is a sine qua non for making a valid assessment under section 153A of the Act on the parity of the ratio

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

b) & (c) of the Act, and consequently the assumption of jurisdiction to make an assessment under section 153A of the Act is untenable in law. iv) The learned assessing officer failed to appreciate that a valid search is a sine qua non for making a valid assessment under section 153A of the Act on the parity of the ratio

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

b) & (c) of the Act, and consequently the assumption of jurisdiction to make an assessment under section 153A of the Act is untenable in law. iv) The learned assessing officer failed to appreciate that a valid search is a sine qua non for making a valid assessment under section 153A of the Act on the parity of the ratio