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

43(5) r.w.s 73.” 4.6 Based on above, the Ld.AO passed assessment order under section 143(3) read with 144C(3) of the Act on 29/04/2013 making addition of Rs.74,38,200/- along with the adjustment proposed by the Ld.TPO. 4.7 On an appeal before the Ld.CIT(A), all other additions were deleted except for the Transfer Pricing adjustment proposed

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

43(5) r.w.s 73.” 4.6 Based on above, the Ld.AO passed assessment order under section 143(3) read with 144C(3) of the Act on 29/04/2013 making addition of Rs.74,38,200/- along with the adjustment proposed by the Ld.TPO. 4.7 On an appeal before the Ld.CIT(A), all other additions were deleted except for the Transfer Pricing adjustment proposed

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

43(5) r.w.s 73.” 4.6 Based on above, the Ld.AO passed assessment order under section 143(3) read with 144C(3) of the Act on 29/04/2013 making addition of Rs.74,38,200/- along with the adjustment proposed by the Ld.TPO. 4.7 On an appeal before the Ld.CIT(A), all other additions were deleted except for the Transfer Pricing adjustment proposed

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

43(5) r.w.s 73.” 4.6 Based on above, the Ld.AO passed assessment order under section 143(3) read with 144C(3) of the Act on 29/04/2013 making addition of Rs.74,38,200/- along with the adjustment proposed by the Ld.TPO. 4.7 On an appeal before the Ld.CIT(A), all other additions were deleted except for the Transfer Pricing adjustment proposed

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

43(5) r.w.s 73.” 4.6 Based on above, the Ld.AO passed assessment order under section 143(3) read with 144C(3) of the Act on 29/04/2013 making addition of Rs.74,38,200/- along with the adjustment proposed by the Ld.TPO. 4.7 On an appeal before the Ld.CIT(A), all other additions were deleted except for the Transfer Pricing adjustment proposed

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

43 of 58 claimed depreciation under section 32(1)(ii) of the Act with respect to the aforesaid various intangible assets aggregating to Rs.16.58 crores acquired through slump sale and categorized under the head “goodwill”. The assessing officer, CIT(A) and Tribunal disallowed the aforesaid claim of depreciation on intangible assets/goodwill. On further appeal, the High Court allowed the appeal

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

In the result, the assessee’s appeal stands allowed and revenue’s appeal stands dismissed

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2013-14 M/S. Lifestyle International Pvt. Ltd., 77, Town Centre, The Deputy Building No. 3, Commissioner Of West Wing, Income Tax, Off Hal Airport Road, Circle – 4(1)(1), Yamlur, Vs. Bengaluru. Bengaluru – 560 037. Pan: Aaacl2937J Appellant Respondent & Assessment Year : 2013-14 (By Revenue)

section 43(6)(c)(ii) while the accountant has determined the value u/s 43(6)(c)(i)(C). In view of the above arguments it is doubtful that the company has transferred the brand on a slump sale basis as what was transferred was only a brand and not an undertaking or division Hence, the transfer on account of sale

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

5,69,16,52,215/- to the total income of the assessee. The assessee’s alternative claim for enhanced deduction under section 10AA of the Act on account of increased profits was also rejected for want of direct nexus. 23. The aggrieved assessee preferred an appeal before the learned CIT(A). 24. Before the learned CIT(A), the assessee submitted

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

5,69,16,52,215/- to the total income of the assessee. The assessee’s alternative claim for enhanced deduction under section 10AA of the Act on account of increased profits was also rejected for want of direct nexus. 23. The aggrieved assessee preferred an appeal before the learned CIT(A). 24. Before the learned CIT(A), the assessee submitted

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

5,69,16,52,215/- to the total income of the assessee. The assessee’s alternative claim for enhanced deduction under section 10AA of the Act on account of increased profits was also rejected for want of direct nexus. 23. The aggrieved assessee preferred an appeal before the learned CIT(A). 24. Before the learned CIT(A), the assessee submitted

M/S. TATA ELXSI LTD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), , BENGALURU

43 D of the Act. Since it is purely\na legal ground we admit the same.\n108. The elaborate submission of the assessee in this regard reads as under:-\n“The issue before the Apex Court relates to the interpretation to section 80HH\nrelevant to AY 1979-80 and 1980-81. The relevant section is reproduced hereunder:-\n\"80HH. Deduction

BANGALORE INTERNATIONAL AIRPORT LTD.,,BANGALORE vs. DCIT, BANGALORE

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

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raobangalore International Airport Ltd. Administration Block, Bial, Devanahalli Bangalore-560 300. … Appellant Pan:Aabc8973D Vs. Deputy Commissioner Of Income-Tax, Circle 11(2), Bangalore. … Respondent & Deputy Commissioner Of Income-Tax, Circle 11(2), Bangalore. … Appellant Vs. Bangalore International Airport Ltd. Bangalore-560 300. … Respondent

43(1) defines actual cost for the purpose of grant of depreciation etc. to mean "the actual cost of the assets to the assessee". Till the insertion of the unamended section 43A there was no provision in the Income-tax Act for adjustment of the actual cost which was fixed once and for all, at the time of acquisition

DCIT, BANGALORE vs. M/S BANGALORE INTERNATIONAL AIRPORT LTD.,, BANGALORE

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

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raobangalore International Airport Ltd. Administration Block, Bial, Devanahalli Bangalore-560 300. … Appellant Pan:Aabc8973D Vs. Deputy Commissioner Of Income-Tax, Circle 11(2), Bangalore. … Respondent & Deputy Commissioner Of Income-Tax, Circle 11(2), Bangalore. … Appellant Vs. Bangalore International Airport Ltd. Bangalore-560 300. … Respondent

43(1) defines actual cost for the purpose of grant of depreciation etc. to mean "the actual cost of the assets to the assessee". Till the insertion of the unamended section 43A there was no provision in the Income-tax Act for adjustment of the actual cost which was fixed once and for all, at the time of acquisition

DCIT vs. M/S INDUS GARMENTS INDIA P. LTD.,,

Appeal is treated as dismissed

Bench: Shri B. Ramakotaiah & Shri Narendra Kumar Choudharyassessment Year : 2009-10

section 43(5). Not only that, Page 5 of 6 as seen from Schedule 10 to Profit & Loss Account, the assessee had indeed earned a profit in earlier year to an extent of Rs.56,17,976 which was treated as business income. In view of that also, the stand taken by the AO cannot be justified. Therefore

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

In the result, the appeals filed by the Revenue and the cross objections filed by the assessee are dismissed

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

Section 92C the TPO only computes the arm’s length price in relation to an international transaction and is not empowered to examine the genuineness of the said payment. 4. On facts of the case, whether the ld.CIT(A) is right in deleting the disallowance made on premium on forward cover u/s 43(5) treating it as speculative loss which

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

In the result, the appeals filed by the Revenue and the cross objections filed by the assessee are dismissed

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

Section 92C the TPO only computes the arm’s length price in relation to an international transaction and is not empowered to examine the genuineness of the said payment. 4. On facts of the case, whether the ld.CIT(A) is right in deleting the disallowance made on premium on forward cover u/s 43(5) treating it as speculative loss which

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

5,69,16,52,215/- to the total income of the\nassessee. The assessee's alternative claim for enhanced deduction under\nsection 10AA of the Act on account of increased profits was also rejected\nfor want of direct nexus.\n23. The aggrieved assessee preferred an appeal before the learned\nCIT(A).\n24. Before the learned CIT(A), the assessee submitted

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

5). The appellant submits that even though section 80A(1) is not applicable to section 10AA, the reference to 80A(1) in the decision of Supreme Court would not make the decision inapplicable to section 10AA for the following reasons: (a) Section 80A(1) only provides that deduction u/s 80C to 80U would be available to the assessee. Therefore section