VIJAYA BANK ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX LARGE TAX PAYER UNIT , BANGALORE

In the result, Revenue’s appeal for Assessment Year 2012-13 is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

Disallowance of deduction u/s.36(1)(viii) Rs76,00,00,000 v) Disallowance u/s.14A Rs.2,65,27,250 2.2 Aggrieved by the order

SHREE GOVERDHAN NATHJI HAVELI TRUST ,BENGALURU vs. INCOME TAX OFFICER, EXEMPTIONS-WARD-3 , BENGALURU

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2016-17 M/S. Shree Goverdhan The Income Tax Nathji Haveli Trust, Officer, No. 15, Nehrunagar, Exemptions, Seshadripuram, Ward – 3, Bangalore – 560 020. Bangalore. Vs. Pan: Aacts7617M Appellant Respondent

disallow any deduction, allowance or relief claimed, such deduction, allowance or relief must be such as is, on the basis

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (LTU) , BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2835/Bang/2017 : Asst.Year 2013-2014 M/S.Dell International Services The Additional Commissioner India Private Limited Of Income-Tax (Ltu) V. Bangalore. Divyashree Greens, Sy.Nos.12/1, 12/2A & 13/1A,Challaghatta Village,Varthur Hobli Bengaluru – 560 071. Pan : Aaach1925Q. (Appellant) (Respondent) Appellant By : Sri.T.Suryanarayana, Advocate Respondent By : Sri.Praveen Karanth, Cit-Dr Date Of Pronouncement : 20.01.2023 Date Of Hearing : 13.01.2023 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 30.11.2017 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company, Engaged In The Business Of Manufacturing & Trading In Computer Systems Including Support & Maintenance Services & Leasing Of Computers. For The Assessment Year 2013-2014, The Return Of Income Was Filed On 30.11.2013 Declaring Total Income Of Rs.22,31,24,760. The Assessment Was Selected For Scrutiny & Notice U/S 143(2) Of The I.T.Act Was Issued On 2 It(Tp)A No.2835/Bang/2017. M/S.Dell International Services India Private Limited. 11.09.2014. During The Course Of Assessment Proceedings, It Was Noticed That The International Transactions Entered By The Assessee With Its Associated Enterprises (Aes) Had Exceeded The Prescribed Limit, Hence, The Matter Was Referred To The Transfer Pricing Officer (Tpo) To Determine The Arm’S Length Price (Alp) Of The Said Transaction. The Tpo Passed Order U/S 92Ca Of The I.T.Act On 19.10.2016. In The Said Order, The Tpo Had Proposed Following Adjustments:-

deduction claimed if not allowed will result in double disallowance has merits. The expenses disallowed is eligible for deduction u/s.40

SAP INDIA PRIVATE LIMITED ,BANGALORE vs. COMMISSIONER INCOME TAX (A) BANGALORE-6, BANGALORE

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

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

deduction u/s 10A on such amount disallowed. Otherwise, it would lead to an absurd situation wherein, even after disallowance of huge

SAP INDIA PRIVATE LIMITED,BANGALORE vs. COMMISSIONER INCOME TAX (A) BANGALORE-6, BANGALORE

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

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

deduction u/s 10A on such amount disallowed. Otherwise, it would lead to an absurd situation wherein, even after disallowance of huge

CHIGURUVADA DILEEPKUMAR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(3)(1), BENGALURU

In the result, the appeal filed by assessee in ITA No

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahu

Disallowance of deductions 29,53,200/- claimed u/s. 80E Disallowance of exemption 2,28,166/- claimed u/s. 10(13A) Total

CHIGURUVADA DILEEP KUMAR ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(3)(1) , BANGALORE

In the result, the appeal filed by assessee in ITA No

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahu

Disallowance of deductions 29,53,200/- claimed u/s. 80E Disallowance of exemption 2,28,166/- claimed u/s. 10(13A) Total

THE PAVAGADA SOUHARDA CREDIT CO-OPERATIVE LIMTIED,KOLOR vs. INCOME TAX OFFICER, WARD-1, KOLAR

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2010-11

disallowed the claim of deduction. Before sending the intimation, the assessee was not intimated about the proposal to disallow but the intimation

INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU, BENGALURU vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED, BENGALURU

In the result both the appeals of the Revenue as well as\nCos of the Assessee for the Asst

deduction u/s\n80P(2)(d) was disallowed and reason for disallowance was also not\ncommunicated in the intimation. Subsequently an appeal

ASSISTANT COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. BANGALORE INTERNATIONAL AIRPORT LIMITED, BANGALORE

disallowed the claim of the deduction under Section 80IA(4) of\nthe Act for Rs.207,99,58,356/- out of total

HUBLI ELECTRICITY SUPPLY ,HUBBALLI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), HUBALLI

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

deduction of tax Less: Amount disallowed separately 6070275 on account of no deduction of tax (included in the amount disallowed

YELBURGA PROWDA SHALA NOUKARARA PATTINA SAHAKARA SANGHA (N),YELBURGA vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, appeal of the assessee is allowed for statistical purposes

deduction, disallowed the claim of deduction u/s 80P(2)(a)(i) & enhanced the income determined by the AO and dismissed

NAVODAYA EDUCATION TRUST,RAICHUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY

In the result, the appeal of the assessee is dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2015-16

disallow any deduction, allowance or relief Page 9 of 18 claimed, such deduction, allowance or relief must be such as is, on the basis

THE KARNATAKA STATE COOPERATIVE AGRICULTURE AND DEVELOPMENT BANK LIMITED ,BANGLAORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2022-23

disallowance of ₹3,16,97,426/- out of the assessee’s claim of deduction of ₹42.30 crore under section 80P(2)(a)(i) of the Act. The disallowance

ASSISTANT COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. BANGALORE INTERNATIONAL AIRPORT LIMITED, BANGALORE

In the result, the cross objection of the assessee is hereby partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowed the claim of the deduction under section 80IA(4) of the Act for Rs. 207,99,58,356/- out of total

JOINT COMMISIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S TEXAS INSTRUMENTS INDIA PVT LTD , BANGALORE

In the result, the appeal by the revenue is dismissed and the appeal by the assessee is partly allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

Disallowance of deduction u/s. 80JJA – Rs.77,851,741.  Disallowance of expenses on discontinued capital project – Rs.74,19,000.  Disallowance of write

TEXAS INSTRUMENTS (INDIA) PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

In the result, the appeal by the revenue is dismissed and the appeal by the assessee is partly allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

Disallowance of deduction u/s. 80JJA – Rs.77,851,741.  Disallowance of expenses on discontinued capital project – Rs.74,19,000.  Disallowance of write

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance does deincentivize not deducting tax at source, when such tax deductions are due, but, so far as the legal