M/S. UNITED BREWERIES LIMITED,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE- 12, BANGALORE

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

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

disallowance u/s 43B, an amount of Rs 4,84,865, without appreciating that no such expenditure has been claimed in the P & L account” 22. The ld. AR during the course of hearing submitted that the assessee filed a petition for rectification u/s. 154

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 12(5), BANGALORE

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

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

disallowance u/s 43B, an amount of Rs 4,84,865, without appreciating that no such expenditure has been claimed in the P & L account” 22. The ld. AR during the course of hearing submitted that the assessee filed a petition for rectification u/s. 154

M/S CESSNA GARDEN DEVELOPERS PVT LTD ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BANGALORE

Bench: Shri N.V. Vasudevan & Shri Pradip Kumar Kedia

disallowed by a rectification order passed by the AO u/s. 154 of the Act dated 27.10.2016. 2.2 The assessee challenged

INCOME TAX OFFICER, WARD-1(2)(1), BANGALORE vs. SHRI MUNI REDDY SANTHOSH REDDY, BENGALURU

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

Bench: Shri Chandra Poojariassessment Year: 2014-15

rectification order passed u/s. 154 of the Act withdrawing the deduction allowed u/s. 54 of the Act in respect of 3 plots purchased for construction of residential house and (ii) the disallowance

M/S UNITED BREWERIES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

u/s 154 of the I.T.Act. The learned AR further stated that the Tribunal in its recent decision for AY 2011-12 passed in ITA No.126/Bang/ 2020 (order dated 20.11.2022) has remanded the matter to the AO to verify and allow the claim of the assessee after taking into consideration the rectification order passed for AY 2010-11. The learned

M/S. UNITED SPIRITS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

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

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadaleit(Tp)A No.489/Bang/2017 (Assessment Year: 2012-13) M/S. United Spirits Limited, Ub Towers, No.24, Vittal Mallya Road, Bangalore-560 001 ….Appellant Vs. Dy. Commissioner Of Income Tax, Circle 7(1)(1), Bangalore. ……Respondent. Assessee By: Shri Perci Pardiwala, Senior Advocate & Shri Ketan Ved, C.A. Revenue By: Shri Bipin C.N, Jcit (D.R) Date Of Hearing : 06.03.2020. Date Of Pronouncement : 29.05.2020. O R D E R Per Shri B.R. Baskaran, A.M. : The Assessee Has Filed This Appeal Challenging The Assessment Order Dated 31-01-2017 Passed By The Assessing Officer For Assessment Year 2012-13 Passed U/S 143(3) R.W.S 144C(13) Of The Act.

rectification order u/s 154 of the Act. The Ld A.R submitted that the AO has only partially complied with the directions, i.e., he has not followed the direction in respect of addition relating to belated payment of PF/ESI. In our view, this omission should also be treated as mistake apparent from record, which could have been brought to the notice

M/S. MANYATA PROMOTERS PRIVATE LIMITED (ERSTWHILE EMBASSY OFFICE PARKS PRIVATE LIMITED SINCE MERGED WITH MANYATA PROMOTERS PRIVATE LIMITED),BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX (OSD)- CENTRAL CIRCLE-1(3), BANGALORE

In the result, the assessee’s appeal is allowed for statistical purposes, while the revenue’s appeal is dismissed

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy Sassessment Year : 2017-18

disallowed u/s. 14A considering the same as a mistake apparent from the record. In the said rectification order the AO did not consider the issue raised by the assessee with regard to short credit of TDS. The assessee filed appeal before the CIT(Appeals) against the order of the AO u/s. 154

DEPUTY COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE-1(3), BANGALORE vs. M/S. MANYATA PROMOTERS PRIVATE LIMITED (ERSTWHILE EMBASSY OFFICE PARKS PRIVATE LIMITED ), BANGALORE

In the result, the assessee’s appeal is allowed for statistical purposes, while the revenue’s appeal is dismissed

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy Sassessment Year : 2017-18

disallowed u/s. 14A considering the same as a mistake apparent from the record. In the said rectification order the AO did not consider the issue raised by the assessee with regard to short credit of TDS. The assessee filed appeal before the CIT(Appeals) against the order of the AO u/s. 154

G I AUTO PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), , BANGALORE

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

Bench: Smt. Beena Pillai & Shri Waseem Ahmedassessment Year : 2019-2020

disallowance of deduction claimed u/s. 80JJAA of the act. The assessee filed rectification application u/s. 154 on 24/02/2021 which was partly

M/S AKME HARMONY APARTMENTS OWNERS WELFARE ASSOCIATION ,BANGALORE vs. INCOME TAX OFFICER WARD-4(2)(4), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

rectification order u/s 154 cannot prima-facie be held to be invalid. The assessee’s grounds of appeal are therefore disallowed

M/S. MPHASIS SOFTWARE & SERVICES (INDIA) PRIVATE LIMITED ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 4(1)(2),, BENGALURU

In the result, the appeal of the Assessee is allowed

Bench: Shri N.V.Vasudevan & Shri B.R.Baskaranita No.1948(Bang)/2018 (Assessment Year : 2014-15) Mphasis Software & Services (India) Pvt.Ltd., Bagmane World Technology Centre, 1St Floor, Wing A, Wtc 3, Kr Puram, Marathahalli Outer Ring Road, Mahadevapura, Bengaluru-560 048 Pan No.Aaccm5986K Appellant Vs The Asst. Commissioner Of Income Tax Officer, Circle-4,(1)(2), Bangalore Respondent Appellant By : Shri K.R.Girish, Ca Revenue By : Shri Manjeet Singh, Addl.Cit

disallowance u/s 14A of the Act adopted by the Assessee was incorrect in the light of the books of accounts of the Assessee and only then he can proceed to invoke Rule 8D(2)(iii) of the Rules. In this regard it was argued by the Assessee that the debatable issue are outside the purview of rectification proceedings u/s 154

GMR HYDERABAD INTERNATIONAL AIRPORT LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result ground II is allowed

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

rectification u/s 154 of the I.T.Act, the A.O. made disallowance u/s 14A of Rs.3,15,41,178 in computing the book

KK FOUNDATION AND PUBLIC CHARITABLE TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, (EXEMPTION) CIRCLE-1 , BENGALURU

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

rectification application u/s- 154-and the same was duly considered and the order passed. These are system related procedures which are sacrosanct and it is no possible to digress from these. Accordingly, it is held that there is no violation of principle of natural justice in these proceedings u/s 154 of the Act. The grounds of appeal no.1

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

154 of the Act. 6. That the learned CIT(A) has erred in not considering that the findings, reasons given by the AO for carrying out rectification are contrary to facts emerging from records and is unsustainable and untenable in law. 7. That the learned CIT (A) has erred in fastening a liability on the appellant u/s

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

154 of the Act. 6. That the learned CIT(A) has erred in not considering that the findings, reasons given by the AO for carrying out rectification are contrary to facts emerging from records and is unsustainable and untenable in law. 7. That the learned CIT (A) has erred in fastening a liability on the appellant u/s

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

154 of the Act. 6. That the learned CIT(A) has erred in not considering that the findings, reasons given by the AO for carrying out rectification are contrary to facts emerging from records and is unsustainable and untenable in law. 7. That the learned CIT (A) has erred in fastening a liability on the appellant u/s

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

154 of the Act. 6. That the learned CIT(A) has erred in not considering that the findings, reasons given by the AO for carrying out rectification are contrary to facts emerging from records and is unsustainable and untenable in law. 7. That the learned CIT (A) has erred in fastening a liability on the appellant u/s

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

154 of the Act. 6. That the learned CIT(A) has erred in not considering that the findings, reasons given by the AO for carrying out rectification are contrary to facts emerging from records and is unsustainable and untenable in law. 7. That the learned CIT (A) has erred in fastening a liability on the appellant u/s