M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

Appeal of the assessee is dismissed\nas infructuous

12 of the Act. Since, the exemption\nunder these sections was denied, the deduction claimed for donations as\napplication of income in the return was also disallowed

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE vs. M/S INFOSYS LIMITED , BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

disallowance under section 40(a)(i) should be deleted in entirety. Levy of interest under section 234B :- The learned CIT(A) has erred in 12

M/S INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

disallowance under section 40(a)(i) should be deleted in entirety. Levy of interest under section 234B :- The learned CIT(A) has erred in 12

MAGADI PLANNING AUTHORITY,RAMNAGAR vs. INCOME TAX OFFICER, WARD-3, BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

12 of the Act. 15.1 The facts, in brief, are that the appellant assessee, during the year under consideration, claimed an exemption under Section 10(20) of the Act against income earned or accrued by it. Consequently, the assessee declared taxable income as NIL in the return of income filed by it. 15.2 During the assessment proceedings, the AO found

MAGADI PLANNING AUTHORITY ,RAMNAGAR vs. INCOME TAX OFFICER, EXEMPTION, WARD-3, , BANGALORE

In the result appeal of the assessee is hereby allowed

12 of the Act.\n\n15.1 The facts, in brief, are that the appellant assessee, during the\nyear under consideration, claimed an exemption under Section 10(20) of\nthe Act against income earned or accrued by it. Consequently, the\nassessee declared taxable income as NIL in the return of income filed by\nit.\n\n15.2 During the assessment proceedings

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, the appeals filed by the assessee for all the four A

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER\nAND\nSHRI SOUNDARARAJAN K. (Judicial Member)

disallowance under Section 14A can be made\ntowards the interest expenditure where the Appellant's\ninterest-free funds exceed its interest-free investments.\nFor the above Grounds and for such other Grounds which\nmay be allowed by the Honourable Members to be urged\nat the time of hearing, it is prayed that the aforesaid\nappeal be allowed.”\n Assessment Year

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

disallowance under Section 14A can be made\ntowards the interest expenditure where the Appellant's\ninterest-free funds exceed its interest-free investments.\nFor the above Grounds and for such other Grounds which\nmay be allowed by the Honourable Members to be urged\nat the time of hearing, it is prayed that the aforesaid\nappeal be allowed.”\n Assessment Year

MAGADI PLANNING AUTHORITY,RAMNAGAR vs. INCOME TAX OFFICER, WARD-1, RAMNAGAR

12 of the Act.\n15.1 The facts, in brief, are that the appellant assessee, during the\nyear under consideration, claimed an exemption under Section 10(20) of\nthe Act against income earned or accrued by it. Consequently, the\nassessee declared taxable income as NIL in the return of income filed by\nit.\n15.2 During the assessment proceedings, the AO found

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED ,MANGALURU vs. ASSISTANT COMMISIONER OF INCOME TAX, CIRCLE - 2(1) , MANGALURU

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Soundararajan K.\Nita Nos.642 To 645/Bang/2024\N Assessment Years : 2017-18 To\N2020-21\Nm/S. Bharat Beedi Works\Nprivate Limited,\Ngolden Jubilee Building,\Nbharath Bagh,\Nkadri Road,\Nmangaluru – 575 002.\Npan: Aaacb9001B\Nappellant\Nassessee By\Nrevenue By\N: Shri Chythanya .K, Sr.\Nadvocate\N: Shri E. Shridhar, Cit-Dr\Ndate Of Hearing\Ndate Of Pronouncement\Norder\Nper Bench\Nthese Are The Appeals Filed By The Assessee Challenging The Orders Of\Nthe Ld.Cit(A) -2, Panaji Dated 30/01/2024 In Respect Of The A.Ys.2017-18,\N2018-19, 2019-20 & 2020-21. The Grounds Raised By The Assessee For\Neach Of The Assessment Years Are Extracted Hereunder For The Sack Of\Nconvenience.\Npage 2 Of 74\Nita Nos.642 To 645/Bang/2024\N Assessment Year 2017-18:\N“1. The Impugned Orders Of The Lower Authorities Are Not\Njustified In Law & On The Facts & Circumstances Of The\Ncase.\N2. The Impugned Assessment Proceedings & The\Nimpugned Assessment Order Under Section 143(3) Dated\N29.11.2021 Are Bad & Non-Est Since The Notice Under\Nsection 143(2) Dated 13.08.2018 Was Issued Without\Naffixing Any Signature Either Manually Or Digitally.\N3. Without Prejudice To The Above, Impugned Assessment\Nproceedings & The Impugned Assessment Order Under\Nsection 143(3) Dated 29.11.2021 Are Bad & Non-Est\Nbeing Based On The Notice Under Section 143(2) Dated\N13.08.2018 Which Is Vague, Without Of Application Of Mind\Nand Contrary To Section 143(2) & Applicable Board\Ncirculars & Instructions.\N4. As Regards Disallowance Under Section 14A U/S Rule\N8D(2)(Ii):\N4.

12. Without prejudice to the above, the Learned AO\nerred in relying upon the statement u/s 132(4) dated\n26.02.2020 of Mr. Srinivas Acharya, Manager of Karkala\nBranch when the same was administered by ADIT(Inv.)\nMysuru without any witness.\n15. 13. Without prejudice to the above, even if the\nimpugned disallowance was taken to be under Section

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU, BENGALURU vs. INFOSYS LIMITED, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

disallowance made under section 10AA of the Act ignoring that since no new master service agreement was made, the benefit of claim u/s 10AA from the old SEZ cannot be allowed. 5. The CIT(A) erred in remitting the matter to assessing officer on issue relating to section 80G of the Act ignoring that in instant case assessee

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, all the appeals filed by the assessee are allowed

disallowance made by the Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n\n Assessment Years 2018-19 to 2020-21:\n\n1.\nIt is submitted that the Assessee's Appeal

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

12. As already explained and evidenced from the computation of income as well as the orders of AO in the assessment proceedings, the entire provision has been disallowed under section

INFOSYS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Waseem Ahmed\Nand\Nshri Keshav Dubey\N\N\Nita No. 881/Bang/2023\N Assessment Year: 2019-20\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nvs.\N\Ndy. Commissioner Of Income Tax\Ncircle - 3(1)(1)\Nbmtc Building, 80 Feet Road\Nkoramangala, Bangalore – 560095\Nkarnataka\N\Nrespondent\N\Nita No. 245/Bang/2024\N Assessment Year: 2019-20\N\Njt. Commissioner Of Income Tax (Osd)\Ncircle - 3(1)(1)\Nroom No. 241, 2Nd Floor\Nbmtc Building, 80 Feet Road\N6Th Block, Koramangala\Nbangalore - 560095\Nkarnataka\N\Nvs.\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nrespondent\N\Nassessee By\Ndepartment By\N\Nsri Padam Chand Khincha – Ca\Nsmt. Srinandini Das – Cit - Dr\N\Ndate Of Hearing\Ndate Of Pronouncement:\N\N09.05.2025\N06.08.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Cross Appeals Are Filed Against The Order Of Ld. Commissioner Of\Nincome Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short \"Ld.\Ncit(A)/Nfac] Vide Din & Order No. Itba/Nfac/S/250/2023-24/1056786183(1) Dated 05.10.2023 Passed U/S.250 Of The Income Tax\Nact, 1961 (In Short “The Act\") For The A.Y.2019-20.\N\Npage 2 Of 34\N\N2. The Assessee Has Raised The Following Grounds Of Appeal: - \N\N\"1.\N\Ngeneral Ground\N\N1.

disallowance made under section\n10AA of the Act ignoring that since no new master service agreement was\nmade, the benefit of claim u/s 10AA from the old SEZ cannot be allowed.\n\n5.\nThe CIT(A) erred in remitting the matter to assessing officer on issue\nrelating to section 80G of the Act ignoring that in instant case assessee

BHARAT ELECTRONICS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, LARGE PAYERS TAX UNIT, CIRCLE-1, BANGALORE

In the result, appeal of the assessee is partly allowed

disallowance should restrict to\nRs. 2,52,14,792/- (Rs. 7,32,06,000 - Rs. 4,79,91,000).\nPage 12 of 15\nITA No.1067/Bang/2023\nBharat Electronics Limited, Bangalore\n7.10\nIn light of the above, she submitted that it is evident that the\ndisallowance of expenditure under section

M/S. VIJAYANAGAR EDUCATIONAL TRUST,BENGALURU vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), BENGALURU

In the result appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2019-20

disallowances allegedly admitted by Mrs. Rashmi Ravikiran ITA No.2006 /Bang/2019 Page 34 of 37 pertains primarily to capital expenditure and provisions for expenses. While such items may generally not be allowable as deductions under the head "profits and gains of business or profession" in the context of regular business entities, the same do qualify as application of income under Section

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubey

12,60,750/- as deduction under Section 80G of the Act. The TPO/A.O. has disallowed substantial portion of donation under

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

disallowance of interest has not been made under clause (b) of section 40 and as such, proviso to section 28(v) does not apply. This view has been upheld by ITAT, Ahmedabad Bench in case of Shankar Chemicals Works Vs ACIT (2011)(12

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

disallowance of interest has not been made under clause (b) of section 40 and as such, proviso to section 28(v) does not apply. This view has been upheld by ITAT, Ahmedabad Bench in case of Shankar Chemicals Works Vs ACIT (2011)(12

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

disallowance of interest has not been made under clause (b) of section 40 and as such, proviso to section 28(v) does not apply. This view has been upheld by ITAT, Ahmedabad Bench in case of Shankar Chemicals Works Vs ACIT (2011)(12