ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

Bench: Shri George George K & Shri Waseem Ahmed

D E R PER BENCH: These are the appeals filed by the Revenue against the order passed by the NFAC, New Delhi dated 17/05/2023 for the assessment years 2017-18, 2018-19 & 2021-22. 2. At the outset, it is observed that the grounds of appeal raised by the Revenue in all three assessment years under consideration are identical

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

13. The CIT(A) dismissed the claim of the assessee and upheld the order of the AO on the basis that (i) Provisions for bad and doubtful debts made u/s 36(1)(viia) and referred to in sec. 36(1)(vii) and sec. 36(2)(v) applies to all advances, whether rural or other advances. (ii) deduction in respect

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

13. The CIT(A) dismissed the claim of the assessee and upheld the order of the AO on the basis that (i) Provisions for bad and doubtful debts made u/s 36(1)(viia) and referred to in sec. 36(1)(vii) and sec. 36(2)(v) applies to all advances, whether rural or other advances. (ii) deduction in respect

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

13 of 46 deduction towards PBDD under clause (a) of sec. 36(1)(viia) and it relates to the rural advances only. Hence the proviso to sec. 36(1)(vii) shall have bearing only on PBDD relating to rural advances only. Thus, according to Ld A.R, the bad debts written off relating to non- rural advances should be allowed independently

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

13 of 46 deduction towards PBDD under clause (a) of sec. 36(1)(viia) and it relates to the rural advances only. Hence the proviso to sec. 36(1)(vii) shall have bearing only on PBDD relating to rural advances only. Thus, according to Ld A.R, the bad debts written off relating to non- rural advances should be allowed independently

SRI PANATI VIDYANATH REDDY ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

D E R Per: Chandra Poojari, A.M. ITA No. 1148/Bang/2022 – AY 2019-20 This appeal by the assessee is directed against the order of the CIT(A)/NFAC, Delhi dated 18.11.2022 for AY 2019-20. 2. The facts are that for the assessment year under consideration the return of income was processed by the CPC and in the intimation issued

M/S. NIRMAL ENVIRO SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

D E R Per: Chandra Poojari, A.M. ITA No. 1148/Bang/2022 – AY 2019-20 This appeal by the assessee is directed against the order of the CIT(A)/NFAC, Delhi dated 18.11.2022 for AY 2019-20. 2. The facts are that for the assessment year under consideration the return of income was processed by the CPC and in the intimation issued

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

section 13(1)(d) of the Act, he submitted that the Standard Chartered Bank loan of Rs. 1,49,66,540 was borrowed by the family members and was introduced as loan in the trust with the object to carry on activities of the trust because trust was facing acute shortage of money. It was submitted that loans were obtained

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

13\n2\n103,01,34,0\n33\n309,04,02,09\n9\n2016\n309,04,02,09\n3035,54,78,4\n3344,58,80,5\n836,14,70,1\n2508,44,10,4\n-17\n9\n80\n79\n45\n34\n2017\n2508,44,10,4\n2508,44,10,4\n627,11,02,6\n1881

M/S. BANGALORE PHARMACEUTICAL AND RESEARCH LABORATORY PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-1(1)(2), BANGALORE

In the result, the appeal by the assessee is dismissed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2018-19

d) No expenditure which is "disallowable" indicated in the audit report e) It is a case of disallowance "inferred" from the audit report and not a disallowance indicated by the auditor. Additional Ground no 10 and 13 ( Paragraph 4 . Pages 58 to 63 and paragraph 9 pages 124 to 133) 11. Amendments made to Section 36(1

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

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

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

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

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

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

D E R PER BENCH: These appeals by the assessee in ITA Nos.294 to 296/Bang/2023 are directed against the order of NFAC, Delhi dated 12.1.2023 for the AYs 2018-19 to 2020-21 passed u/s 250 of the Income-tax Act,1961 ['the Act' for short]. The issue in all these appeals are common in nature except figures, hence, these

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

D E R PER BENCH: These appeals by the assessee in ITA Nos.294 to 296/Bang/2023 are directed against the order of NFAC, Delhi dated 12.1.2023 for the AYs 2018-19 to 2020-21 passed u/s 250 of the Income-tax Act,1961 ['the Act' for short]. The issue in all these appeals are common in nature except figures, hence, these

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

D E R PER BENCH: These appeals by the assessee in ITA Nos.294 to 296/Bang/2023 are directed against the order of NFAC, Delhi dated 12.1.2023 for the AYs 2018-19 to 2020-21 passed u/s 250 of the Income-tax Act,1961 ['the Act' for short]. The issue in all these appeals are common in nature except figures, hence, these

SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1(1) & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

D E R PER PRASHANT MAHARISHI, VICE PRESIDENT: 1. ITA No. 2396 and 2397/Bangalore/2024 are filed by the assessee against the appellate orders passed by The Additional Commissioner Of Income Tax – (A) – 4, Chennai (the learned CIT – A) dated 28 June 2024 for both these assessment years wherein the appeals filed against the assessment order passed under section

SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1 & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

D E R PER PRASHANT MAHARISHI, VICE PRESIDENT: 1. ITA No. 2396 and 2397/Bangalore/2024 are filed by the assessee against the appellate orders passed by The Additional Commissioner Of Income Tax – (A) – 4, Chennai (the learned CIT – A) dated 28 June 2024 for both these assessment years wherein the appeals filed against the assessment order passed under section

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the assessment order dated 20/06/2024 in DIN No. ITBA/AST/S/143(3)/2024-25/ 1065988655(1) for the assessment year 2020-21. 2. The issues raised by the assessee in Ground Nos. 1 to 3 of the appeal are general in nature and therefore, the same