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

disallowance of deduction under Section 80G of the Act. In the financial year 2014-15, the assessee has incurred expenditure of Rs.4,72,00,024/to meet the CSR (Corporate Social Responsibility) as per Policy formulated under Section 135

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.

135 of the Companies Act, 2013) (18 of\n2013).\"\n\nWhere these two exceptions are provided in Section 80G of the Act, it can be inferred that the\nother contributions made u/s.135(5) of the Companies Act are also eligible for deduction u/s.\n80G of Income Tax Act subject to assessee satisfying the requisite conditions prescribed for\ndeduction u/s.80G

M/S ZEENATH TRANSPORT COMPANY ,BELLARY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1, BELLARY

In the result, appeal filed by the assessee stands partly allowed as indicated herein above

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallow above expenditure incurred by the assessee. Explanation (2) to section 37 reads as follows:- “Explanation 2. — For the removal of doubts, it is hereby declared that for the purposes of sub-section (1), any expenditure incurred by an assessee on the activities relating to corporate social responsibility referred to in section 135

SRI. B. RUDRAGOUDA,BELLARY vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1, BELLARY

In the result, the appeal is allowed

Bench: Shri Chandra Poojari & Shri George George K.

disallow above expenditure incurred by the assessee. Explanation (2) to section 37 reads as follows:- ITA Nos.314 & 315/Bang/2020 Page 10 of 70 “Explanation 2. — For the removal of doubts, it is hereby declared that for the purposes of sub-section (1), any expenditure incurred by an assessee on the activities relating to corporate social responsibility referred to in section 135

SRI. B. RUDRAGOUDA,BELLARY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1, BELLARY

In the result, the appeal is allowed

Bench: Shri Chandra Poojari & Shri George George K.

disallow above expenditure incurred by the assessee. Explanation (2) to section 37 reads as follows:- ITA Nos.314 & 315/Bang/2020 Page 10 of 70 “Explanation 2. — For the removal of doubts, it is hereby declared that for the purposes of sub-section (1), any expenditure incurred by an assessee on the activities relating to corporate social responsibility referred to in section 135

M/S. SYNGENE INTERNATIONAL LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 6, BANGALORE

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

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2010-11

disallowed. Contentions before the ITAT: 3.6 There is no splitting up or reconstruction of business. The following factual aspects demonstrate the independence of SEZ Unit S11: 3.7 Physical location: The EOU unit 1 was situated at 20th KM, Hosur Road whereas the SEZ unit — S 11 is situated at Biocon SEZ, Bommasandra - Jigani Link Road, Bangalore. These two units

MYSORE MINERALS LIMITED (NOW KNOWN AS KARNATAKA STATE MINERALS CORPORATION LIMITED),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 4(1)(2), BENGALURU

In the result, both the appeals are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallow above expenditure incurred by the assessee. Explanation (2) to section 37 reads as follows:- “Explanation 2. — For the removal of doubts, it is hereby declared that for the purposes of sub-section (1), any expenditure incurred by an assessee on the activities relating to corporate social responsibility referred to in section 135

MYSORE MINERALS LIMITED (NOW KNOWN AS KARNATAKA STATE MINERALS CORPORATION LIMITED),BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 4(1)(2), BENGALURU

In the result, both the appeals are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallow above expenditure incurred by the assessee. Explanation (2) to section 37 reads as follows:- “Explanation 2. — For the removal of doubts, it is hereby declared that for the purposes of sub-section (1), any expenditure incurred by an assessee on the activities relating to corporate social responsibility referred to in section 135

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK ,BENGALURU vs. INCOME-TAX OFFICE, WARD-5(2)(1), BENGALURU

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

135, 146 & 313/2019 -22- undertaking.\nSub-clause (iib) of clause (a) of section 40 provides that,\nany amount paid by way of royalty, licence fee, service fee,\nprivilege fee, service charge, or any other fee or charge\n\"which is levied exclusively on\" a state government\nundertaking by the State Government (emphasis supplied)\nalone will satisfy the ingredients for disallowance

M/S. PEAK XV PARTNERS ADVISORS PRIVATE LIMITED, ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

disallowed under Section 37, can be eligible for deduction under Section 80G if the conditions are met. The Tribunal also clarified the validity of approvals under Section 80G based on CBDT circulars. The issue of eligibility and quantum of deduction was remitted back to the AO.", "result": "Partly Allowed", "sections": [ "80G", "37(1)", "135

REDSEER MANAGEMENT CONSULTING PRIVATE LIMITED,BENGALURU vs. DCIT, CIRCLE-5(1)(1), BANGALORE

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

sections": [ "143(1)", "143(2)", "142(1)", "80G", "37(1)", "135", "30", "36" ], "issues": "Whether a donation made as part of Corporate Social Responsibility (CSR) expenditure, which was disallowed

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

section 37 of the I.T.Act, expenditure laid out and expended wholly and exclusively for the purpose of business or profession shall be allowed as deduction while computing the business income. To qualify as a business expenditure, the following the conditions are to be satisfied :- (i) expenditure must be revenue in nature; Page 14 of 37 IT(TP)A No. 2333/Bang/2016

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

section 37 of the I.T.Act, expenditure laid out and expended wholly and exclusively for the purpose of business or profession shall be allowed as deduction while computing the business income. To qualify as a business expenditure, the following the conditions are to be satisfied :- (i) expenditure must be revenue in nature; Page 14 of 37 IT(TP)A No. 2333/Bang/2016

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

section 37 of the I.T.Act, expenditure laid out and expended wholly and exclusively for the purpose of business or profession shall be allowed as deduction while computing the business income. To qualify as a business expenditure, the following the conditions are to be satisfied :- (i) expenditure must be revenue in nature; Page 14 of 37 IT(TP)A No. 2333/Bang/2016

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

section 37 of the I.T.Act, expenditure laid out and expended wholly and exclusively for the purpose of business or profession shall be allowed as deduction while computing the business income. To qualify as a business expenditure, the following the conditions are to be satisfied :- (i) expenditure must be revenue in nature; Page 14 of 37 IT(TP)A No. 2333/Bang/2016

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

section 37 of the I.T.Act, expenditure laid out and expended wholly and exclusively for the purpose of business or profession shall be allowed as deduction while computing the business income. To qualify as a business expenditure, the following the conditions are to be satisfied :- (i) expenditure must be revenue in nature; Page 14 of 37 IT(TP)A No. 2333/Bang/2016

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

135, 146 & 313/2019 -22- undertaking.\nSub-clause (iib) of clause (a) of section 40 provides that,\nany amount paid by way of royalty, licence fee, service fee,\nprivilege fee, service charge, or any other fee or charge\n\"which is levied exclusively on\" a state government\nundertaking by the State Government (emphasis supplied)\nalone will satisfy the ingredients for disallowance

M/S BOSCH LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE-1 , BANGALORE

In the result, appeal of the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2013-14 Bosch Limited, Vs. The Assistant Commissioner Hosur Road, Adugodi, Of Income Tax, Ltu, Bangalore – 560 030. Circle 1, Pan: Aaacm 9840P Bangalore. Appellant Respondent Appellant By : Shri Percy Pardiwala, Advocate Respondent By : Shri V S Chakrapani, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 01.09.2022 Date Of Pronouncement : 13.09.2022 O R D E R Per Padmavathy S.2. This Appeal Is Against The Order Of The Cit(Appeals), Bangalore-9, Bangalore Dated 31.3.2018 For The Assessment Year 2013- 14. 3. The Assessee Raised Grounds Pertaining To The Following Issues:- Deduction U/S. 35(2Ab) Computed On Net Expenditure As Opposed To Gross Expenditure Disallowance Of Provision For Bad & Doubtful Debts I) Disallowance Of Provision For Long Term Service Award Disallowance Of Expenditure U/S. 14A Of The Act Ii) Page 2 Of 67

disallowance is restricted to the expenses incurred by the assessee under a statutory obligation under section 135 of Companies Act 2013, and there