M/S MARMON FOOD & BEVERAGE TECHNOLOGIES INDIA PVT LTD ,BANGALORE vs. THE INCOME TAX OFFICER WARD-11(2), BANGALORE

In the result, appeal of the assessee in ITA No

Bench: Shri Sunil Kumar Yadav

Section 144A of the Act for the assessment year 2009- 10. 4. The Learned Commissioner (Appeals) is not justified in upholding the action of the Learned Assessing Officer in disallowing

SMT. BRIDGET ANTHONY(LEGAL HEIR OF LATE MR. ELEVATHINGAL JOSEPH ANTHONY),BANGALORE vs. INCOME-TAX OFFICER, WARD-4(2)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

disallowances, the assessee would be given a fair opportunity to explain his position on the proposed additions/disallowances in accordance with the principle of natural justice. In this regard, the Assessing Officer shall issue an appropriate show-cause notice duly indicating the reasons for the proposed additions/disallowances along with necessary evidences/reasons forming the basis of the same. Before passing the final

M/S. ORIGAMI CELLULO PRIVATE LIMITED,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 5, BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2015-16

144A; (ii) an order made by the [Joint] Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer conferred on, or assigned to, him under the orders or directions issued by the Board or by the [Principal Chief Commissioner or] Chief Commissioner or [Principal Director General or] Director General or [Principal Commissioner

CHOKKANAHALLI GUNDAPPA CHANDRAPPA ,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), BANGALORE

In the result both these appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

144A of the Act disallowed the expenditure of Rs. 4,65,00,000 and Rs. 1,94,62,591 for assessment 2017-18 and 2018-19 respectively and concluded the assessment proceedings by passing the Order u/s 143(3) of the Act. 5. Aggrieved by the order of the AO passed u/s 143(3) of the Act, the assessee preferred

CHOKKANAHALLI GUNDAPPA CHANDRAPPA ,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), BANGALORE

In the result both these appeals filed by the\nassessee are allowed

144A" ], "issues": "Whether statements recorded during a survey under Section 133A of the Income Tax Act, without corroborative evidence and subsequently retracted, can be the sole basis for disallowing

M/S. MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BANGALORE

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2015-16

section 36(1)(iii) could not be invoked to disallowed interest on borrowed loans. ……….. …………… Page 22 of 25 Accordingly, the disallowance of Rs.4,85,00,000/- by the A.O, that was erroneously confirmed by the CIT(A) - ought to be deleted, since the invocation of Sec.36(1)(iii) Proviso is not warranted, as the Assessee held sufficient funds 'interest free

KOGOD BASAVARAJU JAYACHANDRA ,HASSAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result the ITA No

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

disallowance of interet but while assessing the income in has not been considered. For the sake of convenience, we are reproducing the same: “8. Considering the rival submissions, we note that a survey was conducted in the case of in the case of M/s Xentrix Studios P Ltd on 03.05.2017 and statements were recorded

KOGOD BASAVARAJU JAYACHANDRA ,HASSAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result the ITA No

disallowance of interet but while assessing the income in\nhas not been considered. For the sake of convenience, we are reproducing the\nsame:\n\n“8. Considering the rival submissions, we note that a survey was conducted\nin the case of in the case of M/s Xentrix Studios P Ltd on 03.05.2017 and\nstatements were recorded u/s.131

EIT SERVICES INDIA PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1)(2), BANGALORE, BANGALORE

In the result, the appeals of the assessee are treated as allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri B R Baskaran

disallowance on account of treating expenditure on software as revenue expenditure was Rs.38,26,608 and this sum was added to the total income of the Assessee; (ii) The Assessee had claimed deduction u/s.10A of the Act at Rs.134,80,27,117/-. The AO found that in applying the formula for claiming deduction u/s.10A of the Act, the Assessee

EIT SERVICES INDIA PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1)(2), BANGALORE

In the result, the appeals of the assessee are treated as allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri B R Baskaran

disallowance on account of treating expenditure on software as revenue expenditure was Rs.38,26,608 and this sum was added to the total income of the Assessee; (ii) The Assessee had claimed deduction u/s.10A of the Act at Rs.134,80,27,117/-. The AO found that in applying the formula for claiming deduction u/s.10A of the Act, the Assessee

VANISHREE HOLABSU SHETTAR,GULEDGUDD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, HUBLI

In the result, the appeal is allowed in favour of the assessee

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2017-18

disallowing the agricultural expenses amounting to Rs.1,27,461/-. The assessee received a show cause notice u/s. 263 of the Act from the PCIT proposing to set aside the assessment order u/s. 143(3) for the reason that the same is erroneous and prejudicial to the interest of the Revenue. The assessee filed submissions stating that the AO has made

SRI RAMASEVA BAHUSARA KSHARIYA CO-OP. SOCIETY LIMITED,SHIMOGA vs. PR. CIT, BENGALURU-1, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21 M/S. Sri Ramaseva Bahusara Kshariya Co-Op. Society Ltd. 01, Ramanna Setty Park Spm Road, Doddapete So Vs. Principal Cit Shimoga 577 202 Bengaluru-1 Karnataka Pan No :Aaajs0083P Appellant Respondent Appellant By : Sri V. Srinivasan, A.R. Respondent By : Sri Kiran D., D.R. Date Of Hearing : 11.12.2025 Date Of Pronouncement : 30.01.2026

disallowances, and other determinations made by the AO on facts and Law, however, for an appeal against a revision order u/s 263 of the Act, the Tribunal is essentially confine itself to examine (1) Whether the very assumption of 263 jurisdiction is valid (2) whether the PCIT’s conclusion on “erroneous and prejudicial” are sustainable in law and (3) Whether

BHARATH CREDIT CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. PR. CIT, BANGALORE -1, BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2020-21

disallowances, and other determinations made by the AO on facts and Law, however, for an appeal against a revision order u/s 263 of the Act, the Tribunal is essentially confine itself to examine (1) Whether the very assumption of 263 jurisdiction is valid (2) whether the PCIT’s conclusion on “erroneous and prejudicial” are sustainable in law and (3) Whether

BSNL EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LIMITED ,HUBBALLI vs. PR. CIT, HUBBALLI , HUBBALLI

In the result the appeal filed by the assessee is allowed

disallowances, and other determinations made by the AO\non facts and Law, however, for an appeal against a revision order u/s 263 of the Act,\nthe Tribunal is essentially confine itself to examine (1) Whether the very assumption\nof 263 jurisdiction is valid (2) whether the PCIT's conclusion on “erroneous and\nprejudicial” are sustainable in law and (3) Whether

ADARSHA SOUHARDA SAHAKARI NIYAMIT SIRSI,SIRSI vs. PR. COMMISSIONER OF INCOME TAX, , HUBALLI

In the result the appeal filed by the assessee is allowed

disallowances, and other determinations\nmade by the AO on facts and Law, however, for an appeal against a\nrevision order u/s 263 of the Act, the Tribunal is essentially confine\nitself to examine (1) Whether the very assumption of 263\njurisdiction is valid (2) whether the PCIT's conclusion on\n“erroneous and prejudicial” are sustainable

BHAVANA CO-OP CREDIT SOCIETY NIYAMITA ,SIRSI vs. INCOME TAX OFFICER, WARD-1, SIRSI

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

disallowances, and other determinations made by the AO on facts and Law, however, for an appeal against a revision order u/s 263 of the Act, the Tribunal is essentially confine itself to examine (1) Whether the very assumption of 263 jurisdiction is valid (2) whether the PCIT’s conclusion on “erroneous and prejudicial” are sustainable in law and (3) Whether

GONIKOPPAL PRIMARY RURAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-3, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

disallowances, and other determinations made by the AO on facts and Law, however, for an appeal against a revision order u/s 263 of the Act, the Tribunal is essentially confine itself to examine (1) Whether the very assumption of 263 jurisdiction is valid (2) whether the PCIT’s conclusion on “erroneous and prejudicial” are sustainable in law and (3) Whether

IBM GLOBAL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2000-2001

144A of the Act. One of the disallowance made in the assessment order was denying exemption claimed u/s. 10A of the act on the ground that, the export turnover brought into India does not amount to 75 percent of the total turnover of the STP unit. It was submitted by the assessee that, it treated export credits of the bank

M/S AD2PRO MEDIA SOLUTIONS PRIVATE LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all the 14 appeals filed by the assessee are allowed

Bench: Shri A.K.Garodia & Shri P.K.Gadale(Ita Nos.490 To 503(Bang)/2019) (Assessment Years: 2011-12 To 2017-18) M/S Ad2Pro Media Solutions Pvt.Ltd., No.10, 2Nd Floor, Bannerghatta Road, J.P.Nagar-Iii Phase, Bangalore-560078 Appellant Vs The Deputy Commissioner Of Income Tax, (International Taxation) Circle-1(1), Bmtc Building, Koramangala, Bangalore-560095 Respondent

144A. 10.1. Assessee claims that this issue was already discussed by Corporate AO and the payment was accepted without any disallowance. 10.2. This claim deserves to be rejected for the following reasons: 1) Ld AR filed a 'Note' on Pg 414, claiming to have filed it before that AO. No evidence was furnished as to whether this was actually filed