M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, LTU, CIRCLE-2, BANGALORE

In the result, the appeals are partly allowed for statistical purposes

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

disallowance : Rs.427,38,10,826.” 25. On appeal before the CIT(Appeals), the assessee submitted that it has computed the aggregate average advances by considering the outstanding loans of each rural branch at the end of the last day of each month separately and divided the resultant figure by number of months comprised therein. This method of working

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeals are partly allowed for statistical purposes

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

disallowance : Rs.427,38,10,826.” 25. On appeal before the CIT(Appeals), the assessee submitted that it has computed the aggregate average advances by considering the outstanding loans of each rural branch at the end of the last day of each month separately and divided the resultant figure by number of months comprised therein. This method of working

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeals are partly allowed for statistical purposes

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

disallowance : Rs.427,38,10,826.” 25. On appeal before the CIT(Appeals), the assessee submitted that it has computed the aggregate average advances by considering the outstanding loans of each rural branch at the end of the last day of each month separately and divided the resultant figure by number of months comprised therein. This method of working

M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojariassessment Year: 2018-19

disallowance of Rs.99,02,829/-, which is claimed by assessee as an interest payment. The assessee in the year under consideration advanced a sum of Rs.41 crores towards purchase of shares. The AO questioned the sources of Rs.41 crores paid as advance towards purchase of shares. The assessee stated that assessee had taken loan from M/s. Millenia Realtors

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

145\n22 on 30.09.2022, as per the sixth proviso to section 153B(1) of the Act.\nTherefore, the assessments completed on 24.11.2023 and 28.11.2023\nare clearly barred by limitation and are void ab initio.\n8.5 The ld. AR concluded by praying that the Hon’ble Tribunal may\nkindly hold that the assessments made for A.Ys

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

1, Alembic Chemicals Works Co Ltd reported in 177 ITR 377, IBM India Ltd 357 ITR 88 etc. The relevant extracts are under. The Ld.AR submitted that, following the direction of this Tribunal, the Ld.AO passed the OGE to ITAT order on 3.9.2019 and allowed the software expenses as revenue expenditure. 11.5. The Ld.AR submitted that the software expenses were

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

1, Alembic Chemicals Works Co Ltd reported in 177 ITR 377, IBM India Ltd 357 ITR 88 etc. The relevant extracts are under. The Ld.AR submitted that, following the direction of this Tribunal, the Ld.AO passed the OGE to ITAT order on 3.9.2019 and allowed the software expenses as revenue expenditure. 11.5. The Ld.AR submitted that the software expenses were

M/S HONEYWELL TECHNOLOGY SOLUTIONS LAB PRIVATE LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 , BANGALORE

Bench: Shri Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2013-14

Section 9(1)(vii) of the Income tax Act, liable for deduction of tax at source.” 7.8 The contention of the Ld A.R is that the assessee has availed only “legal and professional services” from some professional firms and it will not fall under the category of “Fee for technical services” defined in sec. 9(1

M/S THE SOUTH CANARA DISTRICT CENTRAL CO-OP BANK LTD,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, MANGALORE

In the result, the appeal of the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1, 5, 6 and 7 of appeal memo is that the Ld. CIT-A erred in holding that the hybrid/mixed system of accounting followed by the assessee does not violate the provisions of section 145 of the Act and accordingly erred in deleting the addition made by the AO on account of disallowing

M/S THE SOUTH CANARA DISTRICT CENTRAL CO-OP BANK LTD,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, MANGALORE

In the result, the appeal of the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1, 5, 6 and 7 of appeal memo is that the Ld. CIT-A erred in holding that the hybrid/mixed system of accounting followed by the assessee does not violate the provisions of section 145 of the Act and accordingly erred in deleting the addition made by the AO on account of disallowing

ACIT CIRCLE 1 (1)&TPS, MANGALURU vs. M/S THE SOUTH CANARA DISTRICT CENTRAL CO-OPERATIVE BANK LIMITED.,, MANGALURU

In the result, the appeal of the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1, 5, 6 and 7 of appeal memo is that the Ld. CIT-A erred in holding that the hybrid/mixed system of accounting followed by the assessee does not violate the provisions of section 145 of the Act and accordingly erred in deleting the addition made by the AO on account of disallowing

ACIT CIRCLE1(1)& TPS , MANGALURU, MANGALURU vs. M/S SOUTH KANARA DISTRICT CENTRAL CO-OPERATIVE BANK LTD, MANGALURU

In the result, the appeal of the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1, 5, 6 and 7 of appeal memo is that the Ld. CIT-A erred in holding that the hybrid/mixed system of accounting followed by the assessee does not violate the provisions of section 145 of the Act and accordingly erred in deleting the addition made by the AO on account of disallowing

M/S THE SOUTH CANARA DISTRICT CENTRAL CO-OP BANK LTD,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, MANGALORE

In the result, the appeal of the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1, 5, 6 and 7 of appeal memo is that the Ld. CIT-A erred in holding that the hybrid/mixed system of accounting followed by the assessee does not violate the provisions of section 145 of the Act and accordingly erred in deleting the addition made by the AO on account of disallowing

ACIT CIRCLE 1(1) & TPS, MANGALURU vs. M/S THE SOUTH CANARA DISTRICT CENTRAL CO-OPERATIVE BANK LIMITED, MANGALURU

In the result, the appeal of the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1, 5, 6 and 7 of appeal memo is that the Ld. CIT-A erred in holding that the hybrid/mixed system of accounting followed by the assessee does not violate the provisions of section 145 of the Act and accordingly erred in deleting the addition made by the AO on account of disallowing

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

145 2009-10 150 2010-11 160 2011-12 154 60. The ld. AR submitted that in page 231 of the Paper Book these details are furnished. The AO has included the dates of arrival in India also as being present in India. In this connection as held by the Co-ordinate Bench in Manoj Kumar Reddy Vs ITO, (International

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

145 2009-10 150 2010-11 160 2011-12 154 60. The ld. AR submitted that in page 231 of the Paper Book these details are furnished. The AO has included the dates of arrival in India also as being present in India. In this connection as held by the Co-ordinate Bench in Manoj Kumar Reddy Vs ITO, (International

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

145 2009-10 150 2010-11 160 2011-12 154 60. The ld. AR submitted that in page 231 of the Paper Book these details are furnished. The AO has included the dates of arrival in India also as being present in India. In this connection as held by the Co-ordinate Bench in Manoj Kumar Reddy Vs ITO, (International

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

145 2009-10 150 2010-11 160 2011-12 154 60. The ld. AR submitted that in page 231 of the Paper Book these details are furnished. The AO has included the dates of arrival in India also as being present in India. In this connection as held by the Co-ordinate Bench in Manoj Kumar Reddy Vs ITO, (International