BRIGADE ENTERPRISES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), , BANGALORE

In the result, the assessee’s appeals for assessment years 2008-09 to 2010-11 are partly allowed for statistical purposes

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

disallowance under section 14A r.w.r. 8D(2)(ii); but set aside the issue of disallowance under section 14A r.w.r. 8D(2)(iii) to the file

M/S BRIGADE ENTERPRISES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), BANGALORE

In the result, the assessee’s appeals for assessment years 2008-09 to 2010-11 are partly allowed for statistical purposes

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

disallowance under section 14A r.w.r. 8D(2)(ii); but set aside the issue of disallowance under section 14A r.w.r. 8D(2)(iii) to the file

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

disallowance under Section_14A_r/w_Rule\n8D(2)(ii) without appreciating that disallowance under\nSection 14A cannot be made in the absence

M/S KBD SUGARS & DISTILLERIES LTD,BANGALORE vs. ASST. COMMISSIONER OF INCOME-TAX, BANGALORE

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

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

disallowance under section 14A investment portfolio. Reply of the assessee on the proposed disallowance under section 14A of the Act given

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 r/w Rule\n8D(2)(ii) without appreciating that disallowance under\nSection 14A cannot be made in the absence

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 14A should be made as per Rule 8D. 8.3. The DRP confirmed the disallowance under section 14A

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 14A should be made as per Rule 8D. 8.3. The DRP confirmed the disallowance under section 14A

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.

disallowance under Section 14A r/w Rule\n8D(2)(ii) without appreciating that disallowance under\nSection 14A cannot be made in the absence

M/S UNITED BREWERIES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

Disallowance under section 14A 1,31,50,663 Disallowance under section 40(a)(ia) 8,24,77,951 Disallowance under

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 under Section 14A r/w Rule\n8D(2)(ii) without appreciating that disallowance under\nSection 14A cannot be made in the absence

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

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

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

disallowance under section 14A without demonstrating satisfaction in terms of subsection 2 of section 14A as to why the disallowance

GMR POWER CORPORATION LIMITED,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result, assessee’s appeal viz

Bench: Shri Abraham P George & Shri Vijay Pal Rao & M/S.Gmr Power Corporation Ltd. 25/1, Skip House, Museum Road, Bangalore. … Appellant Pan:Aaacg 6037 G Vs. 1. Addl.Commissioner Of Income-Tax, Range-11, Bangalore. 2. Deputy Commissioner Of Income-Tax, Circle 3(1)(2), Bangalore … Respondent & (By The Revenue) ******** Assessee By: Shri Yogesh A Thar, Ca. Revenue By: Smt.Neera Malhotra, Cit(Dr).

disallowed under section 14A of the Act or where the assessee does not make any disallowance under section 14A of the Act, if the Assessing

DCIT, BANGALORE vs. M/S GMR POWER CORPORATION LTD., (FORMERLY KNOWN AS GMR POWER CORPORATION PVT. LTD.,), BANGALORE

In the result, assessee’s appeal viz

Bench: Shri Abraham P George & Shri Vijay Pal Rao & M/S.Gmr Power Corporation Ltd. 25/1, Skip House, Museum Road, Bangalore. … Appellant Pan:Aaacg 6037 G Vs. 1. Addl.Commissioner Of Income-Tax, Range-11, Bangalore. 2. Deputy Commissioner Of Income-Tax, Circle 3(1)(2), Bangalore … Respondent & (By The Revenue) ******** Assessee By: Shri Yogesh A Thar, Ca. Revenue By: Smt.Neera Malhotra, Cit(Dr).

disallowed under section 14A of the Act or where the assessee does not make any disallowance under section 14A of the Act, if the Assessing

GMR POWER CORPORATION LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, assessee’s appeal viz

Bench: Shri Abraham P George & Shri Vijay Pal Rao & M/S.Gmr Power Corporation Ltd. 25/1, Skip House, Museum Road, Bangalore. … Appellant Pan:Aaacg 6037 G Vs. 1. Addl.Commissioner Of Income-Tax, Range-11, Bangalore. 2. Deputy Commissioner Of Income-Tax, Circle 3(1)(2), Bangalore … Respondent & (By The Revenue) ******** Assessee By: Shri Yogesh A Thar, Ca. Revenue By: Smt.Neera Malhotra, Cit(Dr).

disallowed under section 14A of the Act or where the assessee does not make any disallowance under section 14A of the Act, if the Assessing

MANIPAL GLOBAL EDUCATION SERVICES PVT LTD., ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(2), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance under Rule 8D r.w.s. 14A of the Act. 15. Section 14a OF The Act is as under :- [Expenditure incurred

MANIPAL HOSPITALS PVT. LTD (FORMERLY KNOWN AS COLUMBIA ASIA HOSPITALS PVT. LTD),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance under Rule 8D r.w.s. 14A of the Act. 15. Section 14a OF The Act is as under :- [Expenditure incurred

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD. ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance under Rule 8D r.w.s. 14A of the Act. 15. Section 14a OF The Act is as under :- [Expenditure incurred

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance under Rule 8D r.w.s. 14A of the Act. 15. Section 14a OF The Act is as under :- [Expenditure incurred