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

section 43B disallowance [para 7.3 page 23 of the impugned order of the CIT(A)]. The CIT(A) therefore upheld the addition made by the AO. 9.3 Aggrieved by the order of the first appellate authority, the assessee raised this issue before the Tribunal. The learned AR submitted that the amount of CST and excise duty were never claimed

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU, BENGALURU vs. INFOSYS LIMITED, BENGALURU

In the result, appeal filed by the assessee is partly allowed and the appeal filed by the revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

154 (SC) also make it clear that before applying the apportionment, the AO needs to record satisfaction that having regard to the kind of the assessee, suo moto disallowance u/s 14A of the Act is not correct. Further, as held by this Tribunal in assessee’s own case for AY 2014-15 and AY 2015-16, the disallowance under section

M/S. NSL SUGARS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME - TAX, CIRCLE - 5(1)(1), BANGALORE

In the result appeal filed by revenue stands dismissed

Bench: Shri B.R.Baskaran & Smt.Beena Pillai, Judical Member

disallowance for assessment year 2011-12 under section 14 A read with Rule 8D of the Act. 3. For both years under consideration, subsequently assessment order was revised under section 154

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.

disallowed a sum of\n\nPage 24 of 34\n\nRs.36,52,525 under section 14A. We also take a note of the fact that the\nHon'ble Supreme Court in the case of Maxopp Investment Ltd. V. CIT [2018]\n91 taxmann.com 154

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

disallowed under section 14A Income which does not form part of the total income is broadly adverted to as exempt income as an abbreviated appellation.” 9. After considering these principles as emerged from the decision of Hon’ble Supreme Court in the case of Walfort Share and Stock Brokers P. Ltd. (supra), Hon’ble Jurisdictional High Court has held

M N DASTUR & CO.PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, appeal by the assessee is allowed

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2014-15 M/S. M. N. Dastur & Co. Pvt. Ltd., Vs. Dcit, 7Th Floor, Raheja Towers, 26/27, Circle-4(1)(2), M. G. Road, Bengaluru – 560 001. Bengaluru. Pan : Aabcm 2136 M Appellant Respondent Appellant By : Shri. B. K. Manjunath, Advocate Respondent By : Shri. Swaroop Mannava, Jcit(Dr)(Itat), Bengaluru

disallowed the computation of total income of a sum of Rs.3,00,000/- under section 14A of the Act. An order of assessment under section 143(3) of the Page 2 of 7 Act was passed on 31.05.2016 accepting the returned loss of Rs.19,57,23,783/-. 3. The AO issued a notice under section 154

M/S. GARUDA SECURITY SERVICES,BANGALORE vs. ITO, WARD-5(2)(1), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1051 & 1052/Bang/2022 Assessment Year: 2018-19 & 2019-20

section 36(i)(va) of the Income-tax Act,1961 ['the Act' for short] r.w.s. 43B(b) of the Act. This disallowance was made in an intimation sent u/s 143(1) of the Act dated 16.10.2019 & 7.5.2020 for the AY 2018-19 & 2019-20 respectively. Later, the assessee has filed rectification petition u/s 154

M/S. GARUDA SECURITY SERVICES,BANGALORE vs. ITO, WARD-5(2)(1), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1051 & 1052/Bang/2022 Assessment Year: 2018-19 & 2019-20

section 36(i)(va) of the Income-tax Act,1961 ['the Act' for short] r.w.s. 43B(b) of the Act. This disallowance was made in an intimation sent u/s 143(1) of the Act dated 16.10.2019 & 7.5.2020 for the AY 2018-19 & 2019-20 respectively. Later, the assessee has filed rectification petition u/s 154

M/S. PRAZIM TRADING AND INVESTMENT COMPANY PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2021-22 M/S. Prazim Trading & Investment Vs. Dcit, Company Private Limited, Circle – 3(1)(1), 574, Next To Wipro Corporate Office, Bengaluru. Sarjapur Road, Doddakkanelli, Bengaluru – 560 035. Pan : Aaacp 4921 G Appellant Respondent Assessee By : Shri. B. K. Manjunath, Ca Revenue By : Shri. Subramanian S, Addl. Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 02.05.2024 Date Of Pronouncement : 24.06.2024

154 of the Act by the Centralized Processing Center, which mistake was continuing from the intimation u/s 143(1) of the Act, being an erroneous addition of Rs. 4,93,34,784/- by the IT portal and imputing the same amount as income under the head "profits and gains of business or profession", even when the Appellant had no income

NAVODAYA EDUCATION TRUST,RAICHUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY

In the result, the appeal of the assessee is dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2015-16

154 and claimed that the said disallowance was a mistake apparent from record. In rectification the most important aspect which needs to be looked into is whether the claim of the appellant within the scope of section

DIVYA DINESH ,BENGALURU vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result appeal of the assessee is allowed

154 of the Act. Accordingly, the action of CPC in not allowing the\nintra-head adjustment was upheld.\n7.2 With regard to the deduction under section 80G of the Act, the Id.\nCIT(A) noted that due to the disallowance

TEXO THE BUILDERS ,UDUPI vs. ACIT, CENTRAL CIRCLE-2, MANGALORE

In the result, we dismiss grounds raised by the assessee

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

section 154 of the Act and the AO passed Order on 10.09.2025 for the Assessment Year 2013-14 in ITA Nos.1199, 1200/Bang/2025 Page 3 of 28 which amount was not allowed in OGE were confirmed and rejected the rectification petition filed by the assessee. 5. The learned Counsel reiterated the submissions made before the lower authorities and he has filed

M/S. PRESTIGE ESTATES PROJECTS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, the appeal filed by assessee stands allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2014-15 M/S. Prestige Estates Projects The Deputy Ltd., Commissioner Of Prestige Falcon Tower, Income Tax, No. 19, Brunton Road, Central Circle – 1 Bangalore – North, (1), Bangalore – 560 025. Vs. Bangalore. Pan: Aabcp8096K Appellant Respondent : Shri Padamchand Khincha, Assessee By Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 19-04-2022 Date Of Pronouncement : 02-06-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 23.11.2021 Passed By Ld.Cit(A)-11, Bangalore For A.Y. 2014-15 On The Following Grounds Of Appeal: “The Grounds Mentioned Herein Below Are Independent & Without Prejudice To The Other Grounds Preferred By The Appellant. 1. General Ground 1.1 The Learned Deputy Commissioner Of Income Tax, Central Circle-1(1), Bengaluru (`Ao") Has Erred In Passing The Order Under Section 154 Of The Income Tax Act, 1961 (`The Act-) In The Manner Passed By Him & The Commissioner Of Income Tax (Appeals)-11, Bangalore

Section 154 of the Act and as such no interference is called for in the same.” 2.4 Aggrieved by the order of Ld.CIT(A), assessee has filed the present appeal before this Tribunal. 3. The Ld.AR before us has argued that the Ld.AO passed an order u/s. 154 in an order u/s. 154 dated 28.04.2016. He submitted that

JOINT COMMISSIONER OF INCOME TAX(OSD), CIRCLE- 4(1)(2), BANGALORE vs. M/S. MSOURCE (INDIA) PRIVATE LIMITED, BANGALORE

In the result, appeal of the Revenue and C

Bench: Shri Chandra Poojari & Shri George George Kassessment Year: 2012-13 The Asst. Commissioner Of M/S. Msource (India) Pvt. Ltd. 1St Floor, Wtc 3 Block, B Bagmane World Income Tax, Circle - 4(1)(2), Room No.230, 2Nd Technology Centre, Floor, Bmtc Building, 80 Feet Road, Vs. K. R. Puram, Marathahalli, 6Th Block, Koramangala, Outer Ring Road, Doddenekundi, Bangalore – 560 095. Bangalore-560 024. Pan No : Aaccm 2097 G Appellant Respondent C.O. No.57/Bang/2019 (In Ita No.1397/Bang/2019) M/S. Msource (India) Pvt. Ltd. Vs. The Asst. Commissioner Of Bangalore-560 024. Income Tax, Pan No : Aaccm 2097 G Bangalore – 560 095. Appellant Respondent Assessee By : Shri. K. R. Girish, Ca Revenue By : Shri. Kannan Narayanan, D.R. Date Of Hearing : 01.12.2020 Date Of Pronouncement : 03.12.2020 O R D E R Per Chandra Poojari:

disallowance under section 14A of the Act amounting to Rs.6,79,829/-. However, under section 14A r.w.r. 8D, it would be at Rs.83,10,213/-. This was recomputed by AO under section 154

JCIT, BANGALORE vs. M/S BHUWALKA PIPES PVT. LTD.,, BANGALORE

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

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raojoint Commissioner Of Income-Tax (Osd), Circle 1(1)(2), Bengaluru. … Appellant Vs. M/S.Bhuwalka Pipes Pvt. Ltd. ‘Solus’, 8Th Floor, E & G, No.2 1St Cross Road, Jc Road, Bengaluru-560027. … Respondent Pan: Aabcb 7778 E

disallowed 50% of the expenditure holding it to be not incurred wholly Page 4 of 9 and exclusively for the purpose of business. It is only during the course of proceedings under section 154

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

154", "Section 234B", "Section 234D", "Section 32(1)(iia)", "Section 2(29A)", "Section 147"], "issues": "Whether disallowance under Section 14A is valid

TEXO THE BUILDERS,UDUPI vs. ACIT, CENTRAL CIRCLE-2, MANGALORE

In the result, we dismiss grounds raised by the assessee

section\n37(1) of the Act but he has made addition under section 40A(3) of the Act\nbecause assessee did not satisfy the conditions laid down under the above\nsection. AO examined and found that payment of Rs.29,27,555/- does not\nsatisfy the provisions of section 40A(3) of the Act r.w.r.6DD(j). We have\ngone through

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

disallowed. On these facts, AO has found that this amount of Rs.40 Crore which was transferred to the retiring ITA Nos.1073 to 1075/Bang/2022 Century Sheltors, Bangalore & ITA Nos.1100 to 1102/Bang/2022 Century Silicon City, Bangalore Page 5 of 26 partners, has not been utilized wholly and exclusively for the purpose of the business. Therefore, the proportionate interest