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

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

17,34,85,084 4. During the reassessment proceedings, the AO observed that the assessee has claimed a sum of Rs.936,90,65,332 as deduction u/s. 36(1)(viia) of the Act in the computation of income filed with the return. The AO observed that as per section 36(1)(viia), assessee is eligible to get deduction

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

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

17,34,85,084 4. During the reassessment proceedings, the AO observed that the assessee has claimed a sum of Rs.936,90,65,332 as deduction u/s. 36(1)(viia) of the Act in the computation of income filed with the return. The AO observed that as per section 36(1)(viia), assessee is eligible to get deduction

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

D E R Per Jason P Boaz, Accountant Member These three appeals by the assessee are directed against the separate orders of CIT(A)-1, Bangalore, for Assessment Years 2008-09 to 2010-11. Since common issues are involved, these appeals were heard together and we ITA Nos.528 to 530/Bang/2018 Page 2 of 22 deem it appropriate to dispose them

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

D E R Per Jason P Boaz, Accountant Member These three appeals by the assessee are directed against the separate orders of CIT(A)-1, Bangalore, for Assessment Years 2008-09 to 2010-11. Since common issues are involved, these appeals were heard together and we ITA Nos.528 to 530/Bang/2018 Page 2 of 22 deem it appropriate to dispose them

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

D E R Per Jason P Boaz, Accountant Member These three appeals by the assessee are directed against the separate orders of CIT(A)-1, Bangalore, for Assessment Years 2008-09 to 2010-11. Since common issues are involved, these appeals were heard together and we ITA Nos.528 to 530/Bang/2018 Page 2 of 22 deem it appropriate to dispose them

M/S KBD SUGARS & DISTILLERIES LTD. vs. ACIT,

In the result, the appeals of the assessee for the Assessment Years 2008-

5. Ground No.3 & 4 are in respect of the disallowance made under Section 14A on account of indirect administrative expenses under Rule 8D(2)(iii) of the Income Tax Rules. During the year under consideration the assessee has earned an dividend income of Rs.63,477, the Assessing Officer apart from the disallowance under Section 14A on account of interest expenditure

INCOMETAX OFFICER, WARD 1, UDUPI, UDUPI vs. BRAHMAVARA VYAVASAYA SEVA, BRAHMAVARA

In the result, the appeals filed by Revenue are allowed and the COs\nfiled by the assessee are allowed for statistical purposes

disallowance under\nsection 80P(2)(d) of the Act.\n5.\nAs regards the Assessment Years 2018-19 and 2020-21, the AO\nnoticed that the assessee had claimed deduction under section 80P(2)(a)(i)\nof the Act for the interest income earned from investments with co-\noperative banks. The AO was of the view that the aforesaid interest income

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 made by the Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n Assessment Years 2018-19 to 2020-21:\n1.\nIt is submitted that the Assessee's Appeal in ITA Nos.645

INCOME TAX OFFICER, WARD 1, UDUPI, UDUPI vs. BRAHMAVARA VYAVASAYA SEVA, BRAHMAVARA

In the result, the appeals filed by Revenue are allowed and the COs\nfiled by the assessee are allowed for statistical purposes

disallowance under\nsection 80P(2)(d) of the Act.\n5. As regards the Assessment Years 2018-19 and 2020-21, the AO\nnoticed that the assessee had claimed deduction under section 80P(2)(a)(i)\nof the Act for the interest income earned from investments with co-\noperative banks. The AO was of the view that the aforesaid interest income

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

D of Chapter IV before 'Gross Total Income' as defined under Section 80-B(5) is computed and after which the consideration of various Deductions under Chapter VI-A in Section 80HH etc. comes into picture. Therefore analogy of Chapter VI Deductions cannot be telescoped or imported in Section 10-A or 10-B of the Act. The words 'derived

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

17-21 stands allowed for statistical purposes. 10. The Ld.AR submitted that Ground no. 16 is not pressed and accordingly the same is dismissed. 11. Ground nos. 22-24 – Disallowance of software expenses as capital expenditure. Alternatively, assessee has prayed for depreciation to be granted at 60% as against 25%. The assessee is engaged in the business of development

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

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU, BENGALURU vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED, BENGALURU

In the result both the appeals of the Revenue as well as\nCos of the Assessee for the Asst

d). Accordingly, the assessment was\nconcluded on 22.09.2021 disallowing the deduction of Rs\n3,32,62,487/- claimed by the assessee u/s 80P of the IT Act.\n2. That appeal proceeding for the Assessment Year 2018-19 has\nbeen concluded by the Commissioner of Income Tax, National\nFaceless Appeal Centre on 24.09.2024 in Appeal No. NFAC/2017-\n18/10082339\nwith\nDIN: ITBA/NFAC/S/250/2024-

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

disallowance made by the Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n Assessment Years 2018-19 to 2020-21:\n1.\nIt is submitted that the Assessee's Appeal

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1(4), BENGALURU vs. M/S KANSUR DEVELOPERS INDIA PVT. LTD. , BENGALURU

In the result, the revenue appeals in ITA Nos

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: These appeals by the revenue are directed against orders of CIT(A)-11, Bangalore dated 28.2.2018 for the assessment years 2009-10, 2012-13 & 2008-09 in respect of above two assessees and the Cross objections filed by the assessees against the appeals of the revenue. The grounds raised by the revenue

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1(4), BENGALURU vs. M/S SNOWSHINE REALTORS PVT.LTD. , BENGALURU

In the result, the revenue appeals in ITA Nos

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: These appeals by the revenue are directed against orders of CIT(A)-11, Bangalore dated 28.2.2018 for the assessment years 2009-10, 2012-13 & 2008-09 in respect of above two assessees and the Cross objections filed by the assessees against the appeals of the revenue. The grounds raised by the revenue

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1-(4), BENGALURU vs. M/S KANSUR DEVELOPERS INDIA PVT. LTD., BENGALURU

In the result, the revenue appeals in ITA Nos

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: These appeals by the revenue are directed against orders of CIT(A)-11, Bangalore dated 28.2.2018 for the assessment years 2009-10, 2012-13 & 2008-09 in respect of above two assessees and the Cross objections filed by the assessees against the appeals of the revenue. The grounds raised by the revenue

ACIT, BANGALORE vs. M/S JUPITER CAPITAL (P) LTD.,, BANGALORE

In the result, ITA No. 60/Bang/2012 and 253/Bang/2014 of the assessee are partly allowed for statistical purposes and ITA

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raoassessee’S Appeal

17. This appeal is preferred by the assessee against the order of the CIT(A) mainly on the following grounds: 1. The learned Commissioner of Income tax (Appeals)-I, Bangalore, herein after referred to as assessing officer, erred in considering the interest amount of Rs 3,02,104 as an expenditure disallowable under section 14A of the Act ignoring

JUPITER CAPIAL P. LTD. vs. CIT, BANGALORE

In the result, ITA No. 60/Bang/2012 and 253/Bang/2014 of the assessee are partly allowed for statistical purposes and ITA

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raoassessee’S Appeal

17. This appeal is preferred by the assessee against the order of the CIT(A) mainly on the following grounds: 1. The learned Commissioner of Income tax (Appeals)-I, Bangalore, herein after referred to as assessing officer, erred in considering the interest amount of Rs 3,02,104 as an expenditure disallowable under section 14A of the Act ignoring