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

section 14A rws 8D. Accordingly the Ground No 2 as raised by the Revenue is dismissed. 17. The Ground No 3 deals with disallowance of brand building expenditure which was deleted by the ld. CIT(A)/NFAC. The brief facts in this regard are as under- During the year under consideration, the assessee incurred expenditure

M/S. SYNGENE INTERNATIONAL LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 6, BANGALORE

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

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2010-11

disallowed. Contentions before the ITAT: 3.6 There is no splitting up or reconstruction of business. The following factual aspects demonstrate the independence of SEZ Unit S11: 3.7 Physical location: The EOU unit 1 was situated at 20th KM, Hosur Road whereas the SEZ unit — S 11 is situated at Biocon SEZ, Bommasandra - Jigani Link Road, Bangalore. These two units

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

section 40(a)(i) of the Act and disallowed these expenses claimed. On appeal, the CIT(A) upheld the order of the AO on this issue. 10.3.1 Before us, the learned AR for the assessee reiterated the submissions put forth before the authorities below. It is submitted that the only reason for disallowance of these expenses incurred on commission payments

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

section 40(a)(i) of the Act and disallowed these expenses claimed. On appeal, the CIT(A) upheld the order of the AO on this issue. 10.3.1 Before us, the learned AR for the assessee reiterated the submissions put forth before the authorities below. It is submitted that the only reason for disallowance of these expenses incurred on commission payments

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

section 40(a)(i) of the Act and disallowed these expenses claimed. On appeal, the CIT(A) upheld the order of the AO on this issue. 10.3.1 Before us, the learned AR for the assessee reiterated the submissions put forth before the authorities below. It is submitted that the only reason for disallowance of these expenses incurred on commission payments

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

section 40(a)(i) of the Act and disallowed these expenses claimed. On appeal, the CIT(A) upheld the order of the AO on this issue. 10.3.1 Before us, the learned AR for the assessee reiterated the submissions put forth before the authorities below. It is submitted that the only reason for disallowance of these expenses incurred on commission payments

M/S DELL INTERNATIONAL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. JCIT, BANGALORE

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

Disallowance on provision for leave encashment: 8. That on the facts and circumstances of the case and in law, the AO has erred in adding back provision for leave encashment amounting to INR 82,356,024 for computing book profit under section 115JB of the Act. 9. That on the facts and circumstances of the case

M/S. TEJAS NETWORKS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

disallowed during AY 2010-11 and treated as eligible for depreciation under section 32 of the Act by the learned AO in its order for AY 2010-11) despite the fact that the same IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 19 of 34 was allowed

TEJAS NETWORKS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

disallowed during AY 2010-11 and treated as eligible for depreciation under section 32 of the Act by the learned AO in its order for AY 2010-11) despite the fact that the same IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 19 of 34 was allowed

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

disallowed during AY 2010-11 and treated as eligible for depreciation under section 32 of the Act by the learned AO in its order for AY 2010-11) despite the fact that the same IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 19 of 34 was allowed

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

disallowed during AY 2010-11 and treated as eligible for depreciation under section 32 of the Act by the learned AO in its order for AY 2010-11) despite the fact that the same IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 19 of 34 was allowed

TEJAS NETWORKS LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

disallowed during AY 2010-11 and treated as eligible for depreciation under section 32 of the Act by the learned AO in its order for AY 2010-11) despite the fact that the same IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 19 of 34 was allowed

ASST.C.I.T., BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

disallowed during AY 2010-11 and treated as eligible for depreciation under section 32 of the Act by the learned AO in its order for AY 2010-11) despite the fact that the same IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 19 of 34 was allowed

M/S TEJATS NETWORKS LIMITED ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL , BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

disallowed during AY 2010-11 and treated as eligible for depreciation under section 32 of the Act by the learned AO in its order for AY 2010-11) despite the fact that the same IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 19 of 34 was allowed

M/S PRAXAIR INDIA PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2 , BANGALORE

In the result, both the appeals of the assessee in IT(TP)A No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 271(1)(c) of the Act for furnishing inaccurate particulars of income. IT(TP)A No.3336/Bang/2018 & IT(TP)A No.199/Bang/2021 M/s. Praxier India Pvt. Ltd., Bengaluru Page 14 of 62 4. Ground Nos.1 to 4 in the AY 2014-15 and ground Nos.1 & 2 in the AY 2015-16 are general in nature, which do not require any adjudication

M/S. PRAXAIR INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, both the appeals of the assessee in IT(TP)A No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 271(1)(c) of the Act for furnishing inaccurate particulars of income. IT(TP)A No.3336/Bang/2018 & IT(TP)A No.199/Bang/2021 M/s. Praxier India Pvt. Ltd., Bengaluru Page 14 of 62 4. Ground Nos.1 to 4 in the AY 2014-15 and ground Nos.1 & 2 in the AY 2015-16 are general in nature, which do not require any adjudication

IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

184/-. The penalty under sub-section (7) of section 270A of the Act was levied for disallowance of employees contribution

JCIT, BANGALORE vs. M/S HEWLETT PACKARD INDIA SALES P. LTD.,, BANGALORE

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

disallowances sustained. 8. First, we take up the appeal file by the ld. AO and also deal with connected grounds of appeal of assessee. 9. Ground No. 1 is general in nature, ground no 1 -2 of the appeal of the assessee, are general in nature, no arguments advanced and hence dismissed. 10. Ground no. 2 is against the deletion

HEWLETT PAKCARD INDIA SALES PRIVATE LIMITED,BANGALORE vs. JCIT, BANGALORE

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

disallowances sustained. 8. First, we take up the appeal file by the ld. AO and also deal with connected grounds of appeal of assessee. 9. Ground No. 1 is general in nature, ground no 1 -2 of the appeal of the assessee, are general in nature, no arguments advanced and hence dismissed. 10. Ground no. 2 is against the deletion