M/S. GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

In the result, the assessee's appeal is partly allowed for statistical purposes

Bench: Shri A.K. Garodia & Shri Pavan Kumar Gadaleit(Tp)A No.2355/Bang/2019 (Assessment Year: 2015-16) M/S. Goldman Sachs Services Pvt. Ltd., Wing A, B & C, Helios Business Park, 150, Orr, Kadubeesanahalli, Bangalore-560103 ….Appellant Pan Aaccg 2435N Vs. Joint Commissioner Of Income Tax, Special Range 3, Bangalore. ……Respondent.

section 192 of the Act, giving rise to double taxation on the same transaction. 6. Disallowance of corporate social responsibility

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT LTD ,BANGALORE vs. INCOME TAX OFFICER (TDS) /OSD , BANGALORE

In the result, both the appeals filed by assessee stands allowed for statistical purposes

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

disallowed under section 40(a)/(i)/(ia) while filing the return of income and therefore for non deduction of TDS. What needs to be ascertained is, under such circumstances; whether the assessee(deductor) could be treated to be “assessee in default” under the provisions of Sec.201(1) of the Act ? Whether interest under section 201(1A) deserves to be levied

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIAVTE LIMITED ,BANGALORE vs. INCOME TAX OFFICER (TDS) /OSD LTU , BANGALORE

In the result, both the appeals filed by assessee stands allowed for statistical purposes

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

disallowed under section 40(a)/(i)/(ia) while filing the return of income and therefore for non deduction of TDS. What needs to be ascertained is, under such circumstances; whether the assessee(deductor) could be treated to be “assessee in default” under the provisions of Sec.201(1) of the Act ? Whether interest under section 201(1A) deserves to be levied

INCOME TAX OFFICER, BANGALORE vs. M/S.DELL INDIA PVT.LTD.,, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

disallowed under section 40(a)/(i)/(ia) while filing the return of income and therefore for non deduction of TDS. What needs to be ascertained is, under such circumstances; whether the assessee(deductor) could be treated to be “assessee in default” under the provisions of Sec.201(1) of the Act ? Whether interest under section 201(1A) deserves to be levied

DELL INTERNATIONAL SERVICES INDIA PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

disallowed under section 40(a)/(i)/(ia) while filing the return of income and therefore for non deduction of TDS. What needs to be ascertained is, under such circumstances; whether the assessee(deductor) could be treated to be “assessee in default” under the provisions of Sec.201(1) of the Act ? Whether interest under section 201(1A) deserves to be levied

DELL INDIA P LTD,BANGALORE vs. INCOME TAX OFFICER(TDS), LTU, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

disallowed under section 40(a)/(i)/(ia) while filing the return of income and therefore for non deduction of TDS. What needs to be ascertained is, under such circumstances; whether the assessee(deductor) could be treated to be “assessee in default” under the provisions of Sec.201(1) of the Act ? Whether interest under section 201(1A) deserves to be levied

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubey

section 192 of the Act, giving rise to double taxation on the same transaction. 4. Disallowance of corporate social responsibility

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

disallowance under section 14A. Section 14A concerns itself with proximate expenditure and not any other expenditure howsoever remote and distant. This proposition is affirmed by the following judicial precedents: • CIT v Socidade De Fomento Industrial Pvt Limited (2020) 429 ITR 358 (Born) [CLC-III Pg.490-501] • Canara Bank v ACIT [2014] 52 taxmann.com 162 (Karnataka) [CLC Pg.324-341] M/s. Syngene International Limited

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

disallowing the reimbursement of salary amounting to Rs 36,87,29,475 under section 40(a)(i) of the Act paid by the Appellant to the overseas Group affiliates on secondment of employees. 9. The learned CIT(A) has erred, in law and facts, by erroneously holding that the payment to overseas group entities, towards reimbursement of salary, amounting

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DCIT, CIRCLE 1(1) & TPS, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DCIT, CIRCLE-1(1), MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DCIT, CIRCLE 1(1) & TPS, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DEPUTY COMMISSIONER OF INCOME TAX, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DCIT, CIRCLE 1(1) & TPS, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government