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543 results for “disallowance”+ Section 195clear

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Key Topics

Section 4066 Section 143(3)61 Addition to Income61 Disallowance53 Section 10A42 Section 14841 Deduction41 Section 92C32 Section 143(1)30 Transfer Pricing

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T, BANGALORE

In the result, Revenue’s appeal for A

ITA 102/BANG/2013[2005-06]Status: DisposedITAT Bangalore10 Nov 2017AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri H.N. Khincha, C.AFor Respondent: Shri R. N. Parbat, CIT-III (D.R)

Section 143(3)Section 195Section 40Section 92ASection 92C

section 195 and hence not to be disallowed under section 40(a)(i). 4.3 Even otherwise, the disallowance, if any, should

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

Showing 1–20 of 543 · Page 1 of 28

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

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

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

Section 10ASection 14ASection 2Section 2(24)Section 40

disallowing software expenses paid/payable to residents and non residents amounting to Rs. 30,23,602 and Rs. 14,65,417 respectively [totaling to Rs.44,88,019] under section 40(a)(ia) / 40(a)(i) for not deducting tax at source in respect of the said payments under section 194J / 195

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result, Revenue’s appeal for Assessment Year 2006-07 is partly allowed for statistical purposes

ITA 799/BANG/2015[2006-07]Status: DisposedITAT Bangalore10 Nov 2017AY 2006-07

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri H.N. Khincha, C.AFor Respondent: Shri R. N. Parbat, CIT-III (D.R)

Section 143(1)Section 143(3)Section 195Section 40Section 92C

disallowance of subscription charges paid to M/s Gartner, Forester Research and Meta totally amounting to Rs. 8,42,00,399/- under section 40(a)(ia) of the Act. 2.2 On facts and circumstances of the case and law applicable, the impugned payments were not chargeable to tax in India, not liable for TDS under section 195

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

ITA 1520/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

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

For Respondent: Shri. Pradeep Kumar, CIT

Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

disallowance under section 40(a)(i) of the Act. 10.5.2 Section 195 of the Act deals with the deduction of tax at source

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

ITA 1447/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

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

For Respondent: Shri. Pradeep Kumar, CIT

Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

disallowance under section 40(a)(i) of the Act. 10.5.2 Section 195 of the Act deals with the deduction of tax at source

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

ITA 1519/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

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

For Respondent: Shri. Pradeep Kumar, CIT

Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

disallowance under section 40(a)(i) of the Act. 10.5.2 Section 195 of the Act deals with the deduction of tax at source

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

ITA 1448/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

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

For Respondent: Shri. Pradeep Kumar, CIT

Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

disallowance under section 40(a)(i) of the Act. 10.5.2 Section 195 of the Act deals with the deduction of tax at source

S N BUILDERS & DEVELOPERS ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(3)(1), BANGALORE

In the result, the appeal filed by the assessee- company is allowed

ITA 106/BANG/2019[2014-15]Status: DisposedITAT Bangalore27 Nov 2019AY 2014-15

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadalem/S. S.N.Builders & Developers, No.4, 2Nd Floor, Elephant Rock Road, Above Kalayan Jewellers, Jayanagar 3Rd Block, Bengaluru-560 011. Pan: Abefs 8850 P … Appellant Vs. Asst. Commissioner Of Income-Tax, Circle 4(3)(1), Bengaluru. … Respondent Appellant By : Smt. Suman Lunkar, Ca. Respondent By : Shri Pradeep Kumar, Cit(Dr) Date Of Hearing: 07/11/2019 Date Of Pronouncement: 27/11/2019 O R D E R Per Pavan Kumar Gadale, Jm : The Assessee Has Filed Appeal Against The Order Of The Cit(A), Bangalore-9, Bangalore, Passed U/S 143(3) & 250 Of The Income-Tax Act,1961 ['The Act' For Short].

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)

Section 143(2)Section 143(3)Section 234ASection 40Section 80Section 80I

disallow such claim for deduction. Similarly, vide the Finance Act, 2008, with effect from April 1, 2008, sub-section (6) has been inserted in section 195

DCIT, BANGALORE vs. M/S BIOCON RESEARCH LTD.,, BANGALORE

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

ITA 1251/BANG/2016[2012-13]Status: DisposedITAT Bangalore18 Dec 2017AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri R.N.Parbat, CIT(DR)

Section 10ASection 143(3)Section 14ASection 194CSection 40

disallow such claim for deduction. Similarly, vide the Finance Act, 2008, with effect from April 1, 2008, sub-section (6) has been inserted in section 195

BIOCON RESEARCH LIMITED,BANGALORE vs. CIT(A) I, BANGALORE

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

ITA 1329/BANG/2016[2012-13]Status: DisposedITAT Bangalore18 Dec 2017AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri R.N.Parbat, CIT(DR)

Section 10ASection 143(3)Section 14ASection 194CSection 40

disallow such claim for deduction. Similarly, vide the Finance Act, 2008, with effect from April 1, 2008, sub-section (6) has been inserted in section 195

BIOCON RESEARCH LIMITED,BANGALORE vs. CIT(A) I, BANGALORE

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

ITA 1229/BANG/2016[2011-12]Status: DisposedITAT Bangalore18 Dec 2017AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri R.N.Parbat, CIT(DR)

Section 10ASection 143(3)Section 14ASection 194CSection 40

disallow such claim for deduction. Similarly, vide the Finance Act, 2008, with effect from April 1, 2008, sub-section (6) has been inserted in section 195

DCIT, BANGALORE vs. M/S BIOCON RESEARCH LTD.,, BANGALORE

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

ITA 1250/BANG/2016[2011-12]Status: DisposedITAT Bangalore18 Dec 2017AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri R.N.Parbat, CIT(DR)

Section 10ASection 143(3)Section 14ASection 194CSection 40

disallow such claim for deduction. Similarly, vide the Finance Act, 2008, with effect from April 1, 2008, sub-section (6) has been inserted in section 195

BOSCJ LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal filed by the assessee company is treated as

ITA 1583/BANG/2014[2012-13]Status: DisposedITAT Bangalore01 Mar 2016AY 2012-13

Bench: Smt Asha Vijayaraghavan & Shri Inturi Rama Rao

For Appellant: Shri K.P.Kumar, Sr. CounselFor Respondent: Smt. Rukmani Attri, JCIT

Section 195Section 201(1)Section 40Section 95

disallow such claim for deduction. Similarly, vide the Finance Act, 2008, with effect from April 1, 2008, sub-section (6) has been inserted in section 195

M/S TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. CIT, BANGALORE

In the result, the appeal filed by the assessee-company is allowed

ITA 3/BANG/2015[2012-13]Status: DisposedITAT Bangalore25 May 2016AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raom/S.Te Connectivity India Pvt. Ltd. ‘Te’ Park, 22B, Doddenakundi 2Nd Phase, Industrial Area, Whitefield Road, Bangalore-560048. … Appellant Pan: Aabct 7374 C Vs. Income-Tax Officer (Ltu)(Tds) Bangalore. … Respondent

For Appellant: Shri Pravin Kishore Prasad, CAFor Respondent: Shri Sunil Kumar Agarwala, JCIT(DR)

Section 133(6)Section 201Section 250

disallow such claim for deduction. Similarly, vide the Finance Act, 2008, with effect from April 1, 2008, sub-section (6) has been inserted in section 195

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

ITA 481/BANG/2018[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

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

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR

Section 115JSection 143(2)Section 143(3)Section 14ASection 40Section 43B

disallowance was unwarranted since the said expense was incurred in view of the fact that major viewership of cricket is in the Indian subcontinent. He also referred to various newspapers reports which demonstrated the popularity of the sport in India to support the aforesaid contentions. It was also submitted that the assessee company has consistently promoted its range of products

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

ITA 643/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Apr 2025AY 2018-19

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER\nAND\nSHRI SOUNDARARAJAN K. (Judicial Member)

For Appellant: Shri Chythanya .K, SrFor Respondent: Shri E. Shridhar, CIT-DR

Section 143(2)Section 143(3)Section 14A

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

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

ITA 644/BANG/2024[2019-20]Status: DisposedITAT Bangalore21 Apr 2025AY 2019-20

Section 143(2)Section 143(3)Section 14A

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

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

ITA 809/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R

Section 11Section 14ASection 194JSection 234BSection 40Section 80J

section 195 of the Act. 9. During the course of assessment, the assessee stated that it has made payments of Rs. 3,34,07,038 to M/s. Forester Research as subscription during the current year. This issue has been a disputed issue for several years. This amount has been disallowed

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

ITA 735/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R

Section 11Section 14ASection 194JSection 234BSection 40Section 80J

section 195 of the Act. 9. During the course of assessment, the assessee stated that it has made payments of Rs. 3,34,07,038 to M/s. Forester Research as subscription during the current year. This issue has been a disputed issue for several years. This amount has been disallowed

HEWLETT PACKARD (INDIA) SOFTWARE OPERATION PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

ITA 413/BANG/2022[2017-18]Status: DisposedITAT Bangalore03 Oct 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.413/Bang/2022 Assessment Year: 2017-18

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Sumer Singh Meena, D.R

Section 192Section 195Section 37Section 40Section 92C

section 195 of the Act have not been complied with, and consequently reimbursement towards ESOP shall suffer disallowance under section