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

In the result, all the appeals filed by the assessee are allowed

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

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

disallowed the deduction u/s 80P(2)(d) of the Act. It is\nsubmitted that the investments were made out of surplus funds\nand relied on the decision of Hon'ble Karnataka High Court in the\ndecision of PCIT v. Totagars Co-operative Sale Society 392 ITR 74\nwherein it was held that the interest earned on deposits

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

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

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

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

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

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

M/S. REGIONAL OILSEEDS GROWERS CO-OPERATIVE SOCIETIES UNION LIMITED,CHITRADURGA vs. JOINT COMMISSIONER OF INCOME TAX, DAVANGERE

In the result, the appeals filed by the assessee on this issue\nstands dismissed

195 (URO) wherein it has been\nheld that in the absence of a specific order issued in pursuance to Section 120(4)(b) specifically\nauthorizing Joint Commissioner of Income Tax to exercise the powers and perform the function\nas conferred on or assigned to an Assessing Officer by or under the Act or a notification under\nsection

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowed the deduction u/s 80P(2)(d) of the Act. It is submitted that the investments were made out of surplus funds and relied on the decision of Hon’ble Karnataka High Court in the decision of PCIT v. Totagars Co-operative Sale Society 392 ITR 74 wherein it was held that the interest earned on deposits

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

195 of the Act despite the salary payments having already suffered TDS under section 192 of the Act, giving rise to double taxation on the same transaction. 4. Disallowance of corporate social responsibility expenses claimed as deduction under section 80G of the Act 4.1 The Honorable DRP and the learned AO have erred in law and on facts in disallowing

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRLCE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

disallowance under section 40(a) (i) of the Act for non-deduction of\ntax under section 195 of the Act. It is ordered accordingly.\"\n\n3.2 held that:\n\nJurisdictional Karnataka High Court in the case of Flipkart Internet Pvt. Ltd. vs DCIT\n\"V. Conclusion:-\n\n33. In the present case, the stand taken on the material available

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

2,95,27,021 which was a receipt for the appellant from sale made to UBHL and is not liable to be included in disallowance; (AY 2017-18): Payment to United Breweries Holding Company (UBHL)– Rs.15,20,63,311/- 15. The Ld CIT(A) erred in upholding the order of the Ld AO disallowing the entire payment of Rs.15

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

2,95,27,021 which was a receipt for the appellant from sale made to UBHL and is not liable to be included in disallowance; (AY 2017-18): Payment to United Breweries Holding Company (UBHL)– Rs.15,20,63,311/- 15. The Ld CIT(A) erred in upholding the order of the Ld AO disallowing the entire payment of Rs.15

KARNATAKA BANK LTD,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, MANGALORE

Appeals of the revenue are partly allowed for statistical purposes

disallowed by holding that it is a contingent liability which is not correct. Since the assessee has made provision on the basis of certificate from the actuarial valuer therefore the provisions made are to be treated as ascertained liability. This view is fortified by the decision dated 22.02.2022 of the coordinate Bench of the Tribunal in the case of Jeans

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

disallowance under section 40(a) (i) of the Act for non-deduction of\ntax under section 195 of the Act. It is ordered accordingly.\"\n3.2 held that:\nJurisdictional Karnataka High Court in the case of Flipkart Internet Pvt. Ltd. vs DCIT\n\"V. Conclusion:-\n33. In the present case, the stand taken on the material available is on the construction

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

disallowance under section 40(a) (i) of the Act for non-deduction of\ntax under section 195 of the Act. It is ordered accordingly.\"\n\n3.2 held that:\nJurisdictional Karnataka High Court in the case of Flipkart Internet Pvt. Ltd. vs DCIT\n\n\"V. Conclusion:-\n\n33. In the present case, the stand taken on the material available

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

2 to section 36(1)(va) of the Act and Explanation 5 to section 43B of the Act which are prospective in nature and CBDT has clarified in the Explanatory Memorandum to Finance Bill, 2021 that the amendment is applicable from AY 2021-22. 3. We have heard the both the parties on admission of additional grounds. In our opinion

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

2 to section 36(1)(va) of the Act and Explanation 5 to section 43B of the Act which are prospective in nature and CBDT has clarified in the Explanatory Memorandum to Finance Bill, 2021 that the amendment is applicable from AY 2021-22. 3. We have heard the both the parties on admission of additional grounds. In our opinion

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

2 to section 36(1)(va) of the Act and Explanation 5 to section 43B of the Act which are prospective in nature and CBDT has clarified in the Explanatory Memorandum to Finance Bill, 2021 that the amendment is applicable from AY 2021-22. 3. We have heard the both the parties on admission of additional grounds. In our opinion

INSTAKART SERVICES PRIVATE LIMITED,BANGALORE vs. ACIT, SPECIAL RANGE-3, BANGALORE

In the result appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

195 of the Act to withhold tax clearly applied. Since no TDS was deducted, the AO invoked section 40(a)(i) of the Act and held that the expenditure was liable for disallowance. 18.5 Although the expenditure was already disallowed on merits under section 37, the AO noted that the non-deduction of tax also independently triggered disallowance under section

DCIT, CC-1(4), BENGALURU, BENGALURU vs. INSTAKART SERVICES PVT LTD, BENGALURU

In the result, the stay application dismissed as infructuous

195 of\nthe Act to withhold tax clearly applied. Since no TDS was deducted, the\nAO invoked section 40(a)(i) of the Act and held that the expenditure was\nliable for disallowance.\n18.5 Although the expenditure was already disallowed on merits under\nsection 37, the AO noted that the non-deduction of tax also\nindependently triggered disallowance under section