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

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

INCOME-TAX OFFICER, WARD-1, UDUPI, UDUPI vs. BRAHMAVARA VYAVAYASAYA 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

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

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 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

M/S. SAVANOOR PRIMARY AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LTD.,SAVANOOR, ,PUTTUR vs. INCOME TAX OFFICER, WARD-1, , PUTTUR

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

Bench: Shri George George K & Shri Chandra Poojariassessment Year : 2018-19 M/S. Savanoor Primary Agricultural Vs. Ito, Co-Operative Society Ltd., Ward – 1, Savanoor Co-Operative Agricultural Puttur. Bank Ltd., Saanoor, Savanoor Puttur – 574 202, Karnataka. Pan : Aaeat 1118 M Appellant Respondent Assessee By : Ms. Harsha J, Advocate Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 08.01.2024 Date Of Pronouncement : 09.01.2024

71,588/- which was claimed as deduction under section 80P(2)(a)(iii) of the Act. The AO disallowed the claim

M/S. NAVODAYA GRAMA VIKAS CHARITABLE TRUST,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, BANGALORE

In the result, the appeal filed by assessee stands allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18 M/S. Navodaya Grama Vikas Charitable Trust, The Deputy #14-7-1005, Scdcc Commissioner Of Bank Ltd., Income Tax, Head Office Building, Central Circle – 1, Kodialbail, Vs. Mangaluru. Mangaluru – 575 003. Pan: Aaatn7594E Appellant Respondent : Shri V. Srinivasan, Advocate & Assessee By Ms. Sunaina Bhatia, Ca Revenue By : Shri D.K. Mishra, Cit Dr Date Of Hearing : 07-07-2023 Date Of Pronouncement : 31-08-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 07.03.2022 Passed By Ld.Cit(A)-2, Panaji For A.Y. 2017-18 On Following Grounds Of Appeal: “1. The Orders Of The Authorities Below In So Far As They Are Against The Appellant Are Opposed To Law. Equity, Weight Of Evidence. Probabilities, Facts & Circumstances Of The Case. 2. The Learned Cit [A] Is Not Justified In Upholding The Disallowance Of The Exemption Claimed U/S.11 Of The Act

disallowance of the exemption claimed u/s.11 of the Act, Page 2 on the ground that the activities of the appellant are hit by the provisions of section 13[8] rws the proviso to section 2[15] of the Act, under the facts and in the circumstances of the appellant's case. 3. The learned CIT[A] has erred in holding

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

71,216 vii) Incentive from airlines amounting to Rs.7,63,88,054 viii) Rental income from BSNL amounting to Rs.12,000 3.2. On facts and circumstances of the case and law applicable, the appellant is entitled for the claim of deduction under section 10AA of the Act on the above incomes included in the profits of eligible SEZ units

CHANDRASHEKAR HEMANTH ,BENGALURU vs. INCOME TAX OFFICER WARD 7(2)(4) BANGALORE, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

disallowing the said losses whereas in the present case, the losses related to the A.Ys. 2012-13 and 2013-14 which were properly determined by the AO by considering the returns filed in time and therefore the AO as well as the Ld.CIT(A) had decided the issue erroneously as against the provisions of the Act. 11. We have also

SRI SRINIVASA TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 11 of the Act. Therefore, we direct the AO to delete the disallowance of Rs. 39,99,359.00 only. 15. In the result, the appeal filed by the assessee is partly allowed. Now Coming to ITA No. 1076/Bang/2024 for the AY 2021-22 16. The first issue raised by the assessee in ground No. 2 is that

SRI SRINIVASA TRUST,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 11 of the Act. Therefore, we direct the AO to delete the disallowance of Rs. 39,99,359.00 only. 15. In the result, the appeal filed by the assessee is partly allowed. Now Coming to ITA No. 1076/Bang/2024 for the AY 2021-22 16. The first issue raised by the assessee in ground No. 2 is that

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD. ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

71, if the Assessing Officer, having regard to the accounts of the assessee, is not satisfied with the correctness of the claim of the assessee in respect of such expenditure in relation to income which does not form part of the total income under this Act. (3) The provisions of sub-section (2) shall also apply in relation

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD.,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

71, if the Assessing Officer, having regard to the accounts of the assessee, is not satisfied with the correctness of the claim of the assessee in respect of such expenditure in relation to income which does not form part of the total income under this Act. (3) The provisions of sub-section (2) shall also apply in relation

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

71, if the Assessing Officer, having regard to the accounts of the assessee, is not satisfied with the correctness of the claim of the assessee in respect of such expenditure in relation to income which does not form part of the total income under this Act. (3) The provisions of sub-section (2) shall also apply in relation

MANIPAL GLOBAL EDUCATION SERVICES PVT LTD., ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(2), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

71, if the Assessing Officer, having regard to the accounts of the assessee, is not satisfied with the correctness of the claim of the assessee in respect of such expenditure in relation to income which does not form part of the total income under this Act. (3) The provisions of sub-section (2) shall also apply in relation

MANIPAL HOSPITALS PVT. LTD (FORMERLY KNOWN AS COLUMBIA ASIA HOSPITALS PVT. LTD),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

71, if the Assessing Officer, having regard to the accounts of the assessee, is not satisfied with the correctness of the claim of the assessee in respect of such expenditure in relation to income which does not form part of the total income under this Act. (3) The provisions of sub-section (2) shall also apply in relation

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

In the result, appeal filed by the assessee is partly allowed and the\nappeal filed by the revenue is dismissed

Bench: Shri Waseem Ahmed\Nand\Nshri Keshav Dubey\N\N\Nita No. 881/Bang/2023\N Assessment Year: 2019-20\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nvs.\N\Ndy. Commissioner Of Income Tax\Ncircle - 3(1)(1)\Nbmtc Building, 80 Feet Road\Nkoramangala, Bangalore – 560095\Nkarnataka\N\Nrespondent\N\Nita No. 245/Bang/2024\N Assessment Year: 2019-20\N\Njt. Commissioner Of Income Tax (Osd)\Ncircle - 3(1)(1)\Nroom No. 241, 2Nd Floor\Nbmtc Building, 80 Feet Road\N6Th Block, Koramangala\Nbangalore - 560095\Nkarnataka\N\Nvs.\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nrespondent\N\Nassessee By\Ndepartment By\N\Nsri Padam Chand Khincha – Ca\Nsmt. Srinandini Das – Cit - Dr\N\Ndate Of Hearing\Ndate Of Pronouncement:\N\N09.05.2025\N06.08.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Cross Appeals Are Filed Against The Order Of Ld. Commissioner Of\Nincome Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short \"Ld.\Ncit(A)/Nfac] Vide Din & Order No. Itba/Nfac/S/250/2023-24/1056786183(1) Dated 05.10.2023 Passed U/S.250 Of The Income Tax\Nact, 1961 (In Short “The Act\") For The A.Y.2019-20.\N\Npage 2 Of 34\N\N2. The Assessee Has Raised The Following Grounds Of Appeal: - \N\N\"1.\N\Ngeneral Ground\N\N1.

2. The learned CIT(A) has erred in relying on the Explanation to below\nsubsection 1 of section 10AA without appreciating that the said Explanation\nis applicable only at the stage of allowing deduction under section 10AA\nfrom the total income and it is not applicable at the stage of computation of\ndeduction under section 10AA in respect of profits