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

23,45,95,152. It is also submitted that, no dividends were received in respect of shares of Infosys BPM Ltd (formerly known as Infosys BPO Ltd). Disallowance under section

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

23,45,95,152. It is also submitted that, no dividends were received in respect of shares of Infosys BPM Ltd (formerly known as Infosys BPO Ltd). Disallowance under section

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

disallowance made by the assessee under section 14A is not correct having regard to the books of account of the assessee. The CIT(A)/NFAC accordingly deleted the ITA No.245/Bang/2024 Infosys Limited Page 23

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED ,MANGALURU vs. ASSISTANT COMMISIONER OF INCOME TAX, CIRCLE - 2(1) , MANGALURU

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Soundararajan K.\Nita Nos.642 To 645/Bang/2024\N Assessment Years : 2017-18 To\N2020-21\Nm/S. Bharat Beedi Works\Nprivate Limited,\Ngolden Jubilee Building,\Nbharath Bagh,\Nkadri Road,\Nmangaluru – 575 002.\Npan: Aaacb9001B\Nappellant\Nassessee By\Nrevenue By\N: Shri Chythanya .K, Sr.\Nadvocate\N: Shri E. Shridhar, Cit-Dr\Ndate Of Hearing\Ndate Of Pronouncement\Norder\Nper Bench\Nthese Are The Appeals Filed By The Assessee Challenging The Orders Of\Nthe Ld.Cit(A) -2, Panaji Dated 30/01/2024 In Respect Of The A.Ys.2017-18,\N2018-19, 2019-20 & 2020-21. The Grounds Raised By The Assessee For\Neach Of The Assessment Years Are Extracted Hereunder For The Sack Of\Nconvenience.\Npage 2 Of 74\Nita Nos.642 To 645/Bang/2024\N Assessment Year 2017-18:\N“1. The Impugned Orders Of The Lower Authorities Are Not\Njustified In Law & On The Facts & Circumstances Of The\Ncase.\N2. The Impugned Assessment Proceedings & The\Nimpugned Assessment Order Under Section 143(3) Dated\N29.11.2021 Are Bad & Non-Est Since The Notice Under\Nsection 143(2) Dated 13.08.2018 Was Issued Without\Naffixing Any Signature Either Manually Or Digitally.\N3. Without Prejudice To The Above, Impugned Assessment\Nproceedings & The Impugned Assessment Order Under\Nsection 143(3) Dated 29.11.2021 Are Bad & Non-Est\Nbeing Based On The Notice Under Section 143(2) Dated\N13.08.2018 Which Is Vague, Without Of Application Of Mind\Nand Contrary To Section 143(2) & Applicable Board\Ncirculars & Instructions.\N4. As Regards Disallowance Under Section 14A U/S Rule\N8D(2)(Ii):\N4.

section 28 to 44DA” of the revised\nreturn dated 09.02.2021 was towards undervaluation of\nstock whereas the appellant reflected the same value of\nstocks as supported by its books, audited financials and\ntax audit report, in all its returns.\n14. 7. The Learned AO erred in making the impugned\naddition merely on the basis of statements extracted from\nthe Appellant

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

Section 132(4).\n\nPage 23 of 74\nITA Nos.642 to 645/Bang/2024\n16. 8. The Learned AO erred in making the impugned\naddition merely on the basis of statements extracted from\nthe Appellant during search proceedings under coercion,\nwhen the same were retracted by the Appellant vide\nletters dated 06.01.2021 (the copy of same was also filed\nbefore Learned Ad.CIT

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.

disallowance made by the\nassessee under section 14A is not correct having regard to the books of\naccount of the assessee. The CIT(A)/NFAC accordingly deleted the\n\nPage 23

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

23. Ground No.9 is with regard to disallowance of claim u/s 40(a)(ia) of the Act. IT(TP)A No.2846/Bang/2017 M/s. Dell International Services India Pvt. Ltd., Bangalore Page 25 of 47 23.1 The ld. A.R. submitted that the Assessing Officer disallowed a sum of Rs. 11,52,36,103/- under Section

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 68,72,56,631/- Disallowance of interest on reserve fund Ground No.5: 3,95,432/- Mismatch of TDS 3. 725/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 23

M/S. BHARAT ELECTRONICS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

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

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahuassessment Year : 2012-13 M/S. Bharat Electronics The Assistant Ltd., Commissioner Of Registered Office, Income Tax, Outer Ring Road Ltu, Nagawara, Circle – 1, Vs. Bangalore – 560 045. Bangalore. Pan: Aaacb5985C Appellant Respondent

Section 14A of the Act r.w. Rule 8D in its return of income and it is humbly submitted that disallowance to the tune of Rs. 4,69,055/- (5,99,055-1,30,000) on total investments is unjustified. B. Disallowance of Foreign exchange loss of Rs. 48,23