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 14A of the Act can be invoked where the assessee has not incurred any expenditure in relation to exempt income. 4.6 In this regard, the AO referred the decision of Hon'ble High Court of Delhi in the case Maxopp investments Ltd Vs. CIT (TS- 668-HC-2011(HC)), which has upheld the decision of the Hon'ble High

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE vs. SHRI H B SUDARSHAN , CHIKKAMANGALUR

In the result, all the assessee’s appeals are dismissed and revenue’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts in the circumstances of the Appellants case. 7. The appellant craves leave to add, alter, substitute and delete any or all of the grounds

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE vs. SHRI.H B SUDARSHAN , CHIKKAMANGALUR

In the result, all the assessee’s appeals are dismissed and revenue’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts in the circumstances of the Appellants case. 7. The appellant craves leave to add, alter, substitute and delete any or all of the grounds

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE , BANGALORE vs. SHRI. H B SUDARSHAN , CHIKKAMANGALUR

In the result, all the assessee’s appeals are dismissed and revenue’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts in the circumstances of the Appellants case. 7. The appellant craves leave to add, alter, substitute and delete any or all of the grounds

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE , BANGALORE vs. SHRI.H B SUDARSHAN , CHIKKAMANGALUR

In the result, all the assessee’s appeals are dismissed and revenue’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts in the circumstances of the Appellants case. 7. The appellant craves leave to add, alter, substitute and delete any or all of the grounds

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE , BANGALORE vs. SHRI H B SUDARSHAN , CHIKKAMANGALUR

In the result, all the assessee’s appeals are dismissed and revenue’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts in the circumstances of the Appellants case. 7. The appellant craves leave to add, alter, substitute and delete any or all of the grounds

SHRI H B SUDARSHAN ,CHIKKAMANGALUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the assessee’s appeals are dismissed and revenue’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts in the circumstances of the Appellants case. 7. The appellant craves leave to add, alter, substitute and delete any or all of the grounds

SHRI H B SUDARSHAN ,CHIKKAMANGALUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the assessee’s appeals are dismissed and revenue’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts in the circumstances of the Appellants case. 7. The appellant craves leave to add, alter, substitute and delete any or all of the grounds

SHRI H B SUDARSHAN,CHIKKAMANGALUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the assessee’s appeals are dismissed and revenue’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts in the circumstances of the Appellants case. 7. The appellant craves leave to add, alter, substitute and delete any or all of the grounds

SHRI H B SUDARSHAN ,CHIKKAMANGALUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the assessee’s appeals are dismissed and revenue’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts in the circumstances of the Appellants case. 7. The appellant craves leave to add, alter, substitute and delete any or all of the grounds

SRI. SINGONAHALLI CHIKKAREVANNA GANGADHARAIAH,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(1), BENGALURU

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

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

disallowed since the situation contemplated by the first proviso viz. deduction and payment of tax in a subsequent year would never come about. Such unintended consequence has been sought to be taken care of by the second proviso inserted in section 40(a)(ia) by the Finance Act, 2012. There can be no 15 Sri.Singonahalli Chikkarevanna Gangadharaiah. doubt that

TEXO THE BUILDERS ,UDUPI vs. ACIT, CENTRAL CIRCLE-2, MANGALORE

In the result, we dismiss grounds raised by the assessee

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

disallowed under Section 40A(3) of the Act. 2.16. We rely on the decision of Hon’ble ITAT Jaipur in case of Brother Pharma (P.) Ltd. V. Income tax Officer, Ward 4(2), Jaipur [2017] 82 taxmann.com 234

BANGALORE TURF CLUB LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(2), BENGALURU

In the result, appeal filed by assessee stands partly allowed and appeal filed by revenue stands dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14

234 wherein it has held that the payment of stake money is neither covered under section 194BB nor under section 194B of the Act. 3.2. The learned AO has erred in not appreciating that a review petition filed by the department does not empower the assessing officer to disregard a binding jurisdictional high court decision. 3.3. On facts

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2), BANGALORE vs. M/S. BANGALORE TURF CLUB LIMITED, BANGALORE

In the result, appeal filed by assessee stands partly allowed and appeal filed by revenue stands dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14

234 wherein it has held that the payment of stake money is neither covered under section 194BB nor under section 194B of the Act. 3.2. The learned AO has erred in not appreciating that a review petition filed by the department does not empower the assessing officer to disregard a binding jurisdictional high court decision. 3.3. On facts

TEXO THE BUILDERS,UDUPI vs. ACIT, CENTRAL CIRCLE-2, MANGALORE

In the result, we dismiss grounds raised by the assessee

disallowed under Section 40A(3) of the Act.\n\n2.16.\nWe rely on the decision of Hon'ble ITAT Jaipur in case of Brother\nPharma (P.) Ltd. V. Income tax Officer, Ward 4(2), Jaipur [2017] 82\ntaxmann.com 234

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

disallowing a sum of Rs. 2,22,64,350/- being Rehabilitation and Reclamation Expenses claimed by the appellant as ITA Nos.619 to 622/Bang/2025 Page 4 of 26 Revenue expenditure in the profit and loss account based on the facts and circumstances of the case. The learned Commissioner of Income-tax [Appeals] and the learned 8. assessing officer both failed

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

disallowing a sum of Rs. 2,22,64,350/- being Rehabilitation and Reclamation Expenses claimed by the appellant as ITA Nos.619 to 622/Bang/2025 Page 4 of 26 Revenue expenditure in the profit and loss account based on the facts and circumstances of the case. The learned Commissioner of Income-tax [Appeals] and the learned 8. assessing officer both failed

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

disallowing a sum of Rs. 2,22,64,350/- being Rehabilitation and Reclamation Expenses claimed by the appellant as ITA Nos.619 to 622/Bang/2025 Page 4 of 26 Revenue expenditure in the profit and loss account based on the facts and circumstances of the case. The learned Commissioner of Income-tax [Appeals] and the learned 8. assessing officer both failed

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

disallowing a sum of Rs. 2,22,64,350/- being Rehabilitation and Reclamation Expenses claimed by the appellant as ITA Nos.619 to 622/Bang/2025 Page 4 of 26 Revenue expenditure in the profit and loss account based on the facts and circumstances of the case. The learned Commissioner of Income-tax [Appeals] and the learned 8. assessing officer both failed