M/S. AMRUT DISTILLERIES PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals filed by the assessee are treated as allowed for statistical purposes

Bench: Shri. Laxmi Prasad Sahuandshri. Soundararajan K

section 40(a)(ia) was warranted. Copy of the said letter is enclosed as Annexure – 2. The appellant also submitted that material on the basis of which disallowance was proposed under Sec.40A(3) / Sec.40(a)(ia) relating to payments towards transportation charges exceeding the limits specified u/s. 40A(3), was not incriminating material unearthed during the search proceedings and consequently

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

disallowances made by the AO were deleted, and the assessee's claim for exemption under Section 11 was upheld.", "result": "Allowed", "sections": [ "Section 11", "Section 13(8)", "Section 2(15)", "Section 43B", "Section 234A", "Section 234B", "Section 143(3

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

3)/(3A) in computing application of income\nfrom AY 2019-20 onwards. Hence, section 43B does not\napply.\n3.3 Without prejudice, the learned CIT(A) erred in\nconfirming the addition / disallowance under section 43B\nin respect of slum improvement cess of Rs. 20,04,651 not\npaid within the due date under section 139(1).\n3.4 On facts and circumstances

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

disallowance under section 40(a)(i) should be deleted in entirety. Levy of interest under section 234B :- The learned CIT(A) has erred in 12. confirming the action of the learned assessing officer in levying interest under section 234B of the Act. On facts $nd circumstances of the case and law applicable, interest under section 234B is not leviable

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

disallowance under section 40(a)(i) should be deleted in entirety. Levy of interest under section 234B :- The learned CIT(A) has erred in 12. confirming the action of the learned assessing officer in levying interest under section 234B of the Act. On facts $nd circumstances of the case and law applicable, interest under section 234B is not leviable

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

3)", "Section 154", "Section 234B", "Section 234D", "Section 32(1)(iia)", "Section 2(29A)", "Section 147"], "issues": "Whether disallowance under

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

234B is consequential in nature and dependent on the outcome of the assessment which is under appeal. Hence, this ground is also dismissed as infructuous. 4. The issue raised in Ground No. 31 pertains to the initiation of penalty proceedings under section 270A of the Income Tax Act. As this matter is premature at this stage, it is dismissed accordingly

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

disallowance under Section 14A was permissible. The cross objections challenging the reopening of assessment were dismissed.", "result": "Allowed", "sections": [ "Section 14A", "Rule 8D", "Section 132", "Section 148", "Section 153A", "Section 143(3)", "Section 154", "Section 234B

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

234B is consequential in nature. 13. The assessee has filed the additional grounds of appeal at the time of hearing of the appeal with regard to the claim of deduction under section 37(1) of the Act in respect of foreign taxes paid amounting to Rs. 16,67,20,749/- which is not eligible for relief either under section

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

234B of the Act by considering the disallowance under section 80G of the Act amounting to INR 3,01,02,815 vis-a-vis actual

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 under Section 14A was deleted due to the AO's failure to record satisfaction. Brand building expenditure was allowed as revenue expenditure. Foreign tax credit related to Section 10AA income was allowed. The issue of deduction for foreign taxes not eligible for relief under Section 90/91 was remanded.", "result": "Partly Allowed", "sections": [ "10AA

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

3. The learned Commissioner of Income Tax (Appeals) failed to appreciate that the addition made of a sum of Rs. 2,52,18,750/- is not arising out of any incriminating material found during the course of search and consequently the addition made in a proceedings under section 153A of the Act which is not arising out of incriminating material

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

3. The learned Commissioner of Income Tax (Appeals) failed to appreciate that the addition made of a sum of Rs. 2,52,18,750/- is not arising out of any incriminating material found during the course of search and consequently the addition made in a proceedings under section 153A of the Act which is not arising out of incriminating material

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

3. The learned Commissioner of Income Tax (Appeals) failed to appreciate that the addition made of a sum of Rs. 2,52,18,750/- is not arising out of any incriminating material found during the course of search and consequently the addition made in a proceedings under section 153A of the Act which is not arising out of incriminating material

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

disallowance under Section 14A was permissible. The reopening of assessment grounds were dismissed based on a jurisdictional High Court decision. Regarding additional depreciation, the conversion of raw coffee beans to liquid coffee was considered a manufacturing activity, allowing for additional depreciation.", "result": "Allowed/Dismissed", "sections": ["14A", "32(1)(iia)", "143(3)", "147", "148", "153A", "234B

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

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

disallowance of depreciation on goodwill not arising from incriminating material, were not justified. The Tribunal accepted the assessee's contention that the consideration paid in excess of tangible assets was rightly classified as goodwill.", "result": "Partly Allowed", "sections": [ "132", "153A", "143(3)", "250", "32(1)(ii)", "234A", "234B

ARECA TRUST,BANGALORE vs. INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU

In the result, appeal filed by the assessee is dismissed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Areca Trust, The Commissioner Of Income Tax (Appeals), No.23, Nadathur Place, 8Th Main, National Faceless Appeal Centre (Nfac), Jayanagar 3Rd Block, Vs. Delhi. Bengaluru – 560 011. Pan : Aafta 7784 A Appellant Respondent Assessee By : Shri. Sumeet Khurana, Ca Revenue By : Shri. Sunil Kumar Singh, Cit-2(Dr), Itat, Bengaluru. Date Of Hearing : 26.07.2023 Date Of Pronouncement : 26.07.2023

disallowance reiterated in the order under section 143(3) of the Act was unsustainable. 5. On the facts and in the circumstances of the case, thelearned CIT(A) has erred in directing the learned AO to charge interest under section 234B

M/S INFORMATICA BUSINESS SOLUTIONS PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RAGE-3, BANGALORE

In the result appeal filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2014-15

3,20,173 b) The AO disregarded the fact that the said provision was disallowed in the year of creation and again offering the same to tax would tantamount to double taxation. Levy of interest under Section 234B