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

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

disallowance as relatable to SEZ units. 47. Assuming without admitting that the payments made to Infosys Technologies (China) Co Ltd amounting to Rs.262,02,26,125 are liable for TDS u/s 195, as the demand raised under section 201(1)/(1A) in respect of the aforesaid payment has been fully paid in FY 2013-14, the said expenditure should

NADATHUR ESTATES PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(1), BENGALURU

Appeal of the assessee is allowed for statistical purposes

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale

disallowance under section 14A read with rule 8D amounting to Rs. 1,52,32,371 should be fully deleted. 8. Levy of interest under section 234B, 234C and 234D

NADATHUR ESTATES PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(1), BENGALURU

Appeal of the assessee is allowed for statistical purposes

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale

disallowance under section 14A read with rule 8D amounting to Rs. 1,52,32,371 should be fully deleted. 8. Levy of interest under section 234B, 234C and 234D

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

disallowance is deleted. Consequently, ground No.6 of the assessee’s appeal is allowed. 11. Ground No.7 – Charging of interest under section 234B and 234D

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

disallowance is deleted. Consequently, ground No.6 of the assessee’s appeal is allowed. 11. Ground No.7 – Charging of interest under section 234B and 234D

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

disallowance is deleted. Consequently, ground No.6 of the assessee’s appeal is allowed. 11. Ground No.7 – Charging of interest under section 234B and 234D

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

disallowance is deleted. Consequently, ground No.6 of the assessee’s appeal is allowed. 11. Ground No.7 – Charging of interest under section 234B and 234D

M/S ALTISOURCE BUSINESS SOLUTIONS PVT. LTD.,,BANGALORE vs. ACIT, BANGALORE

In the result appeal filed by assessee stands allowed partly as indicated hereinabove

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.208/Bang/2016 Assessment Year : 2011-12

disallowing brought forward business loss and unabsorbed depreciation amounting to INR Rs.1,64,07.586 and INR 47,05,273 respectively which is consequential in nature to the appeal of the appellant for AY 2010-11. 19. Non grant of brought forward MAT credit - INR 2,73,54,274 The learned AO has erred in giving MAT credit of only

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

234D of the Act is consequential in nature. 15. Penalty proceedings under section 271(1)(c) of the Act 15.1. The learned AO erred in law and on the facts and circumstance of the case by initiating penalty proceedings under section 271(1)(c) of the Act for furnishing inaccurate particulars of income and concealment of income. 15.2. The learned

TEJAS NETWORKS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

234D of the Act is consequential in nature. 15. Penalty proceedings under section 271(1)(c) of the Act 15.1. The learned AO erred in law and on the facts and circumstance of the case by initiating penalty proceedings under section 271(1)(c) of the Act for furnishing inaccurate particulars of income and concealment of income. 15.2. The learned

ASST.C.I.T., BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

234D of the Act is consequential in nature. 15. Penalty proceedings under section 271(1)(c) of the Act 15.1. The learned AO erred in law and on the facts and circumstance of the case by initiating penalty proceedings under section 271(1)(c) of the Act for furnishing inaccurate particulars of income and concealment of income. 15.2. The learned

M/S TEJATS NETWORKS LIMITED ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL , BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

234D of the Act is consequential in nature. 15. Penalty proceedings under section 271(1)(c) of the Act 15.1. The learned AO erred in law and on the facts and circumstance of the case by initiating penalty proceedings under section 271(1)(c) of the Act for furnishing inaccurate particulars of income and concealment of income. 15.2. The learned

TEJAS NETWORKS LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

234D of the Act is consequential in nature. 15. Penalty proceedings under section 271(1)(c) of the Act 15.1. The learned AO erred in law and on the facts and circumstance of the case by initiating penalty proceedings under section 271(1)(c) of the Act for furnishing inaccurate particulars of income and concealment of income. 15.2. The learned

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

234D of the Act is consequential in nature. 15. Penalty proceedings under section 271(1)(c) of the Act 15.1. The learned AO erred in law and on the facts and circumstance of the case by initiating penalty proceedings under section 271(1)(c) of the Act for furnishing inaccurate particulars of income and concealment of income. 15.2. The learned

M/S. TEJAS NETWORKS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

234D of the Act is consequential in nature. 15. Penalty proceedings under section 271(1)(c) of the Act 15.1. The learned AO erred in law and on the facts and circumstance of the case by initiating penalty proceedings under section 271(1)(c) of the Act for furnishing inaccurate particulars of income and concealment of income. 15.2. The learned

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

section 234B & 234D of the Income- Tax Act, 1961, on the facts and circumstances of the case. 12. The Appellant craves leave of this Hon'ble Tribunal, to add, alter, modify, delete or substitute any of the grounds urged above. 13. In the view of the above and other grounds that may be urged at the time of the hearing

DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S INFOSYS BPO LTD, BANGALORE

In the result appeal filed by assessee stands partly allowed

Bench: Shri J. Sudhakar Reddy & Smt.Beena Pillai

234D be (viii) deleted. 2. Brief facts of the case are as under: Assessee filed its return of income on 30/10/07 declaring income of Rs.4,85,37,120/-. Return was processed under section 143(1) of the Act, and subsequently statutory notice under section 143 (2) along with questionnaire was issued to assessee. In response to statutory notices, representative

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

234D", "Section 32(1)(iia)", "Section 2(29A)", "Section 147"], "issues": "Whether disallowance under Section 14A is valid without exempt