KARNATAKA POWER CORPORATION LIMITED,BENGALURU vs. ACIT, CIRCLE-4(1)(1), BENGALURU

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

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmed

disallowances made in the order of assessment passed under section 143[3] r.w.s. 144B of the Act dated 30/09/2021, has preferred a statutory appeal before the learned Commissioner of Income-tax [Appeals], NFAC, as per the provisions of section 246A

KARNATAKA POWER CORPORATION LIMITED,BENGALURU vs. ACIT, CIRCLE-4(1)(1), BENGALURU

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

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmed

disallowances made in the order of assessment passed under section 143[3] r.w.s. 144B of the Act dated 30/09/2021, has preferred a statutory appeal before the learned Commissioner of Income-tax [Appeals], NFAC, as per the provisions of section 246A

M/S ITTINA PROPERTIES PVT LTD ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the assessee’s appeal is allowed for statistical purposes

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadalem/S.Ittina Properties Pvt. Ltd. No.1054, 3Rd Block, 7Th Main Koramangala, Bengaluru-560034. Pan: Aaci 3805 Q … Appellant Vs. Deputy Commissioner Of Income-Tax, Circle 3(1)(1), Bengaluru. … Respondent Appellant By : Shri V.Chandrashekar, Advocate. Respondent By : Shri R.N.Siddappaji, Addl.Cit(Dr) Date Of Hearing: 15/05/2019 Date Of Pronouncement: 12/06/2019 O R D E R Per Pavan Kumar Gadale, Jm: The Assessee Has Filed Appeal Against The Order Passed By The Cit(A) Dismissing The Assessee’S Petition For Condonation Of Delay In Filing The Appeal. The Learned Ar Submitted That The Cit(A) Has Erred In Dismissing The Assessee’S Appeal Without Providing Adequate Opportunity & Also Narrated Facts In The Petition For Condonation Of Delay & Prayed That An Opportunity Be Granted To The Assessee To Reiterate The Submissions Made Before Lower Authorities With Page 2 Of 6 Substantive Evidences. Contra, Learned Dr Objected To The Submissions & Prayed That The Delay Is Inordinate & The Cit(A) Was Right In Dismissing The Appeal.

246A of the Act within the stipulated time as envisaged in the provisions of the Act. 5. It is submitted that in the impugned order of assessment passed under section • 143(3) of the Act dated 27/03/2015 the learned assessing officer has made the following additions and disallowance

DINESH KUMAR SINGHI,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2011-12 is partly allowed

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

disallowing already allowed claim of Rs. 85,16,56,168/- and determining the total income at Rs.131,01,19,435/-. The reasons for withdrawal of the section 10B deduction which was already granted has been summarized by the AO in para 6.2 of the assessment order extracted as hereunder: ‘’6.2 The question now arises is whether the assessee Mr.Dinesh Kumar

M/S. GE BE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(2), BANGALORE

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

Bench: Shri Chandra Poojari & Shri George K. George

disallowing this claim in this assessment year 2015-16. As the relief was already granted on this issue in this assessment year 2014-15, accordingly, these grounds are dismissed. 11. Ground No.22 is not pressed and hence this ground of the appeal is dismissed as not pressed. IT(TP)A No.2615/Bang/2019 M/s. GE BE Pvt. Ltd., Bangalore Page

INDIANOIL SKYTANKING PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), BENGALURU

In the result, the appeals are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S

disallowance of interest on hedge swaps. 11. The CIT(A) erred in law and on facts in not appreciating that the interest on hedge swaps was an allowable expenditure under section 36(1)(iii) of the Act 12. The CIT(A) erred in law and on facts in not appreciating that the aviation fuel facility of the Assessee was completed

M/S. INDIANOIL SKYTAKING PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), BANGALORE

In the result, the appeals are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S

disallowance of interest on hedge swaps. 11. The CIT(A) erred in law and on facts in not appreciating that the interest on hedge swaps was an allowable expenditure under section 36(1)(iii) of the Act 12. The CIT(A) erred in law and on facts in not appreciating that the aviation fuel facility of the Assessee was completed

M/S INDIANOIL SKYTANKING PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeals are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S

disallowance of interest on hedge swaps. 11. The CIT(A) erred in law and on facts in not appreciating that the interest on hedge swaps was an allowable expenditure under section 36(1)(iii) of the Act 12. The CIT(A) erred in law and on facts in not appreciating that the aviation fuel facility of the Assessee was completed

SRI. MUTHAIAH SANNASURAYYA ,DAVANGERE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahu

246A of the Act, by filing a condonation petition, narrating the entire facts and circumstances leading for delay in filing the statutory appeals against the impugned order of ITA Nos.785 to 787/Bang/2023 Page 14 of 18 penalty passed, by way of a separate condonation petition along with the appeal memo. [xxxiii]. After obtaining proper professional advice and guidance from

SRI. MUTHAIAH SANNASURAYYA,DAVANGERE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahu

246A of the Act, by filing a condonation petition, narrating the entire facts and circumstances leading for delay in filing the statutory appeals against the impugned order of ITA Nos.785 to 787/Bang/2023 Page 14 of 18 penalty passed, by way of a separate condonation petition along with the appeal memo. [xxxiii]. After obtaining proper professional advice and guidance from

SRI. MUTHAIAH SANNASURAYYA,DAVANGERE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahu

246A of the Act, by filing a condonation petition, narrating the entire facts and circumstances leading for delay in filing the statutory appeals against the impugned order of ITA Nos.785 to 787/Bang/2023 Page 14 of 18 penalty passed, by way of a separate condonation petition along with the appeal memo. [xxxiii]. After obtaining proper professional advice and guidance from

SOCIETE GENERALE GLOBAL SOLUTION CENTRE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2018-19

disallowance of deduction claimed under [section 10AA or under any of the provisions of Chapter VI-A under the heading "C.— Deductions in respect of certain incomes", if] the return is furnished beyond the due date specified under sub-section (1) of section 139; or (vi) addition of income appearing in Form 26AS or Form 16A or Form 16 which

M/S. DESAI AND COMPANY ,HUBBALLI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HUBBALI

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

Bench: Shri George George K & Shri Laxmi Prasad Sahur Assessment Year : 2014-15 M/S. Desai & Company, Vs. Acit, No.1, P.B.Road, Vidyanagar, Circle – 1(1), Hubballi – 560 031. Hubballi. Pan : Aaafd 9759 P Appellant Respondent Assessee By : Shri. Ravishankar, Advocate Revenue By : Shri. V. Parthivel, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 02.07.2024 Date Of Pronouncement : 02.07.2024

disallowance of Rs.14,26,882/- under section 40(a)(ia) of the Act. 4. The learned DR supported the Orders of the AO and the CIT(A). 5. We have heard the rival submissions and perused the material on record. The appeal before the CIT(A) was filed under section 246A

M/S. BANGALORE PHARMACEUTICAL AND RESEARCH LABORATORY PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-1(1)(2), BANGALORE

In the result, the appeal by the assessee is dismissed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2018-19

disallowed. Page 20 of 22 9. Another argument is that the debatable issues could not be subject matter of adjustment u/s 143(1). However, so far as the revenue is concerned, this issue is not debatable for the revenue. The revenue has always maintained a position that the claim is allowable to assessee only when the contribution is deposited

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S TEXAS INSTRUMENTS (INDIA) PVT LTD , BANGALORE

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

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

246A provides for appellate remedy for different types of tax demands raised upon the assessee and there should not be any dispute that the assessees have been filing separate appeals for the demand raised under different sections of the Act. 4.12 In the case of Genpact India P Ltd, the Hon’ble Delhi High Court noticed that the additional

M/S TEXAS INSTRUMENTS (INDIA) PVT LTD ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX LTU , BANGALORE

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

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

246A provides for appellate remedy for different types of tax demands raised upon the assessee and there should not be any dispute that the assessees have been filing separate appeals for the demand raised under different sections of the Act. 4.12 In the case of Genpact India P Ltd, the Hon’ble Delhi High Court noticed that the additional

IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

In the result, the appeal filed by the assessee is allowed

246A or an application for revision under section 264\nshall be admissible against the order of assessment or reassessment, referred to in\nclause (a) of sub-section (1), in a case where an order under sub-section (4) has\nbeen made accepting the application.”\n5.3 Before leaping to section 270A of the Act, we first consider\nsection 270AA

M/S. SRI KANYAKAPARAMESHWARI VIVIDODDESHA SAHAKARA NIYAMITHA,BHADRAVATHI vs. INCOME-TAX OFFICER, WARD-1, SHIVAMOGGA

In the result, appeal filed by the assessee is allowed

Bench: Shri George George Kassessment Year : 2011-12 M/S. Sri Kanyakaparameshwari Vividoddesha Vs. Ito, Sahakara Sangha Niyamita, Ward – 1, Near Basaveshwara Circle, Shivamogga. Vasavi Mahal, Old Town, Bhadravathi – 577 301. Pan : Aaaas 6022 K Appellant Respondent Assessee By : Shri. V. Srinivasan, Advocate Revenue By : Shri. Ganesh R Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 22.11.2023 Date Of Pronouncement : 29.11.2023

disallowed the claim of deduction under section 80P of the Act to the extent of Rs.4,27,472/- by bringing to tax the interest income as ‘Income from Other Sources’, rejecting the assessee’s claim as business income. 4. Aggrieved by the Assessment Order, assessee filed appeal before the CIT(A). The CIT(A), vide order dated 19.07.2017, sustained