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

5. Levy of interest under section 234B: 5.1. The levy of interest under section 234B is bad in law and liable to be quashed. 6. Prayer: 6.1. Based on the above grounds and other grounds adduced at the time of hearing, the appellant prays that the order passed under section 250 to the ITA No.245/Bang/2024 Infosys Limited Page

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.

5 years from the date of its installation in\nterms of subsection 2 of section 32AC of the Act. The assessee had acquired\nand installed the certain new assets during AY 2014-15, AY 2015-16, AY\n2016-17 & AY_2017-18 and claimed the deduction u/s 32AC in the\nrespective years. Out of the new assets acquired and installed

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

250 under section 14A of the Äct by mechanically applying Rule 8D when there is no basis to reject the Appellant's claim that no expenditure was incurred for earning exempt income. IT(TP)A No.298/Bang/2024 Goldman Sachs Services Pvt. Ltd., Bangalore Page 7 of 14 2.3 The Honorable DRP and the Learned AO have erred

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

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2013-14

250 in the manner passed by him. The order so passed to the extent prejudicial to the appellant is bad in law and liable to be quashed. Infosys Limited Page 2 of 20 2. Ground relating to disallowance of deduction under section 10AA: 2.1. The learned Deputy Commissioner of Income Tax, Circle 3(1)(1), Bengaluru

BHARAT ELECTRONICS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, LARGE PAYERS TAX UNIT, CIRCLE-1, BANGALORE

In the result, appeal of the assessee is partly allowed

250 of\nthe Income Tax Act, 1961 (in short “The Act”). The assessee has\nraised following grounds of appeal:\ni.\nThe order of the Ld. CIT (A) is opposed to the law, facts, and circumstances of\nthe case.\nii.\nThe order is passed against the principle of natural justice and thus, liable to\nbe quashed.\niii.\nThe learned

THE UNITED THEOLOGICAL COLLEGE,BANGALORE vs. INCOME-TAX OFFICER, (EXEMPTIONS), WARD-2, BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

250 of the Act. 4.2 The ld. A.R. submitted that the learned Assessing officer failed to appreciate that consent cannot confer jurisdiction and even though the assessee’s authorized representative had agreed for the disallowance the disallowance ought to have been made after considering the validity to assume jurisdiction under section 147 of the Act and considering whether the entire

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

5-P(LXX-6) of 1968 dated 19/06/1968 issued by the\nCBDT, the income as disclosed in the accounts plus its other income\ncomputed will be the income of the trust for the purpose of section 11(1).\nTherefore, the Ld.AR submitted that the addition of service charges could\nnot be made based on the above said circular. Alternatively

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

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

250 in the manner passed by him. The order so passed to the extent prejudicial to the appellant is bad in law and liable to be quashed. 2. Disallowance of deduction under section 32AC:- Page 2 of 18 2.1. The learned CIT(A) has erred in not allowing the claim of deduction under section 32AC of the Act amounting

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

250 of the Act by the learned CIT(A),\nNFAC to the extent prejudicial to the appellant be quashed\nor in the alternative the above grounds and the relief\nprayed thereunder be allowed.\nThe Appellant submits that each of the above grounds/\nsub-grounds are independent and without prejudice to one\nanother.\nThe Appellant craves leave to add, alter, vary

M/S. ARHAM MITRA MANDAL,BANGALORE vs. INCOME-TAX OFFICER(EXEMPTIONS)-WARD-1, BANGALORE

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

disallowing the claim of\nexemption under section 11 while processing the return under section\n143(1) of the Act without appreciating that the adjustments u/s 143(1) are\nonly restricted to arithmetical errors and incorrect claims and there is\nno power to deny exemption u/s 11 for delay in filing audit report while\nprocessing return

PRIMARY AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED NIDLE,BELTHANGADY vs. INCOME-TAX OFFICER, WARD-1, PUTTUR

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

250 of the Act is opposed to law, equity, weight of evidence, probabilities and the facts and circumstances in the Appellant's case. 2. The Appellant denies to be assessed to tax on total income as determined by the learned AO of Rs. 86,31,770/- as against the total income reported by the Appellant

M/S. PEAK XV PARTNERS ADVISORS PRIVATE LIMITED, ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

In the result, both the appeals of the assessee are allowed

5 to 42 of the paper book.\nHowever, it is to be noted that the assessee company had\nvoluntarily disallowed the entire donations/contributions paid\ntowards Corporate Social Responsibility (CSR) activities u/s 37 of\nthe Act while computing the income from business & profession.\n2.1 The ld. AO however was of the view that the CSR expenditure\ncannot be allowed

M/S. PEAK XV PARTNERS ADVISORS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

In the result appeal filed by assessee stands allowed

disallowance under Section 37 is for computing business income, while Section 80G deduction is for computing total taxable income.", "result": "Allowed", "sections": [ "80G", "37(1)", "250", "143(2)", "142(1)", "135", "234A", "234C", "30", "31", "32", "33", "34", "35", "35CCD", "36", "80G(1)(i)", "80G(2)", "80G(5

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

250 of the Act by the learned CIT(A), NFAC to the extent prejudicial to the appellant be quashed or in the alternative the addition of Rs.1,09,55,534/- made under section 10AA and consequential levy of tax including interest thereon be deleted. The Appellant submits that each of the above grounds / sub-grounds are independent and without prejudice

SRI. KALABHAIRAWESHWARA MULTI-PURPOSE CO-OP SOCIETY LTD., ,CHIKKAMAGALURU vs. INCOME TAX OFFICER, WARD-1, , CHIKKAMAGALURU

In the result, appeal filed by the assessee is dismissed

Bench: Shri George George K & Ms. Padmavathi. Sr Assessment Year : 2018-19 Sri Kalabhairaveshwara Multi-Purpose Co- Vs. Ito, Operative Society Ltd., Ward Officer, K. M. Road,Chikmagalur District Office Ward – 1, S. O. 577 101, Karnataka. Chikmagaluru. Pan : Aapas 3058 L Appellant Respondent Assessee By : Shri. Mahesh R. Uppin, Advocate Revenue By : Ms. Neha Sahay, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 16.10.2024 Date Of Pronouncement : 17.10.2024

250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2018-19. 2. Brief facts of the case are as follows: Assessee is a co-operative society registered under the Karnataka Co- operative Societies Act, 1959. For the Assessment Year 2018-19, assessee did not file any return of income. Information was available with

M/S. SLK SOFTWARE PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, SPECIAL RANGE-6, BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

5 of 17 of Rs.89,23,485/-. The said clause has been amended to state that the disallowance shall be @ 1 percent of average of average monthly investments. The appellant vide its reply dated 04.02.2021 has furnished the calculation of disallowance under section 14A read with the amended Rule 8D(2) which is reproduced here under: The calculation of monthly

M/S. SLK SOFTWARE PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, SPECIAL RANGE-6N, BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

5 of 17 of Rs.89,23,485/-. The said clause has been amended to state that the disallowance shall be @ 1 percent of average of average monthly investments. The appellant vide its reply dated 04.02.2021 has furnished the calculation of disallowance under section 14A read with the amended Rule 8D(2) which is reproduced here under: The calculation of monthly

INCOME TAX OFFICER,WARD-1, HOSPET vs. GAYATRI PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA, HOSPET, HOSPET

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

250 of the Income Tax Act, 1961 (in short “the Act”) for the assessment year 2017-18.\n\n2. The Revenue has raised the following grounds of appeal:\n\na) \"On facts and circumstances of the case and in law, the Learned CIT(A)/(NFAC) has erred in deleting the disallowance u/s.80P