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 to the extent prejudicial to the\nappellant is bad in law and liable to be quashed.\n2. Assessment order passed is barred by limitation\n2.1. The impugned assessment order passed under section\n143(3) dated 17.2.2020 is barred by limitation in\naccordance with section 153(1) read with clause (iv) of\nExplanation 1 as well

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)", "Section 153(1)", "Section 250", "Section 11(1)(b)", "Section 11(6

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

disallowances made under section 40(a)(i). However, the Ld. CIT(A) without considering the argument forwarded by the assessee proceeded to dismiss the appeal of the assessee without assigning any reasoning. The relevant findings of the ld. CIT-A is reproduced as under: “5.3.3 The facts of the case, assessment order and submissions of the appellant have been considered

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

disallowances made under section 40(a)(i). However, the Ld. CIT(A) without considering the argument forwarded by the assessee proceeded to dismiss the appeal of the assessee without assigning any reasoning. The relevant findings of the ld. CIT-A is reproduced as under: “5.3.3 The facts of the case, assessment order and submissions of the appellant have been considered

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

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

VIJAYKIRAN EDUCATIONALTRUST,BANGALORE KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BANGALORE

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

Bench: Shri Chandra Poojari & Shri Soundararajan K.Assessment Year: 2018-19

250 of the Income Tax Act, 1961 (in short “The Act”). The assessee raised following main grounds: 01. Learned CIT (Appeals) erred in law by disallowing the depreciation on movable assets investment of which is not claimed as application of fund of the trust in the earlier years. Hence depreciation on movable assets

MANOHARS CATERING ,BENGALURU vs. INCOME TAX OFFICER, WARD-7(2)(3), BANGALORE

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

Bench: Mrs. Beena Pillai & Shri Ramit Kocharassessment Year: 2008-09 Manohars Catering, Assistant Commissioner Of Income-Tax & / Or The Partners/ Circle-1, Bangalore Legal Representatives Of (Present Jurisdiction-Income Tax The Partners Of Manohars Officer-Ward7(2)(3), Bangalore) Catering As Stipulated U/S V. 189(1), 189(3) & 189(4) Of The 1961 Act Number 666, Indiranagar 1St Stage Bengaluru-560038 Karnataka Pan:Aalfm1212B (Appellant) (Respondent) Assessee By: Sh. Raghvendra, Ca Revenue By: Ms. Neha Sahay, Jcit Dr Date Of Hearing: 05.09.2024 Date Of Pronouncement: 13.09.2024 O R D E R

250 of the Act wherein ld. CIT(A) dismissed the appeal of the assessee ex- parte in the absence of the assessee for non-prosecution , the appellate proceedings before ld. CIT(A) had arisen from the assessment order dated 24.12.2010 passed by the ld. Assessing Officer under section 143(3) of the Act. 2. The grounds of appeal raised

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, , BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No:Aaajk0398K\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

6) of the Act, the depreciation claimed by the assessee amounting to Rs.65,39,240/- was also disallowed and taxed accordingly. Thus, the AO completed the assessment proceedings on a total income of Rs.51,93,58,124/- while passing order u/s 143(3) r.w.s.144B of the Act dated 26.12.2022.\n\n4. Aggrieved by the aforesaid order of the AO passed

M/S. WINDSOR GARDENS PRIVATE LIMITED,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 7(1)(2), BANGALORE

In the result, appeal of the assessee is allowed

Bench: George George K. & Shri Laxmi Prasad Sahuassessment Year : 2017-18

section. The penalty imposed by the Assessing Officer is confirmed.“ Page 5 of 10 5. Aggrieved from the above order, the assessee filed appeal before the ITAT. 6. The ld.AR reiterated the submissions made before the lower authorities and he submitted that entire investments were made out of own funds and he calculated average investment of Rs.8

MYSORE RACE CLUB LIMITED ,MYSORE vs. ACIT, CIRCLE-2, , MYSORE

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

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

disallowances were made under section 40A(3) and section 40(a)(ia). 2. The appellant being aggrieved filed an appeal before the learned CIT(A) and the order under section 250 of the Act was passed 11.12.2023 dismissing the appeal filed. 3. The appellant submits that it has created multiple mail id’s over a period of time, such

MYSORE RACE CLUB LIMITED,MYSORE vs. ACIT, CIRCLE-2(1), MYSORE

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

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

disallowances were made under section 40A(3) and section 40(a)(ia). 2. The appellant being aggrieved filed an appeal before the learned CIT(A) and the order under section 250 of the Act was passed 11.12.2023 dismissing the appeal filed. 3. The appellant submits that it has created multiple mail id’s over a period of time, such

EVALUATIONZ INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, we do not find any reason to uphold the orders of the learned lower authorities confirming the disallowance of Rs

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2018-19

Disallowance of expenditure of Rs. 36,55,489 under section 69C 2.1. The learned AO and the CIT(A), NFAC have erred in making addition of Rs. 36,55,489 under section 69C in respect of expenditure paid to M/s Techprocode Informat Technology Pvt. Ltd only for the reason that the notice under section 133(6) issued to the said

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

250 of\nthe Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to\n2021-22, which were heard together.\n2.\nFirst, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017-\n18 as the lead case. The assessee, in the memo of appeal, has raised\nfour grounds bearing numbers

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together. 2. First, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017- 18 as the lead case. The assessee, in the memo of appeal, has raised four grounds bearing numbers

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together. 2. First, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017- 18 as the lead case. The assessee, in the memo of appeal, has raised four grounds bearing numbers

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together. 2. First, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017- 18 as the lead case. The assessee, in the memo of appeal, has raised four grounds bearing numbers

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

250 of IT(TP)A No.345/Bang/2021 & M/s. United Breweries Ltd., Bangalore Page 2 of 50 the Act. Certain issues are common in both these appeals, hence, these are clubbed together, heard together and disposed of by this common order for the sake of convenience. 2. Facts of the case in IT(TP)A No.345/Bang/2021 for the assessment year