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.

253 of the Act\n\nPage 22 of 34\n\nand accordingly we inclined to condone the delay and admit the appeal for\nadjudication on merits.\n\n16. The Ground No 1 is general in nature and does not require any\nadjudication.\n\n16.1 The Ground No 2 deals with disallowance under section

M/S KBD SUGARS & DISTILLERIES LTD,BANGALORE vs. ASST. COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, the appeal of assessee is partly allowed and the revenue’s appeal is dismissed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

disallowance on account of interest expenditure under Section 14A in the earlier assessment year. Further, the Tribunal for the Assessment Years 2006-07 & 07-08, while deciding the issue of interest free loans advanced to the related parties have given the finding that the assessee was having sufficient interest free funds. We further find that during the year under consideration

HEWLETT PAKCARD INDIA SALES PRIVATE LIMITED,BANGALORE vs. JCIT, BANGALORE

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

253 12 Disallowance of other provisions 3,99,95,033 13 Expenditure debited under the head cost of 84,98,42,348 goods sold 14 Outside contract service 36,14,59,731 15 Date of approval and disallowed under 28,31,39,077 section

JCIT, BANGALORE vs. M/S HEWLETT PACKARD INDIA SALES P. LTD.,, BANGALORE

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

253 12 Disallowance of other provisions 3,99,95,033 13 Expenditure debited under the head cost of 84,98,42,348 goods sold 14 Outside contract service 36,14,59,731 15 Date of approval and disallowed under 28,31,39,077 section

M/S BOSCH LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE-1 , BANGALORE

In the result, appeal of the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2013-14 Bosch Limited, Vs. The Assistant Commissioner Hosur Road, Adugodi, Of Income Tax, Ltu, Bangalore – 560 030. Circle 1, Pan: Aaacm 9840P Bangalore. Appellant Respondent Appellant By : Shri Percy Pardiwala, Advocate Respondent By : Shri V S Chakrapani, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 01.09.2022 Date Of Pronouncement : 13.09.2022 O R D E R Per Padmavathy S.2. This Appeal Is Against The Order Of The Cit(Appeals), Bangalore-9, Bangalore Dated 31.3.2018 For The Assessment Year 2013- 14. 3. The Assessee Raised Grounds Pertaining To The Following Issues:- Deduction U/S. 35(2Ab) Computed On Net Expenditure As Opposed To Gross Expenditure Disallowance Of Provision For Bad & Doubtful Debts I) Disallowance Of Provision For Long Term Service Award Disallowance Of Expenditure U/S. 14A Of The Act Ii) Page 2 Of 67

sections 115, 44AC, etc. (iii) The reliance on the decision of Hon'ble Apex Court in the case of Woodward Governor India (P.) Ltd. ( supra) is misplaced since that case concerns allowance of losses on re-statement of existing currency assets and liabilities. In the case on hand, it relates only to future sales transactions without certainty of valuation

DCIT, BANGALORE vs. M/S JUPITER CAPITAL PVT. LTD.,, BANGALORE

Accordingly, appeal of the Revenue as well as the assessee are dismissed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

section 14A is as follows: “5.6 This amount of Rs.42,75,757/- is held as attracted for disallowance u/ s. 14A read with Rule 8D of the Income Tax Act. However, the assessee has already made a disallowance u/s.14A of Rs.8,28,302/-, the balance amount of Rs.34,47,455/- is added to the Income returned by the assessee

JUPITER CAPITAL P. LTD.,,BANGALORE vs. CIT, BANGALORE

Accordingly, appeal of the Revenue as well as the assessee are dismissed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

section 14A is as follows: “5.6 This amount of Rs.42,75,757/- is held as attracted for disallowance u/ s. 14A read with Rule 8D of the Income Tax Act. However, the assessee has already made a disallowance u/s.14A of Rs.8,28,302/-, the balance amount of Rs.34,47,455/- is added to the Income returned by the assessee

DCIT, BANGALORE vs. M/S JUPITER CAPITAL PVT. LTD.,, BANGALORE

Accordingly, appeal of the Revenue as well as the assessee are dismissed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

section 14A is as follows: “5.6 This amount of Rs.42,75,757/- is held as attracted for disallowance u/ s. 14A read with Rule 8D of the Income Tax Act. However, the assessee has already made a disallowance u/s.14A of Rs.8,28,302/-, the balance amount of Rs.34,47,455/- is added to the Income returned by the assessee

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

Section 14A rwr 8D. The disallowance is made after examining all the issues and relying upon the decision of the Bombay High court in the case of Godrej and Boyce 328 ITR. 9. The decision of the Hon'ble High Court of Karnataka in assessee's own case for AY 2001-02 has not been accepted by the department

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

Section 14A rwr 8D. The disallowance is made after examining all the issues and relying upon the decision of the Bombay High court in the case of Godrej and Boyce 328 ITR. 9. The decision of the Hon'ble High Court of Karnataka in assessee's own case for AY 2001-02 has not been accepted by the department

M/S. AMPAR CO-OPERATIVE AGRICULTURE SOCIETY LIMITED,UDUPI vs. INCOME-TAX OFFICER, WARD-1, UDUPI

In the result, the appeals of the Assessee for AY 2013-14 & 2014-15 are allowed while the appeal for AY 2015-16 is partly allowed

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

disallowed by the ld. AO in the assessment order passed u/s 143(3) of the Act: Particulars Amount (Rs.) NPA 12,00,000 Employee Retirement Benefit 6,00,000 Employee Leave encashment 9,70,000 Total 27,70,000 3.5 The assessee contended that the above expenses are to be debited to the Profit & Loss account in conformity with

M/S. AMPAR CO-OPERATIVE AGRICULTURE SOCIETY LIMITED,UDUPI vs. INCOME-TAX OFFICER, WARD-1, UDUPI

In the result, the appeals of the Assessee for AY 2013-14 & 2014-15 are allowed while the appeal for AY 2015-16 is partly allowed

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

disallowed by the ld. AO in the assessment order passed u/s 143(3) of the Act: Particulars Amount (Rs.) NPA 12,00,000 Employee Retirement Benefit 6,00,000 Employee Leave encashment 9,70,000 Total 27,70,000 3.5 The assessee contended that the above expenses are to be debited to the Profit & Loss account in conformity with

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

disallowance amount of Rs. 52,08,24,535/-, which has resulted in short computation of income to the tune of Rs. 8,03,98,978/- resulting in a short levy of tax, Rs. 2,80,94,618/- and interest under section 234B of Rs. 84,28,386/- aggregating to Rs. 3,65,23,004/-• 9. The Petitioner / Appellant being aggrieved

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

disallowance amount of Rs. 52,08,24,535/-, which has resulted in short computation of income to the tune of Rs. 8,03,98,978/- resulting in a short levy of tax, Rs. 2,80,94,618/- and interest under section 234B of Rs. 84,28,386/- aggregating to Rs. 3,65,23,004/-• 9. The Petitioner / Appellant being aggrieved

YOKOGAWA INDIA LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, the appeal is allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

253 of the Income- tax Act, 1961 ("Act") against the order passed on 28.01 .2016 under Section 143 (3) read with Section 144 C of the Income Tax Act, 1961, by Deputy Commissioner of Income-tax, Large Taxpayers Unit, Circle - 1, Bangalore ("AO") (hereinafter referred to as the Impugned Order) in pursuance of the directions issued by Dispute Resolution Panel

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1), MANGALURU, MANGALURU vs. KARNATAKA BANK LTD., MANGALURU

In the result, the appeal of the revenue for AYs 2016-17 and\n2017-18 are partly allowed for statistical purposes

253 (Karnataka) in which it has been held as\nunder:-\n\"The instant case is concerned with the assessment for the\n assessment years 2003-04 and 2004-05. The first day of the\nprevious year for these assessment years would be 1-4-2002 and 1-\n4-2003. For the purpose of computing the deduction under section\n36(viia

M/S. CHITRADURGA NIRMITHI KENDRA,CHITRADURGA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), DAVANGERE

In the result, appeal of the assessee is dismissed

disallowed an expenditure of Rs. 1,34,80,381/- under section 40(a)(ia) of the Income Tax Act, 1961. However, the counsel for the assessee did not press this ground before the CIT(A), leading to the dismissal of the appeal.", "held": "The Tribunal held that the assessee failed to establish a \"sufficient cause\" for the inordinate delay

M/S UNBXD SOFTWARE PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result appeal filed by assessee stands allowed for statistical purposes

Bench: Shri B.R Baskaran & Smt. Beena Pillaiassessment Year : 2015-16

Section 253 of the Income-tax Act, 1961 (Act") against the Order passed by the Commissioner of Income- tax (Appeals) —7, Bangalore [learned CIT(A)"] dated 06 July 2018 (received by the Appellant on 11 July 2018), on the following grounds: 1. Ground 1: General Page 2 of 12 1.1 The impugned order of the learned CIT(A) is based