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

253 of the Act ITA No.245/Bang/2024 Infosys Limited Page 22 of 34 and accordingly we inclined to condone the delay and admit the appeal for adjudication on merits. 16. The Ground No 1 is general in nature and does not require any adjudication. 16.1 The Ground No 2 deals with disallowance under section

INCOME TAX OFFICER, WARD-7(2)(1), BENGALURU, BANGALORE vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED , BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowed the deduction u/s 80P(2)(d) of the Act. It is submitted that the investments were made out of surplus funds and relied on the decision of Hon’ble Karnataka High Court in the decision of PCIT v. Totagars Co-operative Sale Society 392 ITR 74 wherein it was held that the interest earned on deposits

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

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

disallowing the claim of exemption claimed under section 10(38) of the Act with respect to the capital gains on the long term equity shares and have failed to take cognizance of the DEMAT statement, contract notes, etc submitted during the course of assessment proceedings on the facts and circumstances. ii. The authorities below have erred in treating the long

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

2. Disallowance u/s 14A: ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 4 of 46 The CIT(A) has erroneously allowed relief on the ground that the AO failed to record non-satisfaction with regard to the correctness of the claim of the assessee, as envisaged under the provisions of section 14A has not been recorded by the AO before proceeding to make

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

2. Disallowance u/s 14A: ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 4 of 46 The CIT(A) has erroneously allowed relief on the ground that the AO failed to record non-satisfaction with regard to the correctness of the claim of the assessee, as envisaged under the provisions of section 14A has not been recorded by the AO before proceeding to make

KARNATAKA BANK LTD,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, MANGALORE

Appeals of the revenue are partly allowed for statistical purposes

253 (Karnataka) in which it has been held as under:-\n\n\"The instant case is concerned with the assessment for the assessment years 2003-04 and 2004-05. The first day of the previous year for these assessment years would be 1-4-2002 and 1-4-2003. For the purpose of computing the deduction under section 36(viia

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

2,25,13,253 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

2,25,13,253 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

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

In the result, the appeals filed by the assessee is allowed with the above directions

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance. With respect to depreciation allowance, the issue was partly ITA Nos.1283/Bang/2016 & 169 to 171/Bang/2025 Page 10 of 22 allowed. Accordingly, the Appellate Order was passed on 28.04.2016. 12. The ld. AR, Shri Padamchand Khincha, CA, submitted that the issue is covered by the decision of Hon’ble Supreme Court in the case of Ahmedabad Urban Development Authority in Civil

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

In the result, the appeals filed by the assessee is allowed with the above directions

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance. With respect to depreciation allowance, the issue was partly ITA Nos.1283/Bang/2016 & 169 to 171/Bang/2025 Page 10 of 22 allowed. Accordingly, the Appellate Order was passed on 28.04.2016. 12. The ld. AR, Shri Padamchand Khincha, CA, submitted that the issue is covered by the decision of Hon’ble Supreme Court in the case of Ahmedabad Urban Development Authority in Civil

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

disallowed the balance amount of Rs.88,24,01,309 as\nunder:-\nParticulars\n01\n10% of average aggregate advances made during the year\nby rural branches being Rs.421.49 crores(Rs.607.89 crores\nRs.186.40 crores; excluding advances pertaining to branches\nsituated in Semi-Urban branches and Urban\nagglomeration and after considering the amount of\nadvances sanctioned by rural branch during the year\nincremental

M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

section 36(1)(vii) of the Act vide Finance Act 2013. 6. There is no scope in IT Act to allow the provision of non rural branches advances u/s 36(1)(vii) of the IT Act and in the present case it was not bad debt write off of non rural branches. The assessee bank has made false submission

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

section 36(1)(vii) of the Act vide Finance Act 2013. 6. There is no scope in IT Act to allow the provision of non rural branches advances u/s 36(1)(vii) of the IT Act and in the present case it was not bad debt write off of non rural branches. The assessee bank has made false submission

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

Appeals of the revenue are partly allowed for\nstatistical 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

KARNATAKA HOUSING BOARD ,BANGALORE vs. DCIT, EXEMPTIONS CIRLCE-1 , BENGALURU

In the result, the appeals filed by the assessee is allowed with\nthe above directions

disallowance.\nWith respect to depreciation allowance, the issue was partly\nallowed. Accordingly, the Appellate Order was passed on\n28.04.2016.\n\n12. The ld. AR, Shri Padamchand Khincha, CA, submitted that the\nissue is covered by the decision of Hon'ble Supreme Court in\nthe case of Ahmedabad Urban Development Authority in Civil\nAppeal No21762 of 2017 dated 03.11.2022. He submits

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by the assessee is allowed with\nthe above directions

disallowance.\nWith respect to depreciation allowance, the issue was partly\nallowed. Accordingly, the Appellate Order was passed on\n28.04.2016.\n12. The ld. AR, Shri Padamchand Khincha, CA, submitted that the\nissue is covered by the decision of Hon'ble Supreme Court in\nthe case of Ahmedabad Urban Development Authority in Civil\nAppeal No21762 of 2017 dated 03.11.2022. He submits that

KARNATAKA BANK LTD,MANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, MANGALORE

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

disallowed the balance amount of Rs.88,24,01,309 as\nunder:-\nParticulars\n01\n10% of average aggregate advances made during the year\nby rural branches being Rs.421.49 crores(Rs.607.89 crores\nRs.186.40 crores; excluding advances pertaining to branches\nsituated in Semi-Urban branches and Urban\nagglomeration and after considering the amount of\nadvances sanctioned by rural branch during the year\nincremental