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

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

M/S INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED ,MANGALURU vs. ASSISTANT COMMISIONER OF INCOME TAX, CIRCLE - 2(1) , MANGALURU

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Soundararajan K.\Nita Nos.642 To 645/Bang/2024\N Assessment Years : 2017-18 To\N2020-21\Nm/S. Bharat Beedi Works\Nprivate Limited,\Ngolden Jubilee Building,\Nbharath Bagh,\Nkadri Road,\Nmangaluru – 575 002.\Npan: Aaacb9001B\Nappellant\Nassessee By\Nrevenue By\N: Shri Chythanya .K, Sr.\Nadvocate\N: Shri E. Shridhar, Cit-Dr\Ndate Of Hearing\Ndate Of Pronouncement\Norder\Nper Bench\Nthese Are The Appeals Filed By The Assessee Challenging The Orders Of\Nthe Ld.Cit(A) -2, Panaji Dated 30/01/2024 In Respect Of The A.Ys.2017-18,\N2018-19, 2019-20 & 2020-21. The Grounds Raised By The Assessee For\Neach Of The Assessment Years Are Extracted Hereunder For The Sack Of\Nconvenience.\Npage 2 Of 74\Nita Nos.642 To 645/Bang/2024\N Assessment Year 2017-18:\N“1. The Impugned Orders Of The Lower Authorities Are Not\Njustified In Law & On The Facts & Circumstances Of The\Ncase.\N2. The Impugned Assessment Proceedings & The\Nimpugned Assessment Order Under Section 143(3) Dated\N29.11.2021 Are Bad & Non-Est Since The Notice Under\Nsection 143(2) Dated 13.08.2018 Was Issued Without\Naffixing Any Signature Either Manually Or Digitally.\N3. Without Prejudice To The Above, Impugned Assessment\Nproceedings & The Impugned Assessment Order Under\Nsection 143(3) Dated 29.11.2021 Are Bad & Non-Est\Nbeing Based On The Notice Under Section 143(2) Dated\N13.08.2018 Which Is Vague, Without Of Application Of Mind\Nand Contrary To Section 143(2) & Applicable Board\Ncirculars & Instructions.\N4. As Regards Disallowance Under Section 14A U/S Rule\N8D(2)(Ii):\N4.

Section 132(4).\nPage 26 of 74\nITA Nos.642 to 645/Bang/2024\n16. 8. The Learned AO erred in making the impugned\naddition merely on the basis of statements extracted from\nthe Appellant during search proceedings under coercion,\nwhen the same were retracted by the Appellant vide\nletters dated 06.01.2021 (the copy of same was also filed\nbefore Learned Ad.CIT

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

section 14A rws 8D. Accordingly the Ground No 2 as raised by the Revenue is dismissed. 17. The Ground No 3 deals with disallowance of brand building expenditure which was deleted by the ld. CIT(A)/NFAC. The brief facts in this regard are as under- During the year under consideration, the assessee incurred expenditure

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, all the appeals filed by the assessee are allowed

26 of 74\nITA Nos.642 to 645/Bang/2024\n18. 10. The Lower Authorities have failed to appreciate\nthat no disallowance under Section

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

section 35 or 35CCC or 35CCD\nExcess additional deduction claim u/s 35(2AB) now disallowed (B) – (C)\n--Rs.905,26

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section 201(1) of IT(TP)A No.2846/Bang/2017 M/s. Dell International Services India Pvt. Ltd., Bangalore Page 26 of 47 the Act as the Assessee had made a suo moto disallowance

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.

section 14A rws 8D. Accordingly the Ground No 2 as raised by the\nRevenue is dismissed.\n\n17. The Ground No 3 deals with disallowance of brand building\nexpenditure which was deleted by the 1d. CIT(A)/NFAC. The brief facts in\nthis regard are as under-\n\nDuring the year under consideration, the assessee incurred expenditure of\nRs.261

TEXO THE BUILDERS ,UDUPI vs. ACIT, CENTRAL CIRCLE-2, MANGALORE

In the result, we dismiss grounds raised by the assessee

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

26,000 19,87,857 ITA Nos.1199, 1200/Bang/2025 Page 14 of 28 (vi) Contract from receipts from Shanti 1,21,17,822 Sadana (vii) Cash payment disallowance u/s 40A(3) of the Act Total Income assessed as per assessment order 1,65,00,980 u/s 147 3.4. The appellant aggrieved by the above addition and disallowance preferred an appeal before

TEXO THE BUILDERS,UDUPI vs. ACIT, CENTRAL CIRCLE-2, MANGALORE

In the result, we dismiss grounds raised by the assessee

26,000\n1,21,17,822\n\nTotal Income assessed as per assessment order\nu/s 147\n1,65,00,980\n\n3.4.\nThe appellant aggrieved by the above addition and disallowance\npreferred an appeal before learned Commissioner of Income Tax\n(Appeals). During the course of the appeal proceedings the appellant\nsubmitted all the relevant details to substantiate the genuineness

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

Section 36(1)(iii) of the 1961 Act as argued on behalf of the assessee? ITA Nos.1073 to 1075/Bang/2022 Century Sheltors, Bangalore & ITA Nos.1100 to 1102/Bang/2022 Century Silicon City, Bangalore Page 12 of 26 Legal Position Explained 14. Before enactment of FA 1992, broadly speaking, payment of interest by the firm to any partner of the firm constituted Business Disallowance

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

Section 36(1)(iii) of the 1961 Act as argued on behalf of the assessee? ITA Nos.1073 to 1075/Bang/2022 Century Sheltors, Bangalore & ITA Nos.1100 to 1102/Bang/2022 Century Silicon City, Bangalore Page 12 of 26 Legal Position Explained 14. Before enactment of FA 1992, broadly speaking, payment of interest by the firm to any partner of the firm constituted Business Disallowance

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

Section 36(1)(iii) of the 1961 Act as argued on behalf of the assessee? ITA Nos.1073 to 1075/Bang/2022 Century Sheltors, Bangalore & ITA Nos.1100 to 1102/Bang/2022 Century Silicon City, Bangalore Page 12 of 26 Legal Position Explained 14. Before enactment of FA 1992, broadly speaking, payment of interest by the firm to any partner of the firm constituted Business Disallowance

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

Section 36(1)(iii) of the 1961 Act as argued on behalf of the assessee? ITA Nos.1073 to 1075/Bang/2022 Century Sheltors, Bangalore & ITA Nos.1100 to 1102/Bang/2022 Century Silicon City, Bangalore Page 12 of 26 Legal Position Explained 14. Before enactment of FA 1992, broadly speaking, payment of interest by the firm to any partner of the firm constituted Business Disallowance

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

Section 36(1)(iii) of the 1961 Act as argued on behalf of the assessee? ITA Nos.1073 to 1075/Bang/2022 Century Sheltors, Bangalore & ITA Nos.1100 to 1102/Bang/2022 Century Silicon City, Bangalore Page 12 of 26 Legal Position Explained 14. Before enactment of FA 1992, broadly speaking, payment of interest by the firm to any partner of the firm constituted Business Disallowance

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

Section 36(1)(iii) of the 1961 Act as argued on behalf of the assessee? ITA Nos.1073 to 1075/Bang/2022 Century Sheltors, Bangalore & ITA Nos.1100 to 1102/Bang/2022 Century Silicon City, Bangalore Page 12 of 26 Legal Position Explained 14. Before enactment of FA 1992, broadly speaking, payment of interest by the firm to any partner of the firm constituted Business Disallowance

DEPUTY COMMISSIONER OF INCOME TAX, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowance under section 14A of the Act, claim under section 80IA of the Act of Rs.11,51,71,466/- and addition of interest of Rs.71,26

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

In the result, the appeal of the Revenue on this for the Assessment Years

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

disallowance under section 14A of the Act, claim under section 80IA of the Act of Rs.11,51,71,466/- and addition of interest of Rs.71,26