H VENKATESH REDDY ,BENGALURU vs. INCOME TAX OFFICER, WARD-4(3)(2), BENGALURU

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Years: 2015-16

disallowance. However, the lower authority levied a penalty for concealment of income in accordance with the provisions of section 271(1

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

In the result, the appeals filed by the assessee for all the four A

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER\nAND\nSHRI SOUNDARARAJAN K. (Judicial Member)

1) of the\nPage 37 of 74\nITA Nos.642 to 645/Bang/2024\nact.\n2\n[2017] 87\nТахтапn.Com 244\n(Karnataka)\nSharavathy\nConductors (P.)\nLtd.\nV.\nChief\nCommissioner\nof\nIncome-Тах,\nBengaluru-2*\nAssesse cited case deals\nwith condonation of delay\nin filing a revised return\nof\nincome\nfor\nthe\n Assessment Year 1997-98\nunder Section

DUSTERS TOTAL SOLUTIONS SERVICES PRIVATE LIMITED ,BANGALORE vs. DCIT, CIRCLE-2(1)(2), BANGALORE

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271, compilation of case law running from pages 1 to 272 and chart explaining the issue involved. 8.1 The learned AR submitted that the provisions of section 80JJAA of the Act are beneficial in nature. The object of the section is to encourage generation of employment. Therefore, the provision has to be interpreted liberally. It should not be interpreted

DUSTERS TOTAL SOLUTIONS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-2(1)(1), BANGALORE

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271, compilation of case law running from pages 1 to 272 and chart explaining the issue involved. 8.1 The learned AR submitted that the provisions of section 80JJAA of the Act are beneficial in nature. The object of the section is to encourage generation of employment. Therefore, the provision has to be interpreted liberally. It should not be interpreted

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

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

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

271/- and for the current year the claim is allowed to the extent of Rs.48,85,56,317/-. The claim of assessee u/s. 36(1)(vii) for the current year after write off pertaining to rural branches is at Rs.413,94,00,446/-. Since the available provision exceeds the claim, the entire claim of deduction u/s. 36(1)(viia

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, LTU, CIRCLE-2, BANGALORE

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

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

271/- and for the current year the claim is allowed to the extent of Rs.48,85,56,317/-. The claim of assessee u/s. 36(1)(vii) for the current year after write off pertaining to rural branches is at Rs.413,94,00,446/-. Since the available provision exceeds the claim, the entire claim of deduction u/s. 36(1)(viia

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

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

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

271/- and for the current year the claim is allowed to the extent of Rs.48,85,56,317/-. The claim of assessee u/s. 36(1)(vii) for the current year after write off pertaining to rural branches is at Rs.413,94,00,446/-. Since the available provision exceeds the claim, the entire claim of deduction u/s. 36(1)(viia

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

271 C, and, section 40(a)(ia) does not add to the same. The provisions of Section 40(a)(ia), as they existed prior to insertion of second proviso thereto, went much beyond the obvious intentions of the lawmakers and created undue hardships even in cases in which the assessee's tax withholding lapses did not result in any loss

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

In the result, the appeal filed by the Revenue is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

disallowance has formed the basis of imposition of penalty in the case of the person for the same or any other assessment year. (12)The penalty referred to in sub-section (1) shall be imposed, by an order in writing, by the Assessing Officer, the Commissioner (Appeals), the Commissioner or the Principal Commissioner, as the case may be. Dcit

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

1) of the\nPage 37 of 74\nITA Nos. 642 to 645/Bang/2024\n2\n[2017] 87\nТахтапn.Com 244\n(Karnataka)\nact.\nSharavathy\nConductors (P.)\nLtd.\nV.\nChief\nCommissioner\nof\nIncome-Tax,\nBengaluru-2*\nAssesse cited case deals\nwith condonation of delay\nin filing a revised return\nof\nincome\nfor\nthe\n Assessment Year 1997-98\nunder Section

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3),, BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowances. Penalty proceedings were initiated mechanically, despite the fact that the assessment was completed by accepting the returned income. 6.2 Further, the assessee submitted that penalty under section 271(1

RAGHURAM ENTERPRISES ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowances. Penalty proceedings were initiated mechanically, despite the fact that the assessment was completed by accepting the returned income. 6.2 Further, the assessee submitted that penalty under section 271(1

RAGHURAM ENTERPRISES ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowances. Penalty proceedings were initiated mechanically, despite the fact that the assessment was completed by accepting the returned income. 6.2 Further, the assessee submitted that penalty under section 271(1

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowances. Penalty proceedings were initiated mechanically, despite the fact that the assessment was completed by accepting the returned income. 6.2 Further, the assessee submitted that penalty under section 271(1

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowances. Penalty proceedings were initiated mechanically, despite the fact that the assessment was completed by accepting the returned income. 6.2 Further, the assessee submitted that penalty under section 271(1

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowances. Penalty proceedings were initiated mechanically, despite the fact that the assessment was completed by accepting the returned income. 6.2 Further, the assessee submitted that penalty under section 271(1

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

1) of the\n\nPage 34 of 74\nITA Nos.642 to 645/Bang/2024\nact.\n\nAssesse cited case deals\nwith condonation of delay\nin filing a revised return\nincome\nfor\nthe\n Assessment Year 1997-98\nunder Section 119(2)(b) of\nthe Income" Tax Act, 1961.\n\n2\n[2017] 87\nTaxmann.Com 244\n(Karnataka)\nSharavathy\nConductors (P.)\nLtd