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 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)/(1A) having regards to the scheme of the Act and various decisions by Hon’ble Karnataka High Court as well as various decisions of coordinate bench. We have reproduced the findings of the Ld.CIT(A) in the preceding paragraphs. And the same stands upheld based on the discussions herein above. 12. We therefore, are of the view

DELL INDIA P LTD,BANGALORE vs. INCOME TAX OFFICER(TDS), LTU, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 201 for a default that is not been committed by assessee. We confer with the view taken by the Ld.CIT(A) for assessment year 2013-14 to be applied for all the assessment years under consideration. 13. On the issue of applicability of TDS provisions on the commission and Rebate payment by assessee, we note that the relevant observations

DELL INTERNATIONAL SERVICES INDIA PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 201 for a default that is not been committed by assessee. We confer with the view taken by the Ld.CIT(A) for assessment year 2013-14 to be applied for all the assessment years under consideration. 13. On the issue of applicability of TDS provisions on the commission and Rebate payment by assessee, we note that the relevant observations

INCOME TAX OFFICER, BANGALORE vs. M/S.DELL INDIA PVT.LTD.,, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 201 for a default that is not been committed by assessee. We confer with the view taken by the Ld.CIT(A) for assessment year 2013-14 to be applied for all the assessment years under consideration. 13. On the issue of applicability of TDS provisions on the commission and Rebate payment by assessee, we note that the relevant observations

SRI. SINGONAHALLI CHIKKAREVANNA GANGADHARAIAH,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(1), BENGALURU

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

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

293 ITR 226 (SC) where the same view was taken. We 14 Sri.Singonahalli Chikkarevanna Gangadharaiah. find that the aforesaid settled position in law has also been legislatively recognized by insertion of a proviso in sub-section (1) of section 201 of the Act by the Finance Act, 2012. Thus, the settled position in law is that if the deductee/payee

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK ,BENGALURU vs. INCOME-TAX OFFICE, WARD-5(2)(1), BENGALURU

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

293(1) of the\nConstitution. It is submitted that, section 43B contemplates that,\na law must levy a tax, duty, cess or fee, and that there is no such\nlevy in the case of a guarantee commission. The Ld.AR thus\nsubmitted that Section 43B does not cover guarantee\ncommission.\n18.3 The Ld.AR submitted that the commission is paid as\nconsideration

DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S INFOSYS BPO LTD, BANGALORE

In the result appeal filed by assessee stands partly allowed

Bench: Shri J. Sudhakar Reddy & Smt.Beena Pillai

disallow payments when TDS was not done and subsequently become taxable on account o f a retrospective legislation. It has also referred to the decisions of the Delhi & Mumbai Tribunal in SMS Demag Pvt Ltd , 132 ITJ 498 & Sonic Biochem Extractions Pvt. Ltd. 23 ITR (Trib) 447, respectively. We uphold the decision of the CIT(A) and dismiss the grounds

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

293(1) of the\nConstitution. It is submitted that, section 43B contemplates that,\na law must levy a tax, duty, cess or fee, and that there is no such\nlevy in the case of a guarantee commission. The Ld.AR thus\nsubmitted that Section 43B does not cover guarantee\ncommission.\n18.3 The Ld.AR submitted that the commission is paid as\nconsideration

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

293(1) of the\nConstitution. It is submitted that, section 43B contemplates that,\na law must levy a tax, duty, cess or fee, and that there is no such\nlevy in the case of a guarantee commission. The Ld.AR thus\nsubmitted that Section 43B does not cover guarantee\ncommission.\n18.3 The Ld.AR submitted that the commission is paid as\nconsideration

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. THE INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

293(1) of the\nConstitution. It is submitted that, section 43B contemplates that,\na law must levy a tax, duty, cess or fee, and that there is no such\nlevy in the case of a guarantee commission. The Ld.AR thus\nsubmitted that Section 43B does not cover guarantee\ncommission.\nPage 35 of 48\nITA Nos. 1052 to 1060/Bang/2023\n18.3

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD- 5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

293(1) of the\nConstitution. It is submitted that, section 43B contemplates that,\na law must levy a tax, duty, cess or fee, and that there is no such\nlevy in the case of a guarantee commission. The Ld.AR thus\nsubmitted that Section 43B does not cover guarantee\ncommission.\n18.3 The Ld.AR submitted that the commission is paid as\nconsideration

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

293(1) of the\nConstitution. It is submitted that, section 43B contemplates that,\na law must levy a tax, duty, cess or fee, and that there is no such\nlevy in the case of a guarantee commission. The Ld.AR thus\nsubmitted that Section 43B does not cover guarantee\ncommission.\n18.3 The Ld.AR submitted that the commission is paid as\nconsideration

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

293(1) of the\nConstitution. It is submitted that, section 43B contemplates that,\na law must levy a tax, duty, cess or fee, and that there is no such\nlevy in the case of a guarantee commission. The Ld.AR thus\nsubmitted that Section 43B does not cover guarantee\ncommission.\n\nPage 35 of 48\n\nITA Nos. 1052 to 1060/Bang/2023

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME-TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

293(1) of the\nConstitution. It is submitted that, section 43B contemplates that,\na law must levy a tax, duty, cess or fee, and that there is no such\nlevy in the case of a guarantee commission. The Ld.AR thus\nsubmitted that Section 43B does not cover guarantee\ncommission.\n18.3 The Ld.AR submitted that the commission is paid as\nconsideration

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

293(1) of the\nConstitution. It is submitted that, section 43B contemplates that,\na law must levy a tax, duty, cess or fee, and that there is no such\nlevy in the case of a guarantee commission. The Ld.AR thus\nsubmitted that Section 43B does not cover guarantee\ncommission.\n18.3 The Ld.AR submitted that the commission is paid as\nconsideration

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

disallowances of weighted deduction under section 35(2AB) of the Act claimed on account of R&D facility. 69. At the outset, we note that the issue raised by the assessee in its grounds of appeal for the AY 2019-20 is identical to the issue raised by the assessee in ITA No. 291/Bang/2025 for the assessment year

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

disallowances of weighted deduction under section 35(2AB) of the Act claimed on account of R&D facility. 69. At the outset, we note that the issue raised by the assessee in its grounds of appeal for the AY 2019-20 is identical to the issue raised by the assessee in ITA No. 291/Bang/2025 for the assessment year