MANIPAL GLOBAL EDUCATION SERVICES PVT LTD., ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(2), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

301 CTR 489 (SC)[12-02-2018]has categorically held that recording of the satisfaction is a sine qua non before making any disallowance where it has been held as under :- “41. Having regard to the language of Section

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD.,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

301 CTR 489 (SC)[12-02-2018]has categorically held that recording of the satisfaction is a sine qua non before making any disallowance where it has been held as under :- “41. Having regard to the language of Section

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

301 CTR 489 (SC)[12-02-2018]has categorically held that recording of the satisfaction is a sine qua non before making any disallowance where it has been held as under :- “41. Having regard to the language of Section

MANIPAL HOSPITALS PVT. LTD (FORMERLY KNOWN AS COLUMBIA ASIA HOSPITALS PVT. LTD),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

301 CTR 489 (SC)[12-02-2018]has categorically held that recording of the satisfaction is a sine qua non before making any disallowance where it has been held as under :- “41. Having regard to the language of Section

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD. ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

301 CTR 489 (SC)[12-02-2018]has categorically held that recording of the satisfaction is a sine qua non before making any disallowance where it has been held as under :- “41. Having regard to the language of Section

RAAJRATNA ENERGY HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

Accordingly, this\nground is allowed for statistical purposes

section 56(2)(viib) of the\nAct for the Assessment Year 2017-18. Further for the Assessment Year 2018-\n19, AO has disallowed short term capital loss of Rs.5,10,000/- as per his Order\nat para No.5 on sale of investment in Venu Hydro Powers Ltd., and observed\nthat the assessee has claimed excess long term capital loss

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

disallowed the expenditure. The Commissioner (Appeals) held in favour of the assessee observing that there was no dispute that the services were in the nature of technical services, but would be covered under the Explanation clause contained in section 9(1)(vii)(b). This was upheld by the Tribunal. On appeal : Held, dismissing the appeal, that the Commissioner (Appeals

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

disallowed the expenditure. The Commissioner (Appeals) held in favour of the assessee observing that there was no dispute that the services were in the nature of technical services, but would be covered under the Explanation clause contained in section 9(1)(vii)(b). This was upheld by the Tribunal. On appeal : Held, dismissing the appeal, that the Commissioner (Appeals

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-12 , BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

disallowed the expenditure. The Commissioner (Appeals) held in favour of the assessee observing that there was no dispute that the services were in the nature of technical services, but would be covered under the Explanation clause contained in section 9(1)(vii)(b). This was upheld by the Tribunal. On appeal : Held, dismissing the appeal, that the Commissioner (Appeals

SOHANLAL KAWAR ,SHIMOGA vs. INCOME-TAX OFFICER, WARD-1,TPS, SHIMOGA

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

section 57(iii) 2.1 The learned CIT(A) has erred in confirming the disallowance of interest expenditure of Rs. 4,74,301

SOHANLAL KAWAR,SHIMOGA vs. INCOME-TAX OFFICER, WAR-1 & TPS, SHIMOGA

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

section 57(iii) 2.1 The learned CIT(A) has erred in confirming the disallowance of interest expenditure of Rs. 4,74,301

SOHANLAL KAWAR,SHIMOGA vs. INCOME-TAX OFFICER, WARD-1 & TPS, SHIMOGA

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

section 57(iii) 2.1 The learned CIT(A) has erred in confirming the disallowance of interest expenditure of Rs. 4,74,301

M/S SALESFORCE.COM INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

Accordingly these ground raised by assessee stands allowed for statistical purposes

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.3286/Bang/2018 Assessment Year : 2014-15

disallowed sum of Rs.2,45 86,946/-under section 40(a)(ia) of the Act, being the difference in the rent declared in 3CD report and as per statement of computation of income, on which TDS was not deducted. 12. Aggrieved by the addition made by the Ld.AO, assessee raised objections before DRP. DRP upheld the action of the Ld.TPO

XLHEALTH CORPORATION INDIA PRIVATE LIMITED,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, BANGALORE

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

disallowed'. 14. That on the facts of the case and in law, the learned AO has erred in not allowing set off of MAT credit of INR 63,00,690 under section 115JAA of the Act which was brought forward from earlier year(s). 15. That on the facts of the case and in law, the learned AO has erred

SRI.R.P.NARAYANA RAO,MYSORE vs. INCOME TAX OFFICER, MYSORE

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

Bench: Shri Vijay Pal Rao

301 Mysore District. PAN AAOPN 7143 H Appellant Respondent. Appellant By : Shri C.R. Nulvi, C.A. Respondent By : Shri AR.V.Sreenivasan, JCIT (D.R) Date of Hearing : 23.02.2017. Date of Pronouncement : 22.03.2017. O R D E R Per Shri Vijay Pal Rao, J.M. : This appeal by the assessee is directed against the order dt.30.03.2016 of Commissioner of Income Tax (Appeals), Mysore

JOINT COMMISSIONER OF INCOME TAX(OSD) CIRCLE-4(1)(1), BANGALORE vs. M/S KURLON LIMITED , BANGALORE

In the result, Revenue’s appeal is partly allowed

Bench: Shri A. K. Garodia & Smt. Beena Pillaiassessment Year : 2014-15 Joint Commissioner Of M/S. Kurlon Ltd., Income Tax (Osd), No. 301-303, North Block, Iii Floor, Circle – 4(1)(1), 2Nd Floor, Vs. Manipal Centre, Dickenson Road, Bmtc Depot, 6Th Block, Koramangala, Bengaluru – 560 042. Bengaluru – 560 095. Pan : Aabck 2150 K Appellant Respondent Revenue By : Shri. K. N. Dhandapani, Addl. Cit (Dr)(Itat), Bengaluru Assessee By : Shri. C. Ramesh, Ca Date Of Hearing : 12.12.2019 Date Of Pronouncement : 14.02.2020 O R D E R Per A.K. Garodiathis Appeal Is Filed By The Revenue & The Same Is Directed Against The Order Of Learned Cit(A)-4, Bengaluru, Dated 25.01.2017 For The Assessment Year 2014-15. 2. Ground No.1 Is General. As Per Revised Grounds 2 To 5, The Grievance Of The Revenue Is Regarding Part Deletion Of The Disallowance Made By The Ao Under Section 14A R.W.R. 8D(Ii). In This Regard, Learned Dr Of The Revenue Supported The Assessment Order. He Submitted That This Issue Was Decided By Learned Cit(A) As Per Para 5.4 Of His Order & The Disallowance Was Deleted Page 2 Of 7

301-303, North Block, III Floor, Circle – 4(1)(1), 2nd Floor, Vs. Manipal Centre, Dickenson Road, BMTC Depot, 6th Block, Koramangala, Bengaluru – 560 042. Bengaluru – 560 095. PAN : AABCK 2150 K APPELLANT RESPONDENT Revenue by : Shri. K. N. Dhandapani, Addl. CIT (DR)(ITAT), Bengaluru Assessee by : Shri. C. Ramesh, CA Date of hearing : 12.12.2019 Date of Pronouncement

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

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

disallowance of deduction under section 10AA: 3.1. The learned NFAC and the CIT(A) has erred in reducing the following incomes from profits of the business of SEZ units in computing deduction under section 1 OAA for the reason that the said incomes are not derived from the activity of software development and export. i) Interest on deposits with banks

SHRI MAHAVEER CO-OPERATIVE CREDIT SOCIETY LTD,ALAGUR vs. INCOME TAX OFFICER, ALAGUR

In the result, the appeal by the assessee is allowed for statistical purposes\nPronounced in the open court on this 25th day of July, 2025

301.\nPAN: AABAM 6275F\nAPPELLANT\nVs.\nThe Income Tax Officer,\nWard 1,\nBagalkot.\nRESPONDENT\nAppellant by\nRespondent by\nDate of hearing\nDate of Pronouncement\nShri Sanjay D. Shriguppe, CA\nShri Ganesh R. Ghale, Standing Counsel for Revenue.\n02.06.2025\n25.07.2025\nORDER\n1.\nThis appeal is filed by Shri Mahaveer Co-operative Credit Society Ltd. (the\nassessee/appellant) for the assessment year