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

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

disallowance made under section 10AA of the Act ignoring that since no new master service agreement was made, the benefit of claim u/s 10AA from the old SEZ cannot be allowed. 5. The CIT(A) erred in remitting the matter to assessing officer on issue relating to section 80G of the Act ignoring that in instant case assessee

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

disallowance made by the\nappellant.\n\n11. Insofar as the addition made based on the seizure of cash, the\nLd.CIT(A) had deleted the said addition for A.Y. 2020-21 on the ground that\nthe unaccounted sale of gunny bags were duly recorded and accounted for\nin the books and therefore no addition could be made u/s.69A

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.

disallowance made under section\n10AA of the Act ignoring that since no new master service agreement was\nmade, the benefit of claim u/s 10AA from the old SEZ cannot be allowed.\n\n5.\nThe CIT(A) erred in remitting the matter to assessing officer on issue\nrelating to section 80G of the Act ignoring that in instant case assessee

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

33 of 47 when the corresponding income is duly brought to tax. That will be going much beyond the obvious intention of the section. Accordingly, we hold that the insertion of second proviso to Section 40(a)(ia) is declaratory and curative in nature and it has retrospective effect from 1st April, 2005, being the date from which sub clause

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 14A r.w. Rule 8D(2)(iii), where the assessee has disclosed investment of Rs.1,44,00,000/-.Since these investments need a potential Advisor to earn exempted income, the Ao computed disallowance under Rule 8D(2)(iii) ofRs.1,37,500 based on the disclosures in the Balance Sheet. But the assessee company has not yielded any exempted income

MUTHYALA SURYABABU,BENGALURU vs. PR. COMMISSIONER OF INCOME TAX, BANGALORE-1, BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2020-21

disallowed. After examination of the assessment record, the ld. PCIT observed that this aspect of whether the impugned expenditure of “arrears of property tax” is eligible to be allowed as Muthyala Suryababu Page 3 of 8 cost of acquisition or cost of improvement had not been verified and examined during the assessment proceedings. In view of the clause

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

33,46,60,580/- 3. In these cases, assessment orders were framed u/s 143(3) of the Income-tax Act,1961 ['the Act' for short] disallowing the interest on borrowed capital paid to the partners by these firms. While disallowing interest payment, the A.O. enquired with the assessees the necessity of paying such interest to the partners. The assessees herein

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

33,46,60,580/- 3. In these cases, assessment orders were framed u/s 143(3) of the Income-tax Act,1961 ['the Act' for short] disallowing the interest on borrowed capital paid to the partners by these firms. While disallowing interest payment, the A.O. enquired with the assessees the necessity of paying such interest to the partners. The assessees herein

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

33,46,60,580/- 3. In these cases, assessment orders were framed u/s 143(3) of the Income-tax Act,1961 ['the Act' for short] disallowing the interest on borrowed capital paid to the partners by these firms. While disallowing interest payment, the A.O. enquired with the assessees the necessity of paying such interest to the partners. The assessees herein

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

33,46,60,580/- 3. In these cases, assessment orders were framed u/s 143(3) of the Income-tax Act,1961 ['the Act' for short] disallowing the interest on borrowed capital paid to the partners by these firms. While disallowing interest payment, the A.O. enquired with the assessees the necessity of paying such interest to the partners. The assessees herein

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

33,46,60,580/- 3. In these cases, assessment orders were framed u/s 143(3) of the Income-tax Act,1961 ['the Act' for short] disallowing the interest on borrowed capital paid to the partners by these firms. While disallowing interest payment, the A.O. enquired with the assessees the necessity of paying such interest to the partners. The assessees herein

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

33,46,60,580/- 3. In these cases, assessment orders were framed u/s 143(3) of the Income-tax Act,1961 ['the Act' for short] disallowing the interest on borrowed capital paid to the partners by these firms. While disallowing interest payment, the A.O. enquired with the assessees the necessity of paying such interest to the partners. The assessees herein

IBM GLOBAL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), BANGALORE

In the result, the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2000-2001

disallowance made in the assessment order was denying exemption claimed u/s. 10A of the act on the ground that, the export turnover brought into India does not amount to 75 percent of the total turnover of the STP unit. It was submitted by the assessee that, it treated export credits of the bank account maintained

ARJUN KESHAVA MURTHY PERIKAL,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(3)(1), BENGALURU

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

disallowance of Rs. 2,33,946/- towards foreign travel\nexpenses on the ground that the assessee failed to prove beyond doubt\nthat the travel related to his business or profession. It was argued that\nthe AO had incorrectly assumed that the foreign travel was related to\nthe appellant's real estate business, whereas in fact the expenditure\nrelated

M/S. ACE DEVELOPERS,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU

In the result, the all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

33,332/- by the Assessing Officer by making disallowance under section 40A(3) of the income tax Act 1961. 3. The learned

M/S. ACE DEVELOPERS,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU

In the result, the all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

33,332/- by the Assessing Officer by making disallowance under section 40A(3) of the income tax Act 1961. 3. The learned