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 11. 40(a)(i) — The learned CIT(A) has erred in confirming the action of the learned assessing officer in disallowing payments made to overseas subsidiaries totally amounting to Rs. 269,31,41

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)

section\n14A, read with rule\n8D-Commissioner (Appeals)\nrestricted disallowance to\nRs.13.46 lakhs which was\nsustained by Tribunal - On\nappeal to High Court it was\nfound that Assessing\nOfficer had wrongly taken\ninto account investments\nother than investments\nmade to earn exempt\nincome\nCommissioner\n(Appeals) had correctly\napplied formula prescribed\nunder rule 8D(2)(iii) -\nWhether thus, no\nsubstantial

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. In this regard we notice that the Hon’ble Supreme Court in the case of Maxopp Investment Ltd. v. CIT [2018] 91 taxmann.com 154 (SC) has held as follows:- “41. Having regard to the language of Section

M/S. BANGALORE ELECTRICITY SUPPLY COMPANY LTD.,,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2), BANGALORE

In the result, the appeal by the assessee is partly allowed and appeal of the ld

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

disallowance. Accordingly ground number 1 of the appeal is dismissed. 15. Ground number 2 of the appeal is with respect to deleting the addition of 5% of sundry creditors payable towards purchase suppliers and work and for expenses as a cessation of liability under section 41

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE- 1(1)(1), BANGALORE, BMTC BUILDING, KORAMANGALA, BAQNGALORE vs. BANGALORE ELECTRICITY SUPPLY COMPANY LIMITED , BESCOM CORPORATE OFFICE

In the result, the appeal by the assessee is partly allowed and appeal of the ld

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

disallowance. Accordingly ground number 1 of the appeal is dismissed. 15. Ground number 2 of the appeal is with respect to deleting the addition of 5% of sundry creditors payable towards purchase suppliers and work and for expenses as a cessation of liability under section 41

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. This is contrary to\nAppellant's own case in ITA 177/2019, the Hon'ble Jurisdictional\nHigh Court (para 15) {CLI 3 – Pg.1534 & 1535}.\n\n6. 4. AO has failed to appreciate that satisfaction contemplated in section\n14A(2) is an objective one and not a subjective one based on some\nvague assumptions\n\nCases\nMaxopp Investment

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. In this regard we\nnotice that the Hon'ble Supreme Court in the case of Maxopp Investment Ltd. v. CIT [2018]\n91 taxmann.com 154 (SC) has held as follows:-\n\n“41. Having regard to the language of Section

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

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

41,850 Total 8. Further in respect of balance amount, assessee has clearly violated the provisions of section 40A(3) of the Act. Therefore, same was disallowed

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

In the result, we dismiss grounds raised by the assessee

41,850/- and\npayments made on Sundays / public holidays of Rs.6,42,380/- and difference\nof Rs.10,14,230/- under section 40A(3) of the Act. For the Assessment Year\n2013-14 and for Assessment Year 2014-15 assessee disputed the amount of\nRs.78,27,682/- for the cash payment towards materials purchased where bill\nreceived and VAT paid

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DCIT, CIRCLE 1(1) & TPS, 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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DCIT, CIRCLE-1(1), 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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DCIT, CIRCLE 1(1) & TPS, 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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DCIT, CIRCLE 1(1) & TPS, 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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

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

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government