M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

B” BENCH, BENGALURU Before Shri George George K., Judicial Member and Shri Laxmi Prasad Sahu, Accountant Member M/s. Bank of Baroda vs. Addl. CIT, LTU, (erstwhile Vijaya Bank) BMTC Building 7th Floor, Central Accounts 6th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 PAN – AAACVO3787 (Appellant) (Respondent) ACIT, Circle - 2(1)(1) vs. M/s. Bank of Baroda Room

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

41(4) in respect of the recoveries made from the bad debts not allowed as deduction u/s 36(1)(vii) in the earlier years and in the current year, if the Ground relating to the claim of bad debts u/s 36(1)(vii) is decided against the Appellant Bank. ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 3 of 46 4. The learned

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

41(4) in respect of the recoveries made from the bad debts not allowed as deduction u/s 36(1)(vii) in the earlier years and in the current year, if the Ground relating to the claim of bad debts u/s 36(1)(vii) is decided against the Appellant Bank. ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 3 of 46 4. The learned

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

b) of Income Tax Rules, the\nsubmission of Form 3CL issued by DSIR is mandatory for allowing\nweighted deduction under section 35(2AB) of the Act. Since the assessee\nfailed to furnish Form 3CL for the relevant year, the AO concluded that\nthe assessee was not eligible for weighted deduction at 150%.\nAccordingly, the AO disallowed the excess weighted deduction

SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1(1) & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

41 – 45 to state that the amendment has been made with effect from 1 April 2021 and further referred to the memorandum explaining the provisions of the Finance Bill 2021 wherein it is mentioned that the above amendment will take effect from 1 April 2021 and will accordingly apply to the assessment year 2021 – 22 and subsequent assessment years

SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1 & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

41 – 45 to state that the amendment has been made with effect from 1 April 2021 and further referred to the memorandum explaining the provisions of the Finance Bill 2021 wherein it is mentioned that the above amendment will take effect from 1 April 2021 and will accordingly apply to the assessment year 2021 – 22 and subsequent assessment years

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

41 every corresponding new bank shall be deemed to be an „Indian company‟ and the company in which the public are „substantially interested' and since in Section 2(17) of the Income Tax Act, the „company‟ has been defined as any Indian company therefore, the provisions of the Income Tax Act would apply because Section

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

41. In the result, the appeal of the assessee is partly allowed for statistical purposes. Coming to ITA No. 291/Bang/2025 pertaining to A.Y. 2018-19 ITA Nos.290 - 294/Bang/2025 Page 35 of 53 42. The Ground Nos. 1 and 6 of the assessee’s appeal are general Grounds which do not require any separate adjudication. Hence, we dismiss the same

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

41. In the result, the appeal of the assessee is partly allowed for statistical purposes. Coming to ITA No. 291/Bang/2025 pertaining to A.Y. 2018-19 ITA Nos.290 - 294/Bang/2025 Page 35 of 53 42. The Ground Nos. 1 and 6 of the assessee’s appeal are general Grounds which do not require any separate adjudication. Hence, we dismiss the same

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

41. In the result, the appeal of the assessee is partly allowed for statistical purposes. Coming to ITA No. 291/Bang/2025 pertaining to A.Y. 2018-19 ITA Nos.290 - 294/Bang/2025 Page 35 of 53 42. The Ground Nos. 1 and 6 of the assessee’s appeal are general Grounds which do not require any separate adjudication. Hence, we dismiss the same

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

b) Without prejudice, the sum of Rs.6,44,25,411/- ought to have been allowed as a business loss/ expense under section 28 or section 37(1) of the Act under the facts and circumstances of the case. ITA Nos.234 to 237/Bang/2020 Page 6 of 41 c) Without prejudice, the authorities below erred in disallowing

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

b) Without prejudice, the sum of Rs.6,44,25,411/- ought to have been allowed as a business loss/ expense under section 28 or section 37(1) of the Act under the facts and circumstances of the case. ITA Nos.234 to 237/Bang/2020 Page 6 of 41 c) Without prejudice, the authorities below erred in disallowing

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

b) Without prejudice, the sum of Rs.6,44,25,411/- ought to have been allowed as a business loss/ expense under section 28 or section 37(1) of the Act under the facts and circumstances of the case. ITA Nos.234 to 237/Bang/2020 Page 6 of 41 c) Without prejudice, the authorities below erred in disallowing

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

41 (1) of the act. Accordingly, we dismiss ground number 2 of the appeal of the learned AO. 20. In the result appeal filed by the learned assessing officer is dismissed. 21. Now we proceed to decide the appeal of Assessee. 22. Ground number 1 of the appeal is general in nature, no specific arguments were advanced, therefore

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

41 (1) of the act. Accordingly, we dismiss ground number 2 of the appeal of the learned AO. 20. In the result appeal filed by the learned assessing officer is dismissed. 21. Now we proceed to decide the appeal of Assessee. 22. Ground number 1 of the appeal is general in nature, no specific arguments were advanced, therefore

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

b) of Income Tax Rules, the\nsubmission of Form 3CL issued by DSIR is mandatory for allowing\nweighted deduction under section 35(2AB) of the Act. Since the assessee\nfailed to furnish Form 3CL for the relevant year, the AO concluded that\nthe assessee was not eligible for weighted deduction at 150%.\nAccordingly, the AO disallowed the excess weighted deduction

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

B of the Act. The words ‘derived by an undertaking’ in section 10AA means all profits and gains of the SEZ unit including the incidental incomes arising in the ordinary course of business even though not as a direct result of export. All incidental activities resulting in incidental incomes in the SEZ units are earned out of business decisions

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

41(1) of the Act in the year of recovery. Any recovery made in a loan account which is not written off is credited to that loan account only and not to P&L account. However, recovery made in an account which is written off is credited to P&L account. Thus, the very fact that recovery is credited

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

41(1) of the Act in the year of recovery. Any recovery made in a loan account which is not written off is credited to that loan account only and not to P&L account. However, recovery made in an account which is written off is credited to P&L account. Thus, the very fact that recovery is credited