M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

43 Others SUPREME COURT [2020] 422 ITR 3 ING Vysya Bank Limited 6 - 11 50 - 52 116 (Kar) ITA No. 740 / Del / 2020 - Punjab National Bank order dated 31- 217 - 4 (successor of Oriental Bank 10 03-2023 for 227 of Commerce) Asst Year 2016- 17 2020 (3) TMI 181 - 5 Indian Overseas Bank 897 - ITAT 29 - 30 182 CHENNAI

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)

disallowance made by the Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n Assessment Years 2018-19 to 2020-21:\n1.\nIt is submitted that the Assessee's Appeal in ITA Nos.645

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

5 of the BR Act, 1949, it would not be a co-\noperative bank. Then the definitions under the NABARD\nAct, 1981 would not apply. If a co-operative society is not a\nco-operative bank, then such an entity would be entitled to\ndeduction but on the other hand, if it is a co-operative bank\nwithin the meaning

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

5 of the BR Act, 1949, it would not be a co-\noperative bank. Then the definitions under the NABARD\nAct, 1981 would not apply. If a co-operative society is not a\nco-operative bank, then such an entity would be entitled to\ndeduction but on the other hand, if it is a co-operative bank\nwithin the meaning

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

disallowance made by the Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n Assessment Years 2018-19 to 2020-21:\n1.\nIt is submitted that the Assessee's Appeal

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 Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n\n Assessment Years 2018-19 to 2020-21:\n\n1.\nIt is submitted that the Assessee's Appeal

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

5 of the BR Act, 1949, it would not be a co-\noperative bank. Then the definitions under the NABARD\nAct, 1981 would not apply. If a co-operative society is not a\nco-operative bank, then such an entity would be entitled to\ndeduction but on the other hand, if it is a co-operative bank\nwithin the meaning

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

43 of 48\nITA Nos. 1052 to 1060/Bang/2023\nundertaking by the State Government (emphasis supplied)\nalone will satisfy the ingredients for disallowance. The\nstatute has not used the word; levied exclusively on the\nstate government undertakings by the State Government.\nInstead, the word used is "exclusively on" "a state\ngovernment undertaking". Therefore, in order to bring the\ndisallowance within

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

43 of 48\nITA Nos. 1052 to 1060/Bang/2023\nundertaking by the State Government (emphasis supplied)\nalone will satisfy the ingredients for disallowance. The\nstatute has not used the word; levied exclusively on the\nstate government undertakings by the State Government.\nInstead, the word used is "exclusively on" "a state\ngovernment undertaking". Therefore, in order to bring the\ndisallowance within

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

5 of the BR Act, 1949, it would not be a co-\noperative bank. Then the definitions under the NABARD\nAct, 1981 would not apply. If a co-operative society is not a\nco-operative bank, then such an entity would be entitled to\ndeduction but on the other hand, if it is a co-operative bank\nwithin the meaning

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

43 - Deduction under 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

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

43 - Deduction under 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

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

43 of 48\n\nITA Nos. 1052 to 1060/Bang/2023\n\nundertaking by the State Government (emphasis supplied)\nalone will satisfy the ingredients for disallowance. The\nstatute has not used the word; levied exclusively on the\nstate government undertakings by the State Government.\nInstead, the word used is "exclusively on" "a state\ngovernment undertaking". Therefore, in order to bring the\ndisallowance

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

5 of the BR Act, 1949, it would not be a co-\noperative bank. Then the definitions under the NABARD\nAct, 1981 would not apply. If a co-operative society is not a\nco-operative bank, then such an entity would be entitled to\ndeduction but on the other hand, if it is a co-operative bank\nwithin the meaning

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

5 of the BR Act, 1949, it would not be a co-\noperative bank. Then the definitions under the NABARD\nAct, 1981 would not apply. If a co-operative society is not a\nco-operative bank, then such an entity would be entitled to\ndeduction but on the other hand, if it is a co-operative bank\nwithin the meaning

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

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2013-14

disallowances were made in the assessment order resulting in an assessed Infosys Limited Page 3 of 20 total income of Rs. 11407,97,47,950/-. Being aggrieved, the assessee filed an appeal before the ld. CIT(A)/NFAC on 17.01.2017 against the said order. The CIT(A)/NFAC passed an order on 21.12.2017, partly allowing the appeal. Again aggrieved

SRI SRINIVASA TRUST,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These appeals filed by the assessee are against the order passed by the CIT(A)-15, BLR both dated 29/03/2024 for the assessment years 2020-21 and 2021-22 ITA No. 1075/Bang/2024, an appeal by the assessee for the AY 2020-21. ITA No.1075 & 1076/Bang/2024 Page 2 of 20 2. The issue

SRI SRINIVASA TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These appeals filed by the assessee are against the order passed by the CIT(A)-15, BLR both dated 29/03/2024 for the assessment years 2020-21 and 2021-22 ITA No. 1075/Bang/2024, an appeal by the assessee for the AY 2020-21. ITA No.1075 & 1076/Bang/2024 Page 2 of 20 2. The issue