M/S MHM HOLDINGS PVT LTD ,BANGALORE vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-12 , BANGALORE

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

Bench: Smt. Beena Pillai & Ms. Padmavathy S.M/S. Mhm Holding Pvt. Ltd. Vs Acit, Range - 12 Bengaluru No. 52, Bassappa Road Shantinagar Bengaluru 560027 Pan – Aabcm6614L (Appellant) (Respondent) Assessee By: Shri Parthasarathi, Adv. Revenue By: Shri K.R. Narayana, Addl Cit-Dr Date Of Hearing: 23/11/2022 Date Of Pronouncement: 25/11/2022 O R D E R Per: Padmavathy, A.M.

Section 50B of the Act as per the detailed computation given below: - Provisional purchase price in respect of capacitors 116,00,00,000 division Less Adjustment in purchase price as given in Pg. 1,74,16,651 No. 15 of the agreement Final purchase price in respect of capacitors division 114,25,83,349 Add Purchase price in respect

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 4(1)(1), BANGALORE vs. M/S. LIFESTYLE INTERNATIONAL PRIVATE LIMITED, BANGALORE

In the result, the assessee’s appeal stands allowed and revenue’s appeal stands dismissed

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2013-14 M/S. Lifestyle International Pvt. Ltd., 77, Town Centre, The Deputy Building No. 3, Commissioner Of West Wing, Income Tax, Off Hal Airport Road, Circle – 4(1)(1), Yamlur, Vs. Bengaluru. Bengaluru – 560 037. Pan: Aaacl2937J Appellant Respondent & Assessment Year : 2013-14 (By Revenue)

1 read with Explanation 2 of section 50 B. According to these provisions, aggregate value of total asset is reduced by value of liability of such undertaking. The aggregate value of asset and the value of liability as per Explanation 2, is the written down value of depreciable assets, book value of other assets and the book value

M/S TALLY SOLUTIONS PVT. LTD.,,BANGALORE vs. ACIT, BANGALORE

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

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

disallowed by the Assessing Officer. The Hon'ble Supreme Court has allowed the claim as business loss sustained by the assessee as a result of misappropriation by the employee which is incidental to carrying on his business. The learned Authorised Representative thus submitted that the assessee has disclosed in the notes to the accounts for the year ended 31.3.2006 that

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. DECCAN CHARTERS PVT LTD, BANGALORE

In the result, the appeal filed by the revenue stands partly allowed for statistical purposes

Bench: Smt. Beena Pillai & Shri Waseem Ahmedassessment Year : 2019-20 M/S. Deccan Charters Pvt. Ltd., The Deputy Jakkur Aerodrome, Commissioner Of Bellary Road, Income Tax, Jakkur B.O., Circle – 2(1)(1), Bangalore North, Bangalore. Vs. Bangalore – 560 064. Pan: Aaccd9105G Appellant Respondent

section 143(1)(a)” Aggrieved by the intimation u/s. 143(1)(a), the assessee preferred appeal before the Ld.CIT(A). 2.3 The Ld.CIT(A) after considering the submissions of the assessee was of the view that the disallowance made u/s. 143(1)(a) is not sustainable as it was a debatable issue. Page 3 of 5 2.4 The Ld.CIT

TYCO FIRE AND SECURITY INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariit(Tp)A No.270/Bang/2021 Assessment Year : 2016-17 Acit, M/S. Tyco Fire & Security India Private Limited, Vs. D-601, Rmz Centennial, Circle - 7(1)(1), Kundalahalli Main Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 0087 C Appellant Respondent Assessee By : Shri. Rajan Vora, Ca Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 27/11.09.2022 Date Of Pronouncement : 28.11.2022 O R D E R Per N V Vasudevan

1 in Ground No.4.3 is concerned, the said company has admittedly a turnover of above Rs.200 crores in FY 2013-14 & 2014-15 and hence is not a comparable company in those two Financial Years and therefore while computing the average profit margin of three financial years, the profit margins of these two Financial years 2013-14 & 2014-15 should

IBM INDIA PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), BENGALURU

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

1. Order bad in law 1.1. On the facts and circumstances of the case and in law, the order under section 250 of the Income-tax Act, 1961 (the Act') dated March 16, 2020 passed by the learned Commissioner of Income-tax (Appeals) - 12, Bangalore ['CIT(A)'], upholding the order passed under Page 2 of 19 section 147 read with

M/S MANGALORE CHEMICALS AND FERTILIZERS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, both the appeals of the Assessee are dismissed

Bench: Shri N.V. Vasudevan, Vice Preseident & Ms. Padmavathy S

1 Captive Power generating units 2014-15 2015-16 142,98,35,558 2 captive power generating units and Plant and Machinery in ammonia section 12. Thus, as per the staggered implementation explained above, the Assessee completed the entire investment in urea/ammonia section together with the captive power generating units to continue to be qualified to receive subsidies

M/S MANGALORE CHEMICALS AND FERTILIZERS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, both the appeals of the Assessee are dismissed

Bench: Shri N.V. Vasudevan, Vice Preseident & Ms. Padmavathy S

1 Captive Power generating units 2014-15 2015-16 142,98,35,558 2 captive power generating units and Plant and Machinery in ammonia section 12. Thus, as per the staggered implementation explained above, the Assessee completed the entire investment in urea/ammonia section together with the captive power generating units to continue to be qualified to receive subsidies

ASSISTANT COMMISSIONER OF INCOME TAX, BANGALORE vs. M/S.PADMINI PRODUCTS PVT LTD.,, BANGALORE

In the result, the appeals filed by the assessee for all the assessment years are dismissed

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaramanassessment Year : 2013-14

disallowance of depreciation on intangible assets to the extent of Rs.29248420/- 1. The Learned Commissioner (Appeals) is not justified in upholding the action of the Learned Assessing Officer in denying depreciation of Rs 1,42,92,623/- on intangibles being brand names and trademarks valued at s.65.26.40,150/-. 2. The lower authorities have failed to appreciate that revaluation

M/S.PADMINI PRODUCTS PVT. LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, the appeals filed by the assessee for all the assessment years are dismissed

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaramanassessment Year : 2013-14

disallowance of depreciation on intangible assets to the extent of Rs.29248420/- 1. The Learned Commissioner (Appeals) is not justified in upholding the action of the Learned Assessing Officer in denying depreciation of Rs 1,42,92,623/- on intangibles being brand names and trademarks valued at s.65.26.40,150/-. 2. The lower authorities have failed to appreciate that revaluation

M/S TE CONNECTIVITY INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU,CIRCLE-1, , BENGALURU

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

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

disallowance, the Learned AO/ learned DRP has disregarded Form 3CEA obtained by the Assessee from a Chartered Accountant which certifies that the capital loss on account of slump sale has been computed correctly in accordance with the provisions of section 50B of the Act.” 65. The assessee has entered into business transfer agreement for sale of tooling parts business

M/S PADMINI PRODUCTS PVT LTD ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-5(1)(2), BANGALORE

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

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumarassessment Year : 2015-16

disallowance of depreciation on intangible assets to the extent of Rs.1,64,95,840/-. 1. The Learned Commissioner (Appeals) is not justified in upholding the action of the Learned Assessing Officer in denying depreciation of Rs.1,64,95,840/-(Rs.84,56,239/-+Rs.80,39,601/-) on intangibles being brand names and trademarks valued at Rs.65