M/S UNITED BREWERIES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

Disallowance under section 43B 49,27,979 Foreign royalty 16,56,488 Brand promotion expense 13,76,00,000 3. The A.O. also

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

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 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), 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

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

ACIT, BANGALORE vs. M/S JUPITER CAPITAL (P) LTD.,, BANGALORE

In the result, ITA No. 60/Bang/2012 and 253/Bang/2014 of the assessee are partly allowed for statistical purposes and ITA

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raoassessee’S Appeal

section 37 of the Act state that, unless the expenditure is capital or personal in nature, which is prohibited by law for the purpose which are an offence, can be allowed. The AO has not established any of the above parameters laid down by the Act but yet choose to disallow the appellant’s claim. 4.5 The material available

JUPITER CAPIAL P. LTD. vs. CIT, BANGALORE

In the result, ITA No. 60/Bang/2012 and 253/Bang/2014 of the assessee are partly allowed for statistical purposes and ITA

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raoassessee’S Appeal

section 37 of the Act state that, unless the expenditure is capital or personal in nature, which is prohibited by law for the purpose which are an offence, can be allowed. The AO has not established any of the above parameters laid down by the Act but yet choose to disallow the appellant’s claim. 4.5 The material available

M/S JUPITER CAPITAL (P) LIMITED,BANGALORE vs. ACIT, BANGALORE

In the result, ITA No. 60/Bang/2012 and 253/Bang/2014 of the assessee are partly allowed for statistical purposes and ITA

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raoassessee’S Appeal

section 37 of the Act state that, unless the expenditure is capital or personal in nature, which is prohibited by law for the purpose which are an offence, can be allowed. The AO has not established any of the above parameters laid down by the Act but yet choose to disallow the appellant’s claim. 4.5 The material available

RAAJRATNA ENERGY HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

disallowance under Section 14A, addition under Section 56(2)(viib) for share premium, and disallowance of short-term capital loss

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

M/S. TUV RHEINLAND NIFE ACADEMY PRIVATE LIMITED,BENGALURU vs. INCOME TAX OFFICER, WARD-7(1)(2),, BENGALURU

In the result, the assessee’s appeal for Assessment Year 2015-16

Bench: Shri N. V. Vasudevanand Shri Jason P. Boazassessment Year : 2015-16 M/S. Tuv Rheinland Nife Vs. The Income Tax Officer, Academy Pvt. Ltd., Ward-7(1)(2), No.27/B, 2Nd Cross, 13, Bengaluru. Konappan Agrahara, Begur Hobli, Electronic City, Bangalore – 560 100. Pan : Aaect 8703 A Appellant Respondent

disallowing the bad debts claimed of Rs.46,70,166/- without appreciating the facts and circumstances of the case and the applicable law. 3. That the Learned ITO while making additions u/s 56(2) (viib) of the Act, disregarded the facts and circumstances of the case and has concluded Assessment in a mechanical manner without application of mind. 4. That

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

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

disallowance of guarantee commission under Section 43B was set aside, remanding the issue to the AO.", "result": "Partly Allowed", "sections": [ "80P(2)(a)(i)", "80P(2)(d)", "80P(4)", "43B", "56

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

56 of the Act (emphasis drawn from\nparas 10-11 of the judgment).\n17.2 Now coming to the merits of the disallowance made u/s.\n80P(2)(d) by the authorities below, the word 'attributable' used in\nthe said 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

disallowance was made in the Assessee’s case for assessment year 2012-13 on the basis of the order for assessment year 2010-11. She submitted that this Tribunal vide its order dated 14.11.2022 in Dell International Services India Private Limited, (for the merged entity Dell India Private Limited) v. JCIT for the assessment year

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

56 of the Act (emphasis drawn from\nparas 10-11 of the judgment).\n17.2 Now coming to the merits of the disallowance made u/s.\n80P(2)(d) by the authorities below, the word 'attributable' used in\nthe said Section

RAAJRATNA ENERGY HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

Accordingly, this\nground is allowed for statistical purposes

section 56(2)(viib) of the\nAct for the Assessment Year 2017-18. Further for the Assessment Year 2018-\n19, AO has disallowed