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

65,80,751/- was disallowed and added back to the returned income of the assessee by the AO. 5. Aggrieved by the above order of the AO, the went in appeal before the ld CIT(A) stating that the assessing officer has erred in computing the disallowance under section

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. 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 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) of IT(TP)A No.2846/Bang/2017 M/s. Dell International Services India Pvt. Ltd., Bangalore Page 26 of 47 the Act as the Assessee had made a suo moto disallowance of the entire provision amount in the year of creation of the provision. Reliance is also placed on the decision of the Hon’ble High Court of Karnataka

BHARAT ELECTRONICS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, LARGE PAYERS TAX UNIT, CIRCLE-1, BANGALORE

In the result, appeal of the assessee is partly allowed

Section 37 of the Act as it was incurred for the\npurpose of business. In other words, the learned Assessing Officer\nshould have restricted the disallowance to the amount of\nRs.2,52,14,792/- (Rs. 7,32,06,000 - Rs. 4,79,91,000).\nPage 10 of 15\nITA No.1067/Bang/2023\nBharat Electronics Limited, Bangalore\n7.5\nShe submitted the computation given

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

65,00,980 u/s 147 3.4. The appellant aggrieved by the above addition and disallowance preferred an appeal before learned Commissioner of Income Tax (Appeals). During the course of the appeal proceedings the appellant submitted all the relevant details to substantiate the genuineness of the expense. However, the learned assessing officer considered the submissions of the appellant and granted relief

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

In the result, we dismiss grounds raised by the assessee

65,00,980\n\n3.4.\nThe appellant aggrieved by the above addition and disallowance\npreferred an appeal before learned Commissioner of Income Tax\n(Appeals). During the course of the appeal proceedings the appellant\nsubmitted all the relevant details to substantiate the genuineness of the\nexpense. However, the learned assessing officer considered the\nsubmissions of the appellant and granted relief

ASSISTANT COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. BANGALORE INTERNATIONAL AIRPORT LIMITED, BANGALORE

In the result, the cross objection of the assessee is hereby partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 43B of the Act. 65. However, since the matter also involves actual payment of ₹88.54, therefore a verification of the actual quantum of expenditure pertaining to the year under . ITA Nos. 1108 & 1109/Bang/2024 & C.O. No. 25/Bang/2024 Page 22 of 26 consideration is required to be made. Therefore, we direct the AO to verify the correctness of the amount

HEWLETT PACKARD INDIA SALES PVT. LTD.,,BANGALORE vs. JCIT, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

section 40(a) and Page 32 ITA Nos. 579 & 593/Bang/2015 40(a)(ia), the Taxpayer reverses accruals created in the previous year and accounts for expenses in connection with the subject accruals and complies with the applicable withholding tax. As a part of the proceedings before the learned CIT(A), the Taxpayer has also furnished sample extract of such reversal

JCIT, BANGALORE vs. M/S HEWLETT - PACKARD INDIA SALES PRIVATE LIMITED, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

section 40(a) and Page 32 ITA Nos. 579 & 593/Bang/2015 40(a)(ia), the Taxpayer reverses accruals created in the previous year and accounts for expenses in connection with the subject accruals and complies with the applicable withholding tax. As a part of the proceedings before the learned CIT(A), the Taxpayer has also furnished sample extract of such reversal

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

disallowance sustained by the learned CIT(A) is set aside. The Assessing Officer is directed to grant appropriate relief in accordance with law. The ground raised by the assessee is allowed. ITA Nos.290 - 294/Bang/2025 Page 48 of 53 60. The Ground No. 5 of the assessee’s appeal pertains to levy of interest under section 234D of the Act which

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

disallowance sustained by the learned CIT(A) is set aside. The Assessing Officer is directed to grant appropriate relief in accordance with law. The ground raised by the assessee is allowed. ITA Nos.290 - 294/Bang/2025 Page 48 of 53 60. The Ground No. 5 of the assessee’s appeal pertains to levy of interest under section 234D of the Act which

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

disallowance sustained by the learned CIT(A) is set aside. The Assessing Officer is directed to grant appropriate relief in accordance with law. The ground raised by the assessee is allowed. ITA Nos.290 - 294/Bang/2025 Page 48 of 53 60. The Ground No. 5 of the assessee’s appeal pertains to levy of interest under section 234D of the Act which

EIT SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal filed by assessee stands allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 258/Bang/2022 Assessment Year : 2017-18 M/S. Eit Services India Pvt. Ltd., The Deputy #39/40, Digital Park, Commissioner Of Electronic City Phase Income Tax, Ii, Circle – 2(1)(1), Hosur Road, Vs. Bangalore. Bangalore – 560 100. Pan: Aaacd4078L Appellant Respondent Assessee By : Shri Padam Chand Khincha, Ca Revenue By : Shri Praveen Karanth, Cit-Dr Date Of Hearing : 01-11-2022 Date Of Pronouncement : 04-01-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 14/02/2022 Passed By Nfac, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal: “1. General Ground 1.1. The Orders Passed By Learned Additional / Joint / Deputy / Assistant Commissioner Of Income Tax/ Income- Tax Officer, National E-Assessment Centre, Delhi (Hereinafter Referred As "Ao" For Brevity), Learned Deputy Commissioner Of Income Tax (Tp) — 1(2)(1), Bangalore (Hereinafter Referred As "Tpo" For Brevity) & The Learned Dispute Resolution Panel - 1, Bengaluru (Hereinafter Referred As "Drp" For Brevity) ("Ao", "Tpo" & "Drp"

section 37 3.1. The learned AO/DRP have erred in disallowing stock compensation expenses of Rs.43,65,82,925 reimbursed to the ultimate

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

section 14A of the Act?\n3. Whether on the facts and circumstances of the case and in law, the\nld. CIT(A) is right in holding that the disallowance u/s 14A cannot\nexceed the income claimed as exempt contrary to the provisions of\nlaw prescribed?\n4. Whether on the facts and circumstances of the case

M/S. NIRMAL ENVIRO SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

Section 143(1) of the Income Tax Act, 1961 (the Act) addition of Nirmal Enviro Solutions P. Ltd. Rs.15,98,331/- on account of contribution of PF and ESI were made to the total income. The issue involved in the ground of appeal is disallowance of Rs.15,98,331/- for contribution to PF and ESI. 3. On appeal

SRI PANATI VIDYANATH REDDY ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BANGALORE

In the result, both the appeals filed by different assessees are partly allowed for statistical purposes

Bench: Shri Chandra Poojarishri Panati Vidyanath Reddy Vs Acit, Circle - 4(3)(1) 10, 32Nd Main, 5Th Cross Bengaluru Dollars Colony, Btm Layout 1St Stage, Bengaluru 560068 Pan – Afmpr3580F (Appellant) (Respondent) M/S. Nirmal Enviro Solutsions P. Ltd. Vs Acit, Circle - 3(1)(1) 26, 9Th Cross, 16Th Main Bengaluru Btm Layout, 1St Stage Bengaluru 560068 Pan – Aadcn1064H (Appellant) (Respondent) Assessee By: Miss Sunaiana Bhatia, Ca Revenue By: Shri Ganesh R. Ghale, Standing Counsel Date Of Hearing: 18.01.2023 Date Of Pronouncement: 18.01.2023 O R D E R Per: Chandra Poojari, A.M.

Section 143(1) of the Income Tax Act, 1961 (the Act) addition of Nirmal Enviro Solutions P. Ltd. Rs.15,98,331/- on account of contribution of PF and ESI were made to the total income. The issue involved in the ground of appeal is disallowance of Rs.15,98,331/- for contribution to PF and ESI. 3. On appeal

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1)(1), BENGALURU, BENGALURU vs. NUTRICRAFT INDIA PRIVATE LIMITED, BENGALURU

In the result appeal filed by the learned assessing officer is partly allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

65,777,280/–. The case was selected for the complete scrutiny. 13. The ld. AO found that assessee has paid a remuneration to its director amounting to ₹ 11,39,00,000/- which is hit by the provisions of section 36 (1) (ii) of the act, so he disallowed