ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , 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

section 36(1)(vii) of the Act vide Finance Act 2013. 6. There is no scope in IT Act to allow the provision of non rural branches advances u/s 36(1)(vii) of the IT Act and in the present case it was not bad debt write off of non rural branches. The assessee bank has made false submission

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

67 (SC) in interpreting the words 'such debt' contained in proviso to Section 36(1)(vii). 2.4. The learned CIT(A) erred in concluding that Sections 36(1)(vii) and 36(1)(viia) of the Income Tax Act are not independent items of deduction post Finance Act, 1985. 2.5. The learned CIT(A) failed to appreciate the fact that introduction

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

67 (SC) in interpreting the words 'such debt' contained in proviso to Section 36(1)(vii). 2.4. The learned CIT(A) erred in concluding that Sections 36(1)(vii) and 36(1)(viia) of the Income Tax Act are not independent items of deduction post Finance Act, 1985. 2.5. The learned CIT(A) failed to appreciate the fact that introduction

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

section 234D of the Act which is consequential in nature and does not require any separate adjudication. Hence, the same is dismissed as infructuous. 61. Coming to issue raised through additional ground of appeal regarding allowances of foreign tax as business expenditure. 62. At the outset, we note that the issue raised by the assessee in its grounds of appeal

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

section 234D of the Act which is consequential in nature and does not require any separate adjudication. Hence, the same is dismissed as infructuous. 61. Coming to issue raised through additional ground of appeal regarding allowances of foreign tax as business expenditure. 62. At the outset, we note that the issue raised by the assessee in its grounds of appeal

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

section 234D of the Act which is consequential in nature and does not require any separate adjudication. Hence, the same is dismissed as infructuous. 61. Coming to issue raised through additional ground of appeal regarding allowances of foreign tax as business expenditure. 62. At the outset, we note that the issue raised by the assessee in its grounds of appeal

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowance made under section 143(1) of the Act. 38.1 The assessee has submitted that the foreign tax credit was rightfully claimed in accordance with the provisions of the Act, and the same was duly supported by the filing of Form 67

MOOG MOTION CONTROLS PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BANGALORE

In the result, the appeal is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2019-20 M/S. Moog Motion Controls Pvt. Ltd., Acit, Site No.42-43, Doraisanipalya Circle – 4(1)(1), Village, Vs. Bengaluru. Opp. Oracle (Kalyani Magnum), Bilekahalli, Begur Hobli, Bengaluru – 560 076. Pan : Aadcm 3828 J Appellant Respondent Assessee By : Shri. Srinivas K. P, Ca Revenue By : Shri. V. Parithivel, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 20.03.2024 Date Of Pronouncement : 08.05.2024

disallowed if the assessee does not file Form 67 within the due date prescribed under section 139(1) of the Act. It was submitted

M/S SYNDICATE BANK,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, UDUPI

In the result, appeal of the revenue in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

67 (SC) it also argued that the term 'such debt' contained in proviso to Section 36(1)(vii) refers to the amount of provision allowed u/s 36(1)(viia) and hence, non-rural debts for which no deduction is allowed u/s 36(1)(viia) need not be adjusted against the provision created under that section and they should be allowed

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

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

1 of section 10AA without appreciating that the said Explanation is applicable only at the stage of allowing deduction under section 10AA from the total income and it is not applicable at the stage of computation of deduction under section 10AA in respect of profits of each SEZ unit. 2.3. On facts and circumstances of the case and law applicable

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

1)(iii) and general provisions of section 37. Therefore, no corresponding adjustment of interest income assessable in the hands of partners of the firm is permissible in the instant case, as the disallowance of interest has not been made under clause (b) of section 40 and as such, proviso to section 28(v) does not apply. This view has been

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

1)(iii) and general provisions of section 37. Therefore, no corresponding adjustment of interest income assessable in the hands of partners of the firm is permissible in the instant case, as the disallowance of interest has not been made under clause (b) of section 40 and as such, proviso to section 28(v) does not apply. This view has been

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

1)(iii) and general provisions of section 37. Therefore, no corresponding adjustment of interest income assessable in the hands of partners of the firm is permissible in the instant case, as the disallowance of interest has not been made under clause (b) of section 40 and as such, proviso to section 28(v) does not apply. This view has been

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

1)(iii) and general provisions of section 37. Therefore, no corresponding adjustment of interest income assessable in the hands of partners of the firm is permissible in the instant case, as the disallowance of interest has not been made under clause (b) of section 40 and as such, proviso to section 28(v) does not apply. This view has been

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

1)(iii) and general provisions of section 37. Therefore, no corresponding adjustment of interest income assessable in the hands of partners of the firm is permissible in the instant case, as the disallowance of interest has not been made under clause (b) of section 40 and as such, proviso to section 28(v) does not apply. This view has been

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

1)(iii) and general provisions of section 37. Therefore, no corresponding adjustment of interest income assessable in the hands of partners of the firm is permissible in the instant case, as the disallowance of interest has not been made under clause (b) of section 40 and as such, proviso to section 28(v) does not apply. This view has been

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