BRIGADE ENTERPRISES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), BANGALORE

In the result, the assessee’s appeals for assessment years 2008-09 to 2010-11 are partly allowed for statistical purposes

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

7 of 22 3.3 Assessment Year 2010-11 General:- The order passed by the learned CIT(A) to the extent 1. prejudicial to the appellant is bad in law and liable to be quashed. Disallowance under section

M/S KBD SUGARS & DISTILLERIES LTD. vs. ACIT,

In the result, the appeals of the assessee for the Assessment Years 2008-

disallowance made by the ld. Authorities below is highly excessive and the same requires to be reduced substantially under the facts and circumstances of the case. 6. The appellant denies itself liable to be charged interest under Sections 234B and 234D of the Act under the facts and circumstances of the case. 7

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 14A and computed the total disallowance at Rs. 8,02,96,882/-. Since Rs. 37,16,131/- was already disallowed by the assessee itself in the return, the balance amount i.e. Rs. 7

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 14A and computed the total disallowance at Rs. 8,02,96,882/-. Since Rs. 37,16,131/- was already disallowed by the assessee itself in the return, the balance amount i.e. Rs. 7

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T, BANGALORE

In the result, Revenue’s appeal for A

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

disallowance under Section 40(a)(i) of the Act of the payments made by the assessee to 8 IT(TP)A Nos.102 & 233/Bang/2013 Infosys Limited Forrester Research Inc., USA for non-deduction of tax at source under Section 195 of the Act. Finding no merit in this Ground No.2.1 raised by the assessee, we dismiss the same. 7

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 40(a)(ia) amounting to INR 7,34,77,951 by observing that TDS was not made

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

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

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

7 IT(TP)A No. 718/Bang/2017 Grounds on reduction of receipts from sale of scrap from profits of SEZ units while computing deduction under section 10AA 35. The learned assessing officer has erred in reducing receipts from sale of scrap amounting to Rs.6,54,378 from profits of SEZ unit at Trivandrum while computing deduction under section 10AA

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)

7\nV.\nOptimal Media\nSolutions Ltd.\nThe case law citied by the\nAssesse, The Head Note\nwhich reads below Section\n14A of the Income-tax Act,\n1961, read with rule 8D of\nthe Income-tax Rules,\n1962 - Expenditure incurred\nin relation to income not\nincludible in total income\n(Quantum of disallowance

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

7\nV.\nOptimal Media\nSolutions Ltd.\nITA Nos. 642 to 645/Bang/2024\nThe case law citied by the\nAssesse, The Head Note\nwhich reads below Section\n14A of the Income-tax Act,\n1961, read with rule 8D of\nthe Income-tax Rules,\n1962 - Expenditure incurred\nin relation to income not\nincludible in total income\n(Quantum of disallowance

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 14A of the act. ITA Nos.60/Bang/2012, 253/Bang/2014, 282/Bang/2012 Page 7 of 23 3. Though various grounds are raised but they are mainly related on two issues. First issue is regarding the calculation of disallowance

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 14A of the act. ITA Nos.60/Bang/2012, 253/Bang/2014, 282/Bang/2012 Page 7 of 23 3. Though various grounds are raised but they are mainly related on two issues. First issue is regarding the calculation of disallowance

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 14A of the act. ITA Nos.60/Bang/2012, 253/Bang/2014, 282/Bang/2012 Page 7 of 23 3. Though various grounds are raised but they are mainly related on two issues. First issue is regarding the calculation of disallowance

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED ,MANGALURU vs. ASSISTANT COMMISIONER OF INCOME TAX, CIRCLE - 2(1) , MANGALURU

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Soundararajan K.\Nita Nos.642 To 645/Bang/2024\N Assessment Years : 2017-18 To\N2020-21\Nm/S. Bharat Beedi Works\Nprivate Limited,\Ngolden Jubilee Building,\Nbharath Bagh,\Nkadri Road,\Nmangaluru – 575 002.\Npan: Aaacb9001B\Nappellant\Nassessee By\Nrevenue By\N: Shri Chythanya .K, Sr.\Nadvocate\N: Shri E. Shridhar, Cit-Dr\Ndate Of Hearing\Ndate Of Pronouncement\Norder\Nper Bench\Nthese Are The Appeals Filed By The Assessee Challenging The Orders Of\Nthe Ld.Cit(A) -2, Panaji Dated 30/01/2024 In Respect Of The A.Ys.2017-18,\N2018-19, 2019-20 & 2020-21. The Grounds Raised By The Assessee For\Neach Of The Assessment Years Are Extracted Hereunder For The Sack Of\Nconvenience.\Npage 2 Of 74\Nita Nos.642 To 645/Bang/2024\N Assessment Year 2017-18:\N“1. The Impugned Orders Of The Lower Authorities Are Not\Njustified In Law & On The Facts & Circumstances Of The\Ncase.\N2. The Impugned Assessment Proceedings & The\Nimpugned Assessment Order Under Section 143(3) Dated\N29.11.2021 Are Bad & Non-Est Since The Notice Under\Nsection 143(2) Dated 13.08.2018 Was Issued Without\Naffixing Any Signature Either Manually Or Digitally.\N3. Without Prejudice To The Above, Impugned Assessment\Nproceedings & The Impugned Assessment Order Under\Nsection 143(3) Dated 29.11.2021 Are Bad & Non-Est\Nbeing Based On The Notice Under Section 143(2) Dated\N13.08.2018 Which Is Vague, Without Of Application Of Mind\Nand Contrary To Section 143(2) & Applicable Board\Ncirculars & Instructions.\N4. As Regards Disallowance Under Section 14A U/S Rule\N8D(2)(Ii):\N4.

disallowance of\nRs.11,81,121/- under Section 14A in the return, they\nblindly taxed the non-existent income reflected in the\nrevised returns filed for the AYs 2019-20 and 2020-21 and\nthe belated return filed for AY 2019-20.\n4. 7

M/S. HICAL INFRA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (OSD), RANGE- 1, BANGALORE

In the result, the appeal by the assessee is allowed

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2016-17

section 234B and 234C is not leviable. The assessee denies its liability to pay interest.” 7. Ground No.1 is general and Ground No.4 is consequential. These grounds do not warrant a separate adjudication. Ground No. 3 and 4 are adjudicated in the following paragraphs. Disallowance

M/S. MOBILY INFOTECH INDIA PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD-4(1)(3), BANGALORE

In the result, the appeal by the assessee is allowed

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2016-17

section 234B and 234C is not leviable. The assessee denies its liability to pay interest.” 7. Ground No.1 is general and Ground No.4 is consequential. These grounds do not warrant a separate adjudication. Ground No. 3 and 4 are adjudicated in the following paragraphs. Disallowance

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

section 32AC of the Act, the aforesaid sum would be liable for tax. Without properly appreciating the above, revenue’s ground no 7 seeks to challenge the relief allowed by CIT(A)/NFAC amounting to Rs. 10,78,69,095/- for the reason that the disallowance

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

7\nV.\nOptimal Media\nSolutions Ltd.\nThe case law citied by the\nAssesse, The Head Note\nwhich reads below Section\n14A of the Income-tax Act,\n1961, read with rule 8D of\nthe Income-tax Rules,\n1962 - Expenditure incurred\nin relation to income not\nincludible in total income\n(Quantum of disallowance

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result, Revenue’s appeal for Assessment Year 2006-07 is partly allowed for statistical purposes

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

disallowance under Section 40(a)(i) of the Act of the payments made by the assessee to Forrester Research Inc., USA and Meta for non-deduction of tax at source under Section 195 of the Act. Finding no merit in this Ground No.2.1 to 2.4 raised by the assessee, we dismiss the same. 7