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)

8. Without prejudice, the Learned AO erred in\nmaking addition of Rs.18,70,77,583/- to the closing stock\nby applying section 145A read with ICDS II making\ncorresponding adjustment to the opening stock.\n14. As regards ad-hoc disallowance

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

8 of 74\nITA Nos. 642 to 645/Bang/2024\nCircle 2 vide order of centralization of the Principal CIT,\nMangalore dated 28.07.2021.\n2.3. Without prejudice to the above, the proceedings\nunder Section 153A and the impugned order under Section\n153A dated 29.09.2021 are bad and non-est as the notice\nunder Section 143(2) dated 27.02.2021 was issued by the\nLearned

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.

8. Without prejudice, the Learned AO erred in\nmaking addition of Rs.18,70,77,583/- to the closing stock\nby applying section 145A read with ICDS II making\ncorresponding adjustment to the opening stock.\n14. As regards ad-hoc disallowance

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

disallowances made by the AO were deleted, and the assessee's claim for exemption under Section 11 was upheld.", "result": "Allowed", "sections": [ "Section 11", "Section 13(8

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

8).\n4.2 The learned AO and CIT(A) erred in not appreciating\nthat Explanation 3 to section 11(1) only applies sections\n40(a)(ia), 40A(3)/(3A) in computing application of income\nfrom AY 2019-20 onwards. Hence, section 43B does not\napply.\n4.3 Without prejudice, the learned CIT(A) erred in\nconfirming the addition / 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

disallowance of deduction under section 32AC of the Act is confirmed by CIT(A) and ITAT for ITA No.245/Bang/2024 Infosys Limited Page 34 of 34 the earlier years. Thus, there is no merit in the revenue’s Ground No 7 and is accordingly dismissed. 22. The Ground No 8

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

8. Without prejudice, the Learned AO erred in\nmaking addition of Rs.18,70,77,583/- to the closing stock\nby applying section 145A read with ICDS II making\ncorresponding adjustment to the opening stock.\n\n14. As regards ad-hoc disallowance

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 of deduction claimed under section 10AA of the Act — Chennai SEZ unit - Rs. 181,403,235 a) The Ld. AO has erred in denying the deduction under Section 10AA of the Act amounting to Rs.181,403,235 claimed by the Appellant, by relying on the assessment order and order of Commissioner of Income-tax (Appeals

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 14A of the Act.\n4.7\nIt is hence submitted by the 1d. A.R. that the learned CIT(A) has\nfailed to appreciate that since no income was received from any other\nPage 6 of 15\nITA No.1067/Bang/2023\nBharat Electronics Limited, Bangalore\ninvestments, the same cannot be considered while computing the\nquantum of disallowance under Rule 8

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 of\ndeduction under section 32AC of the Act is confirmed by CIT(A) and ITAT for\n\nPage 34 of 34\n\nthe earlier years. Thus, there is no merit in the revenue's Ground No 7 and\nis accordingly dismissed.\n\n22. The Ground No 8

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, , BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No:Aaajk0398K\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

8) are inapplicable and consequently exemption under section 11 is to be allowed as claimed by the appellant.\n\n3. Levy of interest under section 234A and 234B\n\n6.1 The learned CIT(A), NFAC erred in confirming the levy of interest under section 234A and 234B of the Act. On facts and circumstances of the case and law applicable

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

8. Further in respect of balance amount, assessee has clearly violated the provisions of section 40A(3) of the Act. Therefore, same was disallowed

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubey

8 of 14 3.7 The Honorable DRP and the Learned AO have erred in law and on facts in upholding the requirement of TDS under section 195 of the Act despite the salary payments having already suffered TDS under section 192 of the Act, giving rise to double taxation on the same transaction. 4. Disallowance

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No :Aaajk0398K\Nappellant\Nrespondent\N\Nappellant By\Nrespondent By\N: Sri Padamchand Khincha, A.R.\N: Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing\N: 17.09.2025\Ndate Of Pronouncement\N: 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed\Nagainst The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide\Ndin & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For\Nthe Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With\Ndin & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For\Nthe Assessment Year 2015-16 Passed U/S 250 Of The Income Tax\Nact, 1961 (In Short “The Act”). Since The Issues In Both The Appeals\Nare Similar, These Are Clubbed Together, Heard Together And\Ndisposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025\Nfor The Assessment Year 2021-22 For Adjudication. The Assessee\Nhas Raised The Following Grounds Of Appeal:\N\N1. General Ground\N1.

8) are inapplicable and consequently exemption under section 11 is to be\nallowed as claimed by the appellant.\n\n3. Levy of interest under section 234A and 234B\n6.1 The learned CIT(A), NFAC erred in confirming the levy of interest under section 234A and\n234B of the Act. On facts and circumstances of the case and law applicable, interest

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

8,19,56,557/- 4,89,13,370/- 3. 2015-16 (-) 9,15,43,286/- 5,36,92,085/- Total 15,06,05,455/- (ii) Century Silicon City, Bangalore: Sl.No. Assessment Declared income Claim of year (Loss) (Rs.) payment of interest

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

8,19,56,557/- 4,89,13,370/- 3. 2015-16 (-) 9,15,43,286/- 5,36,92,085/- Total 15,06,05,455/- (ii) Century Silicon City, Bangalore: Sl.No. Assessment Declared income Claim of year (Loss) (Rs.) payment of interest

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

8,19,56,557/- 4,89,13,370/- 3. 2015-16 (-) 9,15,43,286/- 5,36,92,085/- Total 15,06,05,455/- (ii) Century Silicon City, Bangalore: Sl.No. Assessment Declared income Claim of year (Loss) (Rs.) payment of interest

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

8,19,56,557/- 4,89,13,370/- 3. 2015-16 (-) 9,15,43,286/- 5,36,92,085/- Total 15,06,05,455/- (ii) Century Silicon City, Bangalore: Sl.No. Assessment Declared income Claim of year (Loss) (Rs.) payment of interest