M/S. TATA ELXSI LIMITED,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

80A would clearly signify that such a\ndeduction has to be of gross profits and gains, i.e., before computing the income as\nspecified in Sections 30 to 43D of the Act.\n106. Thus, it has been urged by the assessee by way of the additional ground that the ld.\nCIT(A), Mumbai erred in allowing the deduction in respect

SRI. KALABHAIRAWESHWARA MULTI-PURPOSE CO-OP SOCIETY LTD., ,CHIKKAMAGALURU vs. INCOME TAX OFFICER, WARD-1, , CHIKKAMAGALURU

In the result, appeal filed by the assessee is dismissed

Bench: Shri George George K & Ms. Padmavathi. Sr Assessment Year : 2018-19 Sri Kalabhairaveshwara Multi-Purpose Co- Vs. Ito, Operative Society Ltd., Ward Officer, K. M. Road,Chikmagalur District Office Ward – 1, S. O. 577 101, Karnataka. Chikmagaluru. Pan : Aapas 3058 L Appellant Respondent Assessee By : Shri. Mahesh R. Uppin, Advocate Revenue By : Ms. Neha Sahay, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 16.10.2024 Date Of Pronouncement : 17.10.2024

disallowance of deduction claimed u/s. 80P of the Act by virtue of provision contained in Sec. 80AC of the Act was left out to be pleaded in the grounds of appeal before the First Appellate Authority due to oversight. The belated filing of ITR will not disentitle the appellant from claiming the benefit u/s. 80P of the Act as held

PRIMARY AGRICULTURE COOPERATIVE CREDIT SOCIETY LIMITED, ADARAKATTI,LAKSHMESHWAR TALUK GADAG DISTRICT vs. INCOME TAX OFFICER WARD 1, GADAG

In the result, the appeal of the assessee is dismissed

Bench: Shri Waseem Ahmed

80A. (1) In computing the total income of an assessee, there shall be allowed from his gross total income, in accordance with and subject to the provisions of this Chapter, the deductions specified in sections 80C to 83 [80U] ... (5) Where the assessee fails to make a claim in his return of income for any deduction under section

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

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

BELVE VYAVASAYA SEVA SAHAKARI SANGHA LIMITED ,UDUPI vs. INCOME TAX OFFICER, WARD-2, UDUPI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

80A(5) of the Act provides that the no deduction under section 80P of the Act shall be allowed in case where the assessee fails to claim the same in the return of income. In this case, the assessee has not filed return of income with the prescribed time allowed under section 139(1), 139(4) or within the time

BELVE VYAVASAYA SEVA SAHAKARI SANGHA LIMITED,UDUPI vs. INCOME TAX OFFICER, WARD-2, UDUPI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

80A(5) of the Act provides that the no deduction under section 80P of the Act shall be allowed in case where the assessee fails to claim the same in the return of income. In this case, the assessee has not filed return of income with the prescribed time allowed under section 139(1), 139(4) or within the time

M/S. ALLSTATE INDIA PRIVATE LIMITED ,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year: 2018-19

80A(1) stipulates that in computing the total income of an assessee, there shall be allowed from his gross total income, in accordance with and subject to the provisions of the Chapter, the deductions specified in Sections 80C to 80U. Section 80B(5) defines for the purposes of Chapter VIA "gross total income" to mean the total income computed

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

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2013-14

disallowance of deduction under section 10AA: 2.1. The learned Deputy Commissioner of Income Tax, Circle 3(1)(1), Bengaluru ('AO') and the CIT(A) have erred in not allowing the following incomes from profits of the business of SEZ units in computing deduction under section 10AA for the reason that the said claim had been raised for the first time

KALIA SERVICE CO-OP BANK,BELHANGADY vs. INCOME-TAX OFFICER, WARD-1, PUTTUR

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

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2012-13

80A(5), the claim for deduction under section 80P could be made by an assessee in a return filed within the time prescribed for filing such returns under any of the above provisions. The amendment to Section 80AC with effect from 01-04-2018, however, mandated that for an assessee to get a deduction under section

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

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

disallowed by the learned CIT(A) by holding that the assessee has not claimed deduction under section 10AA of the Act on these items in the return of income. Therefore in pursuance to the provision section 80A(5) of the Act, no deduction under section 10AA of the Act, be allowed in absence of claim made in the return

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE JOINT COMMISSIONER OF INCOME TAX, LARGE TAX PAYERS UNIT, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

80A(4) of the Act, the ld. CIT(A) opined that no further deduction under Section 80JJAA could be allowed for units whose profits were already claimed as exempt under Sections 10A or 10AA of the Act. Consequently, the ld. CIT(A) disallowed the claim for these units. 8.5 The ld. CIT(A) further disallowed the deduction under Section 80JJAA

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2, LTU, BENGALURU vs. M/S. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

80A(4) of the Act, the ld. CIT(A) opined that no further deduction under Section 80JJAA could be allowed for units whose profits were already claimed as exempt under Sections 10A or 10AA of the Act. Consequently, the ld. CIT(A) disallowed the claim for these units. 8.5 The ld. CIT(A) further disallowed the deduction under Section 80JJAA

SRITHERUMALLESHWARA CO-OPERATIVE SOCIETY ,CHITRADURGA vs. INCOME-TAX OFFICER, WARD-1, , CHITRADURGA

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

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2017-18

disallowing the cash deposits during the demonetization period. The AO did not ask further details. If he had any doubt, he should have issued notice further. The CIT(Appeals) has relied on the order in ITA No.329/Bang/2023 dated 14.8.2023 and confirmed the addition. He further submitted that deduction u/s. 80P(2)(a)(i) should also be given to the assessee

SHRI. DUNICHAND KHITRI RAJA,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CPC, , BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Chandra Poojari & Shri George George Kassessment Year : 2019-20 Shri. Dunichand Khitri Raja, The Assistant Commissioner Of #304, 16Th Cross, Sadashivnagar, Income Tax, Bengaluru – 560 080. Vs. Cpc, Pan : Addpr 6538 G Bengaluru. Appellant Respondent Assessee By : Shri. Ankit, Ca Revenue By : Shri. Sankar Ganesh K, Addl. Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 07.06.2023 Date Of Pronouncement : 07.06.2023

1) in accordance with the provisions of section 80A(5). d) Without prejudice, the belated filing of the form, if any, is merely a procedural error and cannot be a ground to bar the claim of deduction under section 80- IA of the Act; 2.3. On the facts and circumstances of the case and in law', the disallowance

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

80A; IT(TP)A No.370/Bang/2021 Page 33 of 110 (iii) any transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-IA; (v) any transaction, referred to in any other section under Chapter

M/S BHUWALKA STEEL INDUSTRIES LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-1(1)(4), BANGALORE

In the result, appeal by the assessee is allowed for statistical purposes

Bench: Shri George George K & Shri Laxmi Prasad Sahu

disallowance of expenses etc. as required under provisions of sections 40A, 80-IA, 10AA, 80A, sections where reference is made to section 80-IA, or to transactions as may be prescribed by the Board, if aggregate amount of all such domestic transactions exceeds Rupees 5 crore in a year. It is further proposed to amend the meaning of related persons

M/S. BHUWALKA STEEL INDUSTRIES LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(2), BANGALORE

In the result, appeal by the assessee is allowed for statistical purposes

Bench: Shri George George K & Shri Laxmi Prasad Sahu

disallowance of expenses etc. as required under provisions of sections 40A, 80-IA, 10AA, 80A, sections where reference is made to section 80-IA, or to transactions as may be prescribed by the Board, if aggregate amount of all such domestic transactions exceeds Rupees 5 crore in a year. It is further proposed to amend the meaning of related persons