M/S. PEAK XV PARTNERS ADVISORS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

In the result appeal filed by assessee stands allowed

sections": [ "80G", "37(1)", "250", "143(2)", "142(1)", "135", "234A", "234C", "30", "31", "32", "33", "34", "35", "35CCD", "36", "80G(1)(i)", "80G(2)", "80G(5)" ], "issues": "Whether donations made towards Corporate Social Responsibility (CSR) activities, 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

section 80G of the Act 4.1 The Honorable DRP and the learned AO have erred in law and on facts in disallowing an amount of INR 2

M/S. PEAK XV PARTNERS ADVISORS PRIVATE LIMITED, ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

In the result, both the appeals of the assessee are allowed

disallowance of CSR expenditure\nunder explanation 2 to section 37(1) of the Act applies only in the\ncontext of determining its income from business and does not\npreclude an assessee from claiming deduction under Chapter VIA\n(which includes section 80G

NORTHERN OPERATING SERVICES PRIVATE LIMITED,ARGON SOUTH TOWER vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 5 (1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2020-21 M/S. Northern Operating Services Pvt. Ltd., Vs. Dcit, 2Nd Floor Rmz Ecopace, Circle – 5(1)(1), Campus 1C, Bengaluru. Sarjapur Outer Ring Road, Bellandur, Bengaluru – 560 103. Pan : Aaccn 1652 J Appellant Respondent Assessee By : Ms. Divya Motwani, Ca. Revenue By : Shri. D. K. Mishra, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 26.09.2024 Date Of Pronouncement : 27.09.2024

2. The solitary issue that is raised is whether the authorities below were justified in disallowing the claim of deduction under section 80G

JSW INDUSTRIAL GASES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(3)(1), BENGALURU, BENGALURU

In the result, appeal filed by the assessee is allowed

disallowance of CSR expenditure under explanation 2 to section 37(1) of the Act applies only in the context of determining its income from business and does not preclude an assessee from claiming deduction under Chapter VIA (which includes section 80G

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

2. The CIT(A) erred in directing the assessing authority to delete disallowance made under section 14A r.w. Rule 8D (iii) of ignoring that conditions for invoking said section are fully satisfied in instant case and CIT(A) has also ignored the circular No.5/2014, dated 11 February 2014 which has clarified that Rule 8D of the Rules read with section

FINASTRA SOFTWARE SOLUTIONS (INDIA) PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands allowed as indicated hereinabove

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No. 189/Bang/2022 Assessment Year : 2017-18 M/S. Finastra Software Solutions (India) Pvt. Ltd., 4Th To 6Th Floor, Virgo The Deputy Building, Bagmane Commissioner Of Constellation Income Tax, Business Park Outer Circle – 3 (1)(1), Ring Road, Vs. Bangalore. Dodanekundi, Bangalore. Pan: Aaack9067G Appellant Respondent : Smt. Tanmayee Rajkumar, Assessee By Advocate Revenue By : Ms. Neera Malhotra, Cit-Dr Date Of Hearing : 01-03-2023 Date Of Pronouncement : 31-05-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 27.01.2022 For A.Y. 2017-18 On Following Grounds Of Appeal: “1. The Impugned Final Assessment Order Dated 27.01.2022 Was Not Communicated In The Manner Prescribed Under The Income-Tax Act, 1961 & The Rules Made Thereunder & Therefore The Proceedings Are Null & Void.

disallowed by new Explanation 2 to section 37(1), while computing Income under the Head 'Income form Business and Profession'. Further, clarification regarding impact of Explanation 2 to section 37(1) of the Income Tax Act in Explanatory Memorandum to The Finance (No.2) Bill, 2014 is as under: "The existing provisions of section 37(1) of the Act provide that

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 made under section\n10AA of the Act ignoring that since no new master service agreement was\nmade, the benefit of claim u/s 10AA from the old SEZ cannot be allowed.\n\n5.\nThe CIT(A) erred in remitting the matter to assessing officer on issue\nrelating to section 80G of the Act ignoring that in instant case assessee

M/S. NAVODAYA GRAMA VIKAS CHARITABLE TRUST,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, BANGALORE

In the result, the appeal filed by assessee stands allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18 M/S. Navodaya Grama Vikas Charitable Trust, The Deputy #14-7-1005, Scdcc Commissioner Of Bank Ltd., Income Tax, Head Office Building, Central Circle – 1, Kodialbail, Vs. Mangaluru. Mangaluru – 575 003. Pan: Aaatn7594E Appellant Respondent : Shri V. Srinivasan, Advocate & Assessee By Ms. Sunaina Bhatia, Ca Revenue By : Shri D.K. Mishra, Cit Dr Date Of Hearing : 07-07-2023 Date Of Pronouncement : 31-08-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 07.03.2022 Passed By Ld.Cit(A)-2, Panaji For A.Y. 2017-18 On Following Grounds Of Appeal: “1. The Orders Of The Authorities Below In So Far As They Are Against The Appellant Are Opposed To Law. Equity, Weight Of Evidence. Probabilities, Facts & Circumstances Of The Case. 2. The Learned Cit [A] Is Not Justified In Upholding The Disallowance Of The Exemption Claimed U/S.11 Of The Act

disallowance of exemption claimed by the assessee u/s. 11 of the Act. The Ld.AR submitted that the assessee is engaged in the charitable activity of relief to the poor by forming Self Help Groups (SHG) of the rural poor and encouraging them to become financially self-sufficient. He submitted that the modus operandi followed by the assessee is to advance

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

80G of the Act but if it could be termed as an expenditure of the category falling under section 37(1) of the Act, then the right of the assessee to claim the whole of it as allowance under section 37(1) of the Act cannot be denied but such money must be laid out wholly or exclusively

SRI SRINIVASA TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

2(i) and (ii) is that the Ld. CIT(A) erred in disallowing the donation and other expenses of Rs. 36,21,782.00 only. 3. Briefly stated, the facts are that the assessee is a charitable trust, duly recognized and registered under section 12A as well as section 80G

SRI SRINIVASA TRUST,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

2(i) and (ii) is that the Ld. CIT(A) erred in disallowing the donation and other expenses of Rs. 36,21,782.00 only. 3. Briefly stated, the facts are that the assessee is a charitable trust, duly recognized and registered under section 12A as well as section 80G

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

disallowance of the exemption claimed under section n of the Act, on the ground that the activities of the appellant are hit by the proviso to section 2(15) of the Act on the facts and circumstances of the case. ITA Nos.744 & 745/Bang/2023 Sanghamitra Rural Financial Services, Bangalore Page 2 of 54 4. The authorities below failed to appreciate that

DIVYA DINESH ,BENGALURU vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result appeal of the assessee is allowed

disallowance of set off of short-term capital\nloss, the gross total income increased. As per section 80G(4) of the Act,\nthe donation in excess of 10% of the gross total income has to be\nignored while computing the deduction. Since the gross total income was\nrecomputed, the allowable deduction under section 80G was correctly\nrestricted

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

disallowance of the\nexemption claimed under section n of the Act, on the ground that the activities\nof the appellant are hit by the proviso to section 2(15) of the Act on the facts\nand circumstances of the case.\n4. The authorities below failed to appreciate that the activities of the appellant fell\nunder \"relief to poor\" and thus

ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION) CIRCLE-1, UNITY BUILDING ANNEX vs. MYMUL RAITHA KALYANA TRUST, SIDDARATHANAGAR

In the result, the appeal of the Revenue in ITA\nNo

80G", "Section 234B", "Rule 46A" ], "issues": "Whether the assessee's activities constitute charitable purposes under Section 2(15) and are eligible for exemption under Section 11. Whether the expenditure on mementoes is to be disallowed

DIVYA DINESH ,BENGALURU vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowance of set off of short-term capital loss, the gross total income increased. As per section 80G(4) of the Act, the donation in excess of 10% of the gross total income has to be ignored while computing the deduction. Since the gross total income was recomputed, the allowable deduction under section 80G was correctly restricted

SASKEN FOUNDATION ,BANGALORE vs. INCOME TAX OFFICER, WARD-1, EXEMPTIONS, , BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2018-19

disallowing the accumulation of income under section 11 (2) amounting to Rs. 77,12,882 by the learned AO and CIT(A) are bad law and liable to be quashed. 2.4. On facts and circumstances of the case and law applicable, accumulation of income under section 11 (2) amounting to Rs. 77, 12,882 should be allowed as claimed