THE KARNATAKA STATE COOPERATIVE AGRICULTURE AND DEVELOPMENT BANK LIMITED ,BANGLAORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2022-23

disallowance made u/s. 80P(2)(d) by the authorities below, the word 'attributable' used in the said Section is of great importance. Hon’ble Supreme Court considered the meaning of the word 'attributable' as supposed to derive from its use in various other provisions of . Page 17 of 38 the statute, in the case of Cambay Electric Supply Industrial

INCOME TAX OFFICER WARD-1, BAGALKOT vs. SHRI BAPOOJI PATTIN SOUHARD SAHAKARI NIYAMIT , BAGALKOT

Bench: Shri Inturi Rama Rao & Shri Laliet Kumarassessment Year : 2013-14

disallowing Pigmi commission on the ground that no TDS was made of Rs.1,70,46,946. The AO denied the exemption u/s. 80P on the ground that the respondent-assessee society is a bank and is hit by the provisions of sub-section (4) of section 80P of the Act. IT(TP)A No.309/Bang/2014 Page 3 of 12 4. Being

JCIT, BANGALORE vs. M/S BHUWALKA PIPES PVT. LTD.,, BANGALORE

In the result, the appeal filed by the revenue is allowed

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raojoint Commissioner Of Income-Tax (Osd), Circle 1(1)(2), Bengaluru. … Appellant Vs. M/S.Bhuwalka Pipes Pvt. Ltd. ‘Solus’, 8Th Floor, E & G, No.2 1St Cross Road, Jc Road, Bengaluru-560027. … Respondent Pan: Aabcb 7778 E

disallowed by giving reasons, the claim cannot be allowed in the proceedings u/s 154. Reliance in this regard is placed on the decision of the Hon’ble Madhya Pradesh High Court in the case of Amolakchand Kewalchand vs. CIT (188 ITR 127), Parshuram Pottery Works Co. Ltd. vs. WTO (100 ITR 651)(Guj), Bhagwandas Kevaldas vs. N.D.Mehrotra

ACIT, BANGALORE vs. SUTURES INDIA PRIVATE LIMITED, BANGALORE

In the result, the appeal of revenue is allowed

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

disallowance made by the Assessing Officer is nothing but the decision taken by the Commissioner in the revision order under Section 263 which has been upheld by this Tribunal. Accordingly, the CIT (Appeals) had no jurisdiction to entertain and adjudicate the said issue on merits. Thus the learned Departmental Representative has submitted that the CIT (Appeals) has passed the impugned

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

disallow depreciation on such capitalized amount as the aforesaid provision does not deal with deduction of depreciation. Having considered arguments from both the sides, we are of the view that there is no error in the order of the learned CIT(A) which requires correction from us. Thus, this ground is also dismissed." Following the decision rendered by the coordinate

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

disallow depreciation on such capitalized amount as the aforesaid provision does not deal with deduction of depreciation. Having considered arguments from both the sides, we are of the view that there is no error in the order of the learned CIT(A) which requires correction from us. Thus, this ground is also dismissed." Following the decision rendered by the coordinate

M/S I G PETROCHEMICALS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the disallowance u/s 40(a)(i) of the I

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

80J was replaced by section 80IA of the I.T.Act). 5.3 The learned Departmental Representative supported the orders of the Income Tax Authorities. 5.4 We have heard rival submissions and perused the material on record. The assessee has submitted that it is eligible for claim deduction under section 80lA of the I.T.Act in respect of the power generation unit

M/S.L.G PETROCHEMICALS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the disallowance u/s 40(a)(i) of the I

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

80J was replaced by section 80IA of the I.T.Act). 5.3 The learned Departmental Representative supported the orders of the Income Tax Authorities. 5.4 We have heard rival submissions and perused the material on record. The assessee has submitted that it is eligible for claim deduction under section 80lA of the I.T.Act in respect of the power generation unit

M/S.L.G PETROCHEMICALS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the disallowance u/s 40(a)(i) of the I

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

80J was replaced by section 80IA of the I.T.Act). 5.3 The learned Departmental Representative supported the orders of the Income Tax Authorities. 5.4 We have heard rival submissions and perused the material on record. The assessee has submitted that it is eligible for claim deduction under section 80lA of the I.T.Act in respect of the power generation unit

M/S.L.G PETROCHEMICALS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the disallowance u/s 40(a)(i) of the I

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

80J was replaced by section 80IA of the I.T.Act). 5.3 The learned Departmental Representative supported the orders of the Income Tax Authorities. 5.4 We have heard rival submissions and perused the material on record. The assessee has submitted that it is eligible for claim deduction under section 80lA of the I.T.Act in respect of the power generation unit

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE vs. M/S COFFEEDAY GLOBAL LIMITED , BANGALORE

In the result, the appeals of the Revenue are partly allowed

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

disallowing the same. 6. On appeal, the CIT(A) after considering the submissions of the assessee held that the company was eligible for additional depreciation as claimed and directed that the same be allowed. According to the CIT(A), under the circumstances, converting raw coffee beans which are not fit for human consumption as such to 'liquid coffee' which

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE vs. M/S COFFEEDAY GLOBAL LIMITED , BANGALORE

In the result, the appeals of the Revenue are partly allowed

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

disallowing the same. 6. On appeal, the CIT(A) after considering the submissions of the assessee held that the company was eligible for additional depreciation as claimed and directed that the same be allowed. According to the CIT(A), under the circumstances, converting raw coffee beans which are not fit for human consumption as such to 'liquid coffee' which

INCOME TAX OFFICER,WARD-1, HOSPET vs. GAYATRI PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA, HOSPET, HOSPET

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowance u/s 80P(2)(d) of the Act as the interest income has been earned from investment in FDs with Co-operative banks/other banks. Further, the ld. DR relied on the decision of Hon'ble High Court of Karnataka Dharwad Division Bench in the case of Pr. CIT Hubballi Vs. Totgar's Co-operative Sale Society Ltd, Sirsi

SHELL APPARELS PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes in the terms indicated above

Bench: Shri Arun Kumar Garodiaassessment Year : 2004-05

disallowance of deduction u/s 80IB to the extent of Rs.5,03,414 and computing the total income of Rs.15,92,490 as against returned income of Rs.10,89,075. 3. That the learned Commissioner of Income Tax (Appeals) erred in law and on facts in not allowing the deduction u/s 80IB to the extent of Rs.5,03,414. Page

IBM GLOBAL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2000-2001

disallowance made in the assessment order was denying exemption claimed u/s. 10A of the act on the ground that, the export turnover brought into India does not amount to 75 percent of the total turnover of the STP unit. It was submitted by the assessee that, it treated export credits of the bank account maintained

SHRI. S.M.REVANA SIDDAIAH, CEO,,BELLARY vs. COMMISSIONER OF INCOME TAX, GULBARGA

In the result, the appeals of the assessees are allowed

Bench: Shri Vijay Pal Rao

disallowance of claim of Section 80P of the Income Tax Act, 1961 (in short 'the Act') in respect of the interest on Fixed Deposits with the Bank. The assessee is a co-operative society which provides credit facilities to the farmers. The assessee earned interest on fixed deposits from SBI, Agriculture Development Bank, Station Road Branch, Bellary. The assessee claimed

M/S. JEANS KNIT PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Ms. Padmavathy Sassessment Year : 2012-13

disallowance of deduction u/s 80JJAA of the Act. The assessee while filing the return of income has claimed deduction of Rs.94/- u/s 80JJAA of the Act. During the course of asst. proceedings, the assessee revised the claim u/s 80JJAA of the Act to Rs.7,99,50,456/-stating that in the return of income the deduction was inadvertently claimed

JAMMANAHALLY PRATHAMIKA KRISHI PATTINA SAHAKARA SANGHA,BALLUPET vs. INCOME TAX OFFICER, WARD-2, HASSAN

In the result ITA No. 192/Bangalore/2025 filed by the assessee is allowed

Bench: Shri Prashant Maharishi

disallowance for one reason that the assessee did not appear before the learned CIT A despite given many opportunities for the hearing, holding as under :- "DECISION: As per the income and expenditure statement submitted, the assesse has declared income on deposits of Rs. 36,58,271/-. Hence, it is evident that the assesse is having interest income, which

JAMMANAHALLY PRATHAMIKA KRISHI PATTINA SAHAKARA SANGHA,SAKLESHPUR vs. INCOME TAX OFFICER, WARD -2, HASSAN

In the result ITA No. 192/Bangalore/2025 filed by the assessee is allowed

Bench: Shri Prashant Maharishi

disallowance for one reason that the assessee did not appear before the learned CIT A despite given many opportunities for the hearing, holding as under :- "DECISION: As per the income and expenditure statement submitted, the assesse has declared income on deposits of Rs. 36,58,271/-. Hence, it is evident that the assesse is having interest income, which