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

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

87\nТахтапn.Com 244\n(Karnataka)\nact.\nSharavathy\nConductors (P.)\nLtd.\nV.\nChief\nCommissioner\nof\nIncome-Tax,\nBengaluru-2*\nAssesse cited case deals\nwith condonation of delay\nin filing a revised return\nof\nincome\nfor\nthe\n Assessment Year 1997-98\nunder Section 119(2)(b) of\nthe Income" Tax Act, 1961.\nα\nThe petitioner, Sharavathy\nConductors

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)

87\nТахтапn.Com 244\n(Karnataka)\nSharavathy\nConductors (P.)\nLtd.\nV.\nChief\nCommissioner\nof\nIncome-Тах,\nBengaluru-2*\nAssesse cited case deals\nwith condonation of delay\nin filing a revised return\nof\nincome\nfor\nthe\n Assessment Year 1997-98\nunder Section 119(2)(b) of\nthe Income Tax Act, 1961.\nα\nThe petitioner, Sharavathy\nConductors (P.) Ltd., had\nfiled

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 made under section 10AA of the Act ignoring that since no new master service agreement was made, the benefit of claim u/s 10AA from the old SEZ cannot be allowed. 5. The CIT(A) erred in remitting the matter to assessing officer on issue relating to section 80G of the Act ignoring that in instant case assessee

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

disallowance made by the\nappellant.\n\n11. Insofar as the addition made based on the seizure of cash, the\nLd.CIT(A) had deleted the said addition for A.Y. 2020-21 on the ground that\nthe unaccounted sale of gunny bags were duly recorded and accounted for\nin the books and therefore no addition could be made u/s.69A

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

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 37 of the Act as it was incurred for the\npurpose of business. In other words, the learned Assessing Officer\nshould have restricted the disallowance to the amount of\nRs.2,52,14,792/- (Rs. 7,32,06,000 - Rs. 4,79,91,000).\nPage 10 of 15\nITA No.1067/Bang/2023\nBharat Electronics Limited, Bangalore\n7.5\nShe submitted the computation given

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

87,857 ITA Nos.1199, 1200/Bang/2025 Page 14 of 28 (vi) Contract from receipts from Shanti 1,21,17,822 Sadana (vii) Cash payment disallowance u/s 40A(3) of the Act Total Income assessed as per assessment order 1,65,00,980 u/s 147 3.4. The appellant aggrieved by the above addition and disallowance preferred an appeal before learned Commissioner

TEXO THE BUILDERS,UDUPI vs. ACIT, CENTRAL CIRCLE-2, MANGALORE

In the result, we dismiss grounds raised by the assessee

87,617/-. The break-up of the same is as under.\n\nParticulars\nTotal Income as per Return of Income\nAmount\n6,38,700\n\nAdd\n(iv) Unaccounted cash receipts\n(v) Unaccounted cheque receipts\n(vi) Contract from receipts from Shanti\nSadana\n(vii) Cash payment disallowance u/s 40A(3) of\nthe

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowed the sales promotion and advertisement expenses totally amounting to Rs. 44,33,55,403 [36,91,12,995 + 7,42,42,408] for the reason that these expenses are brand promotion expenditures of USL logo, it promotes the brand the assessee, gives enduring benefit and hence capital in nature. The DRP confirmed the action of the AO. 12.6.1 Similar

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowed the sales promotion and advertisement expenses totally amounting to Rs. 44,33,55,403 [36,91,12,995 + 7,42,42,408] for the reason that these expenses are brand promotion expenditures of USL logo, it promotes the brand the assessee, gives enduring benefit and hence capital in nature. The DRP confirmed the action of the AO. 12.6.1 Similar

JCIT, BANGALORE vs. M/S HEWLETT - PACKARD INDIA SALES PRIVATE LIMITED, BANGALORE

In the result, the appeal filed by the assessee stands allowed for statistical purposes and appeal filed by the revenue stands partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

87,209 account of goods: 5 Disallowances of other audit entries: 36,89,24,197 Page 8 ITA Nos. 579 & 593/Bang/2015 Disallowance of claim of deduction 6 40(a)(i) and 40(a)(ia) in the 52,58,75,221 computation of income: Disallowance of lease rental paid on 7 6,27,45,952 account of computers Disallowance of other

HEWLETT PACKARD INDIA SALES PVT. LTD.,,BANGALORE vs. JCIT, BANGALORE

In the result, the appeal filed by the assessee stands allowed for statistical purposes and appeal filed by the revenue stands partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

87,209 account of goods: 5 Disallowances of other audit entries: 36,89,24,197 Page 8 ITA Nos. 579 & 593/Bang/2015 Disallowance of claim of deduction 6 40(a)(i) and 40(a)(ia) in the 52,58,75,221 computation of income: Disallowance of lease rental paid on 7 6,27,45,952 account of computers Disallowance of other

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

disallowance made by the assessee under section 14A of the Act. During the impugned AY, the assessee had made investment and earned exempt income as under:- A. Investments Tax free bonds Rs. 5 crore Shares Rs.150.44 crores ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 24 of 46 Total investments Rs.155.44 crores B. Exempt income earned Dividend income Rs. 87

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

disallowance made by the assessee under section 14A of the Act. During the impugned AY, the assessee had made investment and earned exempt income as under:- A. Investments Tax free bonds Rs. 5 crore Shares Rs.150.44 crores ITA Nos.1107/Bang/2019 & 161/PAN/2019 Page 24 of 46 Total investments Rs.155.44 crores B. Exempt income earned Dividend income Rs. 87

ASHRAF NAFISA ALTHAF,MOODUBIDRI MANGALORE vs. INCOME TAX OFFICER, WARD-1 & TPS, UDUPI

In the result, the appeal of the assessee is dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

section 43B of the Act disallowed the same. The assessee carried the appeal before ld. CIT(A) and submitted that the assessee is following mercantile system of accounting. Though assessee collected service tax, on this amount he neither claimed any deduction nor debited the amount as an expenditure in the P&L account. As such, there could

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.

section 40A(7), the DRP upheld the addition proposed in the draft assessment order. 5. On receipt of the DRP directions, the Ld.AO passed the final assessment order by making following additions in the hands of the assessee. Total income as per Rs.39,82,64,080/- ITR Add: TP addition u/s Rs.7,87,77,217/- 92CA Add: Disallowance

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Disallowance under section 14A of the Act 59,87,469 Disallowance of digital media expenses 10,12,47,072 Disallowance

HUBLI ELECTRICITY SUPPLY ,HUBBALLI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), HUBALLI

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

disallow the corresponding payments (of Rs. 2,43,81,732/- + RS. 5,87,05,736 = 8,30,87,468/-) as mentioned below in accordance with the provisions of section