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

disallowance under section 14A should be made as per Rule 8D. 8.3. The DRP confirmed the disallowance under section 14A as per Rule

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)

8D(2)(ii) on the\nwrong notion that the disallowance is presumptive in\nnature even when the expenditure is not actually incurred.\n4. 6. Without prejudice, the Lower Authorities were not\njustified in acting inconsistently in as much as while they\nchose to disturb the voluntary disallowance of\nRs.11,81,121/- under Section

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

8D(2)(ii) on the\nwrong notion that the disallowance is presumptive in\nnature even when the expenditure is not actually incurred.\n4.6. Without prejudice, the Lower Authorities were not\njustified in acting inconsistently in as much as while they\nchose to disturb the voluntary disallowance of\nRs.11,81,121/- under Section

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.

8D(2)(ii) on the\nwrong notion that the disallowance is presumptive in\nnature even when the expenditure is not actually incurred.\n4. 6. Without prejudice, the Lower Authorities were not\njustified in acting inconsistently in as much as while they\nchose to disturb the voluntary disallowance of\nRs.11,81,121/- under Section

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 14A r.w. Rule 8D (iii) of ignoring that conditions for invoking said section are fully satisfied

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

8D(2)(ii) on the\nwrong notion that the disallowance is presumptive in\nnature even when the expenditure is not actually incurred.\n\n4. 6. Without prejudice, the Lower Authorities were not\njustified in acting inconsistently in as much as while they\nchose to disturb the voluntary disallowance of\nRs.11,81,121/- under Section

MANIPAL HEALTH ENTERPRISES PRIVATE LIMITED,BANGALORE vs. ACIT, CIRCLE 2(3)(1), BANGALORE

In the result, the the revenue’s appeal is dismissed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2014-15

disallowance u/s. 14A having regard to the accounts of the assessee. This issue has been decided by the Hon’ble Bombay High Court in the case of Pr.CIT v. Tata Capital Ltd. dated 03.04.2024 reported in [2024] 161taxmann.com 557 (Bombay) wherein it has been held as under:- “ 6. In sub-Section (2) of Section 14A and Rule 8D

MANIPAL HEALTH SYSTEMS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE 1(2), BANGALORE

In the result, the the revenue’s appeal is dismissed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2014-15

disallowance u/s. 14A having regard to the accounts of the assessee. This issue has been decided by the Hon’ble Bombay High Court in the case of Pr.CIT v. Tata Capital Ltd. dated 03.04.2024 reported in [2024] 161taxmann.com 557 (Bombay) wherein it has been held as under:- “ 6. In sub-Section (2) of Section 14A and Rule 8D

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BENGALURU vs. MANIPAL HEALTH ENTERPRISES PVT LTD, BENGALURU

In the result, the the revenue’s appeal is dismissed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2014-15

disallowance u/s. 14A having regard to the accounts of the assessee. This issue has been decided by the Hon’ble Bombay High Court in the case of Pr.CIT v. Tata Capital Ltd. dated 03.04.2024 reported in [2024] 161taxmann.com 557 (Bombay) wherein it has been held as under:- “ 6. In sub-Section (2) of Section 14A and Rule 8D

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance under section 14 A read with rule 8D and computed the disallowance of ₹ 2,872,478 being 1% of the annual

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD. ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance under section 14 A read with rule 8D and computed the disallowance of ₹ 2,872,478 being 1% of the annual

MANIPAL HOSPITALS PVT. LTD (FORMERLY KNOWN AS COLUMBIA ASIA HOSPITALS PVT. LTD),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance under section 14 A read with rule 8D and computed the disallowance of ₹ 2,872,478 being 1% of the annual

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD.,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance under section 14 A read with rule 8D and computed the disallowance of ₹ 2,872,478 being 1% of the annual

MANIPAL GLOBAL EDUCATION SERVICES PVT LTD., ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(2), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

disallowance under section 14 A read with rule 8D and computed the disallowance of ₹ 2,872,478 being 1% of the annual

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 under section 14A read with rule 8D. After\nreducing the voluntarily disallowance amounting to Rs.36,52,525/-, a sum\nof Rs.18

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

disallowance under Section 14A, only investments yielding exempt income should be considered, not all investments. Regarding Section 35(2AB), the Tribunal noted that expenditure incurred for business purposes, even if not certified by DSIR for weighted deduction, is allowable as normal expenditure under Section 37.", "result": "Partly Allowed", "sections": [ "Section 14A", "Rule 8D

M/S MANIPAL TECHNOLOGIES LIMITED,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, UDUPI

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

Bench: Shri Chandra Poojari & Shri Beena Pillaiassessment Year : 2012-13

disallowance made by the Assessing Officer to the extent of Rs.10,80,499/- under Section 14A read with Rule 8D

M/S. BHARAT ELECTRONICS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

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

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahuassessment Year : 2012-13 M/S. Bharat Electronics The Assistant Ltd., Commissioner Of Registered Office, Income Tax, Outer Ring Road Ltu, Nagawara, Circle – 1, Vs. Bangalore – 560 045. Bangalore. Pan: Aaacb5985C Appellant Respondent

8D in its return of income and it is humbly submitted that disallowance to the tune of Rs. 4,69,055/- (5,99,055-1,30,000) on total investments is unjustified. B. Disallowance of Foreign exchange loss of Rs. 48,23,924/- under Section

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

disallowance of INR 37,250 under section 14A of the Act read with Rule 8D of the Income-tax Rules