M/S BRIGADE ENTERPRISES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), BANGALORE

In the result, the assessee’s appeals for assessment years 2008-09 to 2010-11 are partly allowed for statistical purposes

Bench: Shri Jason P Boaz & Shri Pavan Kumar Gadale

disallowances made under section 14A r.w.r. 8D(2)(ii) for Assessment Year 2008-09. According to the learned DR, the proceeds of Rs.703 Crores from issue of issue of shares by IPO is a ITA Nos.528 to 530/Bang/2018 Page 9

SMT. REDDY SANGEETHA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance of Rs.39,03,991/- u/s 36(1)(iii) of the Act without appreciating that the assessee is having sufficient own funds. 11.1 This issue came for consideration before this Bench in ITA No.1110/Bang/2022 in assessment year 2013-14, wherein the Bench has held as under: “9. We have heard the rival submissions and perused the materials available on record

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance of Rs.39,03,991/- u/s 36(1)(iii) of the Act without appreciating that the assessee is having sufficient own funds. 11.1 This issue came for consideration before this Bench in ITA No.1110/Bang/2022 in assessment year 2013-14, wherein the Bench has held as under: “9. We have heard the rival submissions and perused the materials available on record

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance of Rs.39,03,991/- u/s 36(1)(iii) of the Act without appreciating that the assessee is having sufficient own funds. 11.1 This issue came for consideration before this Bench in ITA No.1110/Bang/2022 in assessment year 2013-14, wherein the Bench has held as under: “9. We have heard the rival submissions and perused the materials available on record

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance of Rs.39,03,991/- u/s 36(1)(iii) of the Act without appreciating that the assessee is having sufficient own funds. 11.1 This issue came for consideration before this Bench in ITA No.1110/Bang/2022 in assessment year 2013-14, wherein the Bench has held as under: “9. We have heard the rival submissions and perused the materials available on record

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance of Rs.39,03,991/- u/s 36(1)(iii) of the Act without appreciating that the assessee is having sufficient own funds. 11.1 This issue came for consideration before this Bench in ITA No.1110/Bang/2022 in assessment year 2013-14, wherein the Bench has held as under: “9. We have heard the rival submissions and perused the materials available on record

M/S KBD SUGARS & DISTILLERIES LTD. vs. ACIT,

In the result, the appeals of the assessee for the Assessment Years 2008-

9. Vis-à-vis the disallowance made under Rule 8D(2)(iii), a look at the assessment order clearly show that assessee, though it did not take specific plea it had stated that there was nothing which called for a disallowance under section

M/S HONEYWELL TECHNOLOGY SOLUTIONS LAB PRIVATE LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 , BANGALORE

Bench: Shri Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2013-14

disallowing the reimbursement of salary amounting to Rs 36,87,29,475 under section 40(a)(i) of the Act paid by the Appellant to the overseas Group affiliates on secondment of employees. 9

DCIT, BANGALORE vs. M/S VODAFONE SOUTH LTD.,, NEW DELHI

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(2) INTERNATIONAL TAXATION , BANGALORE vs. M/S VODAFONE SOUTH LTD , BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

VODAFONE SOUTH LIMITED,BANGALORE vs. DYDIT, BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

JOINT COMMISSIONER OF INCOME TAX (OSD) CIRCLE-2(1)(IT), BANGALORE vs. M/S VODAFONE SOUTH LTD , BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

DEPUTY COMMISSIONER OF INCOME TAX,BANGALORE vs. M/S.VODAFONE SOUTH LTD.,, NEW DELHI

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

DEPUTY COMMISSIONER OF INCOME-TAX,BANGALORE vs. M/S. VODAFONE SOUTH LTD.,, NEW DELHI

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts

VODAFONE SOUTH LIMITED,BANGALORE vs. DYDIT, BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

9(1)(vii)(b) of the Act. 3.3 On the facts and circumstances of the case and in law, the learned CIT(A) has erred in upholding the order of the learned Tax Officer holding that IUC and capacity transfer payments qualify as FTS/ FIS as defined under the respective Double Taxation Avoidance Agreements (`DTAAs'). 3.4 On the facts