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

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

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 was deleted due to the AO's failure to record satisfaction. Brand building expenditure was allowed as revenue expenditure. Foreign tax credit related to Section 10AA income was allowed. The issue of deduction for foreign taxes not eligible for relief under Section 90/91 was remanded.", "result": "Partly Allowed", "sections": [ "10AA", "14A", "80G", "37(1)", "90

BACHIRA UTHAIAH POOVAIAH,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(4), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmedassessment Years: 2018-19

90 of the Act as well as in accordance with the provisions of India-Norway DTAA. 8. The appellant submitted that the CPC without communicating the proposal to make disallowances proceeded to disallow the FCT in the intimation order under section

MOOG MOTION CONTROLS PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BANGALORE

In the result, the appeal is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2019-20 M/S. Moog Motion Controls Pvt. Ltd., Acit, Site No.42-43, Doraisanipalya Circle – 4(1)(1), Village, Vs. Bengaluru. Opp. Oracle (Kalyani Magnum), Bilekahalli, Begur Hobli, Bengaluru – 560 076. Pan : Aadcm 3828 J Appellant Respondent Assessee By : Shri. Srinivas K. P, Ca Revenue By : Shri. V. Parithivel, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 20.03.2024 Date Of Pronouncement : 08.05.2024

90 of the Act in the revised return of income. 3. Aggrieved from the above disallowance by the CPC, assessee filed appeal before the CIT(A). The CIT(A) observed that the disallowance for delayed remittance of employees’ contribution as per section

MR. VIKRAM DHONDU RAO, ,BANGALORE vs. DCIT, CIRCLE-4(1)(1), BANGALORE

In the result, appeal filed by the assessee in ITA No

90 will not fall under the purview of section 143(1) of the Act\n\n3. 1. The provisions of section 143(1) of the Act will not fall under the purview of section 143(1) of the Act for the reason that any adjustment/addition or disallowance

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE, BANGALORE vs. DEVESH MOHAN NAYEL, BANGALORE

In the result, the appeal is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2019-20 Dcit, Vs. Shri. Devesh M Nayel, Circle – 2(2)(1), 301, Rennaisance Regalia 95, Main Road, 15Th Cross, Bengaluru. Malleshwaram, Malleshwaram S.O, Bengaluru North, Bengaluru – 560 003. Pan : Aespn 6617 E Appellant Respondent Assessee By : Shri. Veerabasavana Gowda S, Ca Revenue By : Shri. V. Parithivel, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 04.12.2023 Date Of Pronouncement : 05.12.2023

90 or section 90A or section 91, against the income-tax payable under this Act;” 9. It was submitted that the Board has power to prescribe procedure to granting FTC. However, the Board does not have power to prescribe a condition or provide for disallowance

TESSOLVE SEMICONDUCTOR PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1) , BANGALORE

In the result, appeal filed by the assessee is allowed

disallowed for a procedural delay.", "result": "Allowed", "sections": [ "Section 90", "Section 139", "Section 143(1)", "Section 295", "Rule 128" ], "issues

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

90,49,75,405/-, instead of Rs. 6,85,69,84,4057- as per Form 3CL This\nresulted in excess disallowance and the learned Assessing Officer failed\nto provide the deduction under Section

KRISHNAKUMAR BALASANKARA SUBRAMANIAN,BANGALORE vs. DCIT CIRCLE 3(3)(1), BANGALORE, BANGALORE

In the result, the appeal is allowed

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

90 or section 90A or section 91, against the income- tax payable under this Act;” 9. It was submitted that the Board has power to prescribe procedure to granting FTC. However, the Board does not have power to prescribe a condition or provide for disallowance

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

section 90 of the Act nor hit by the disallowance provisions of section 40(a)(ii) of the Act, the same

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

section 90 of the Act nor hit by the disallowance provisions of section 40(a)(ii) of the Act, the same

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

section 90 of the Act nor hit by the disallowance provisions of section 40(a)(ii) of the Act, the same

SHRI. VIKRAM DHONDU RAO ,BANGALORE vs. DCIT, CIRCLE-4(1)(1), BANGALORE

In the result, the appeal of the assessee in ITA

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

90 or section 90A or section 91, against the income-tax payable under this Act;” 9. It was submitted that the Board has power to prescribe procedure to granting FTC. However, the Board does not have power to prescribe a condition or provide for disallowance

SUMUKH SURESH BHARDWAJ ,BENGALURU vs. INCOME TAX OFFICER, WARD-7(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

90 of the Act but the assessee failed to furnish form 67 before the due date of filing of return of income under section 139(1) of the Act, as required under rule 128(9) of the Income Tax Rule 1962. Hence, the CPC while processing the return under section 143(1) of the Act disallowed

DCIT, CIRCLE 1(1) & TPS, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DCIT, CIRCLE-1(1), MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government

DEPUTY COMMISSIONER OF INCOME TAX, MANGALURU vs. NEW MANGALORE PORT AUTHORITY, MANGALURU

In the result, the appeal of the Revenue on this for the Assessment Years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

disallowed the deduction claimed under section 80IA(4)(i) of the Act. 8. Aggrieved from the above Order, both the parties are in appeal before the Tribunal. 9. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the interest received on reserve funds are designated fund to be created mandatorily as per direction of Government