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

94 TTJ 736 (Mum). Accordingly, the amount of Rs.4,67,690 is held as attracted for disallowance u/s. 40 of the Act. 14. The assessee is aggrieved that the assessing officer has erred in disallowing software expenses of Rs. 4,67,690 under section

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

94 TTJ 736 (Mum). Accordingly, the amount of Rs.4,67,690 is held as attracted for disallowance u/s. 40 of the Act. 14. The assessee is aggrieved that the assessing officer has erred in disallowing software expenses of Rs. 4,67,690 under section

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T, BANGALORE

In the result, Revenue’s appeal for A

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

4 IT(TP)A Nos.102 & 233/Bang/2013 Infosys Limited 4.1 The learned Commissioner of Income tax (Appeals) – I, Bangalore has erred in confirming the disallowance of software expenses paid to overseas entities amounting to Rs. 11,94,50,304/- under section

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

In the result, the appeal filed by the assessee is partly allowed

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

Disallowance under section 43B 49,27,979 Foreign royalty 16,56,488 Brand promotion expense 13,76,00,000 3. The A.O. also made an addition of Rs.140.49 crore and treated the amount transferred UBL Trust to the assessee as “long term capital gain” and assessed the same to tax. The A.O. accordingly assessed the income of the assessee

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

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

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

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

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

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

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

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

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

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

NEW MANGALORE PORT AUTHORITY,MANGALORE vs. DCIT, CIRCLE-1 & TPS, MANGALORE

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

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

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

section 14A of the Income Tax Act (hereinafter called ‘the Act’) Ground Nos.3 and 4: 75,58,30,838/- Disallowance of interest on reserve fund 4. 726/Bang/2025 ITBA/NFAC/S/250/2024- Ground Nos.1 and 2: 42,94

M/S. VIJAYANAGAR EDUCATIONAL TRUST,BENGALURU vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), BENGALURU

In the result appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2019-20

94 [(a) the activities of the trust or the institution are being carried out in a manner that the provisions of sections 11 and 12 do not apply to exclude either whole or any part of the income of such trust or institution due to operation of sub-section (1) of section 13; or (b) the trust or institution

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

4,73,18,208 ========== The AO noticed that the assessee has not deducted tax at source from the above said payments. The assessee submitted that the above said payments were made to foreign legal firms, which are firm of individuals in connection with services rendered by them in USA in connection with preparation of tax return, tax reconciliation calculation, application

BRIGADE ENTERPRISES LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX,, BANGALORE

In the result, the assessee’s appeal is treated as partly allowed

Bench: Smt. P. Madhavi Devi & Shri Abraham P Georgem/S.Brigade Enterprises Ltd., 29Th & 30Th Floor, World Trade Centre, Brigade Gateway Campus, 26/1, Dr.Rajkumar Road, Rajajinagar, Bangalore-560055. … Appellant Pan: Aaacb7459F Vs. Addl. Commissioner Of Income-Tax, Range-11, Bangalore. … Respondent

section 94(7) of the Act operate in different fields and in our opinion, will have no bearing on the present case. 20. We are of the view that in the light of the discussion in the earlier part of this order, the question of disallowance to be made under Rule 8D(2)(iii) of the Rules is remanded

M/S. GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

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

Bench: Shri A.K. Garodia & Shri Pavan Kumar Gadaleit(Tp)A No.2355/Bang/2019 (Assessment Year: 2015-16) M/S. Goldman Sachs Services Pvt. Ltd., Wing A, B & C, Helios Business Park, 150, Orr, Kadubeesanahalli, Bangalore-560103 ….Appellant Pan Aaccg 2435N Vs. Joint Commissioner Of Income Tax, Special Range 3, Bangalore. ……Respondent.

disallowances under Section 14A and 80G of the Act and prayed for allowing the assessee appeal. Contra, the learned Departmental Representative objected to the submissions and supported the order of TPO and DRP and relied on the judicial decisions. 7. We heard the rival submissions and perused the material on record. The LdAr made submissions for exclusion of 3 comparables