DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1,, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

property. I think, this is one of the key sections that should help us to defeat the free play of unaccounted money and cheating of the Government." Now it is true that the speeches made by the Members of the Legislature on the floor of the House when a Bill for enacting a statutory provision is being debated are inadmissible

M/S. UDUPI NIRMITHI KEDRA,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE - 1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

property. I think, this is one of the key sections that should help us to defeat the free play of unaccounted money and cheating of the Government." Now it is true that the speeches made by the Members of the Legislature on the floor of the House when a Bill for enacting a statutory provision is being debated are inadmissible

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

property. I think, this is one of the key sections that should help us to defeat the free play of unaccounted money and cheating of the Government." Now it is true that the speeches made by the Members of the Legislature on the floor of the House when a Bill for enacting a statutory provision is being debated are inadmissible

M/S. DAKSHINA KANNADA NIRMITHI KENDRA,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE -1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

property. I think, this is one of the key sections that should help us to defeat the free play of unaccounted money and cheating of the Government." Now it is true that the speeches made by the Members of the Legislature on the floor of the House when a Bill for enacting a statutory provision is being debated are inadmissible

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

property. I think, this is one of the key sections that should help us to defeat the free play of unaccounted money and cheating of the Government." Now it is true that the speeches made by the Members of the Legislature on the floor of the House when a Bill for enacting a statutory provision is being debated are inadmissible

SHRI. KOLA VENKAT RAMA NAIDU,BANGALORE vs. THE COMMISSIONER OF INCOME TAX (APPEALS) - 6, BANGALORE

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

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

house property and other sources filed return of income electronically for the assessment year 2010-11 on 13.10.2010 declaring income of Rs.54,34,810/-. A survey u/s 133A of the Income-tax Act,1961 ['the Act' for short] was conducted on 2.3.2015 at the business premises of the assessee. During the survey, the assessee was asked to explain the present

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

10(23C)(iv). When the\nexpression "charitable purpose", as defined in Section\n2(15) of the said Act, is read in the context of Section\n10(23C)(iv) of the said Act, we would have to give up the\nstrict and literal interpretation sought to be given to the\nexpression "charitable purpose" by the revenue.\n(viii) The expression "charitable

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

10(23C)(iv). When the\nexpression "charitable purpose", as defined in Section\n2(15) of the said Act, is read in the context of Section\n10(23C)(iv) of the said Act, we would have to give up the\nstrict and literal interpretation sought to be given to the\nexpression "charitable purpose" by the revenue.\n(viii) The expression "charitable

CENTRE FOR E-GOVERNANCE ,BANGALORE vs. DCIT, EXEMPTION, CIRCLE-1 , BANGALORE

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

properties, to contract, to sue or be sued and maintained its own fund. When specific exemption to such authorities under the Income-tax Act, 1961, was withdrawn, it sought relief under Article 289. The Hon'ble Supreme Court denied recourse to Article 289 as due to its enacting statue, it has a legal personality distinct from the state

M/S. NAVODAYA GRAMA VIKAS CHARITABLE TRUST,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, BANGALORE

In the result, the appeal filed by assessee stands allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18 M/S. Navodaya Grama Vikas Charitable Trust, The Deputy #14-7-1005, Scdcc Commissioner Of Bank Ltd., Income Tax, Head Office Building, Central Circle – 1, Kodialbail, Vs. Mangaluru. Mangaluru – 575 003. Pan: Aaatn7594E Appellant Respondent : Shri V. Srinivasan, Advocate & Assessee By Ms. Sunaina Bhatia, Ca Revenue By : Shri D.K. Mishra, Cit Dr Date Of Hearing : 07-07-2023 Date Of Pronouncement : 31-08-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 07.03.2022 Passed By Ld.Cit(A)-2, Panaji For A.Y. 2017-18 On Following Grounds Of Appeal: “1. The Orders Of The Authorities Below In So Far As They Are Against The Appellant Are Opposed To Law. Equity, Weight Of Evidence. Probabilities, Facts & Circumstances Of The Case. 2. The Learned Cit [A] Is Not Justified In Upholding The Disallowance Of The Exemption Claimed U/S.11 Of The Act

property held under trust either wholly or in part for charitable or religious purposes shall not be included in the total income computed under the Act. Therefore, for an assessees other than religious trusts, the activities must necessarily be for a "charitable purpose" within the meaning of section 2(15) for availing the exemption under section 11. Page

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, , BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No:Aaajk0398K\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

properties. Apart from building house for the Government, the assessee also purchases land from private parties and construct building for private parties. Thus, the surplus earned by the assessee is liable to be taxed during the year.\n\n5.2 The assessee is not doing any activity that can be treated as charitable in nature and therefore, it is held that

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

15) of the Act r.w. provisions thereto. It is seen that assessee has been created u/s 25 of the Companies Act. 6.4 It is also noted that assessee has been granted the registration u/s 11 of the Act vide section 12AA & 80G of the Act w.e.f. 8.12.1998 vide approval dated 8.12.1998 and 16.8.2010 respectively. The objects of the assessee

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

houses, buildings or works\nnecessary or convenient for the purposes of the Company.\n3. To take any gift or property, whether subject to any special trust or\nnot, for any one or more of the objects of the Company.\n4. To take such steps by personal or written appeals, public meetings\nor otherwise, as may from time to time

M/S. WIPRO LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(2), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

10 of 85 efficiencies in newer technological areas. These are normal research expenses incurred on certain futuristic and disruptive technologies in order to stay competitive and relevant in market place. The assessee has intended to use them in-house and was not meant to exploit it commercially in order to facilitate its business activities. Hence these expenses are revenue expenses

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

10 of 110 Central Government and get the approval of the prescribed authority. In the present case the fresh claim is made by the assessee with regard to conducting scientific research. Hence the burden is on the assessee to refer the matter to the prescribed authority for certificate. The assessee informed the Panel vide letter dated 24/09/2019 that it filed

GOBINDRAM CHANDRAMANI VIVEK,BANGALORE vs. INCOME TAX OFFICER - WARD 1(1), BANGALORE, BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes, in the manner indicated in this order

Bench: Mrs. Beena Pillai & Shri Ramit Kochar

10. Aggrieved, the assessee has now filed appeal before the Tribunal . It was submitted by ld. Counsel for the assessee that there is no double deduction as both the deductions operate on different field as interest on housing loan is allowed as deduction under section 24(b) , while interest paid on the housing loan is added to cost of acquisition

M/S. SILICON ESTATES,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal fails and is hereby dismissed

Bench: Shri Chandra Poojari & Ms. Madhumita Royassessment Year : 2013-14 M/S. Silicon Estates, The Deputy # 14, 6Th Floor, Commissioner Of Geneva House, Income Tax, Cunningham Road, Central Circle Bengaluru – 560 001. 1(4), Vs. Pan: Abefs6150N Bengaluru. Appellant Respondent Assessee By : Shri Tata Krishna, Advocate Revenue By : Shri D.K. Mishra, Cit Dr Date Of Hearing : 11-09-2023 Date Of Pronouncement : 04-12-2023 Order Per Madhumita Roythe Instant Appeal Filed By The Assessee Is Directed Against The Order Dated 24.11.2020 Passed By The Ld.Cit(A)-11, Bangalore Arising Out Of The Order Dated 30.12.2015 Passed By The Ld.Dcit, Central Circle – 1(4), Bangalore U/S. 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For A.Y. 2013-14 Whereby & Whereunder The Rejection Of The Claim U/S. 80Ib(10) Of Rs.4,03,40,492/- For A.Y. 2013-14 Has Been Confirmed.

Properties (P.) Ltd. 's case (supra), referred to supra, whereunder it came to be held that distinction drawn to be put forward by the Revenue with regard to completion certificate vis-a-vis occupancy certificate would not dilute the legal position, we dismiss these appeals.” Page 12 of 17 9. In the above matter, it was found that the certificate

YASH VARDHAN ARYA,BANGALORE vs. THE INCOME TAX OFFICER, (INTERNATIONAL TAXATION) WARD-1(1), BANGALORE

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

Bench: Shri George George K

15] From a reading of the provisions of sub-section (3) of section 23, it appears that the Legislatures in their wisdom have used the words 'house is actually let'. This shows that the words 'property is let' cannot mean actual letting out of the property because had it been so, there was be no need to use the word