ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

Bench: Shri George George K & Shri Waseem Ahmed

property for the benefit of the settlor, etc., contained in section 13(1)(c) and (d) of that Act, the said rate will not apply: to the business profits of such trusts which are otherwise chargeable to fax. In other word, where such a trust contravenes the provisions of section 13(1) (c) or (d) of the Act, the maximum

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

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

house property as provided in section 23(1)(c) of the Act. We, therefore, set aside the order of the learned CIT(A) and the grounds of appeal Nos.5, 6 & 7 raised by the assessee are allowed.” In the present case, the facts involved are similar to that of Smt. Indu Chandra (supra). So, respectfully following the order

S.M. CHANDRASHEKAR,BANGALORE vs. ITO, BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao

house property at Airport Road is nil u/s 23(1)(c) of the Act. 9. That the learned Commissioner of Income Tax (Appeals) erred in law and on facts in holding that the value of Jayanagar property is unexplained even though the appellant had accounted the value of the site in its books of account. 10. That the learned Commissioner

SHRI. MUNINAGA REDDY,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal for A

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

section 80C of the Act towards repayment of housing loan and an amount of Rs.1,50,000 towards interest on housing loan under the head ‘income from house property’. On examination thereof, the Assessing Officer found that both the claims made were wrong. ; the property in question was found to be in the name of the wife of the assessee

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeal filed by the Revenue is allowed for statistical purpose

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahuthe Dy. Commissioner Of Vs Shri C. Gangadhara Murthy Income-Tax, No. 322, 3Rd A Corss, 2Nd Block Circle - 6(2)(1) 3Rd Stage, Basaveshwaranagar Bangalore . Bangalore 560079. Pan – Agipg 2668 N (Appellant) (Respondent)

1), Bangalore was served on the assessee to file return of income for AY 2012-13. In response to the said communication the assessee filed a manual return of income on 06.11.2013 along with a covering letter dated 05.11.2013 and he declared total income of Rs.10,96,154/- comprising of Rs.3,48,933/- being house property income, Rs.3

AMANDA JOY PURAVANKARA ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee is allowed

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2015-16

Section 23(1)(c) to the present case. Amanda Joy Puravankara, Bengaluru Page 2 of 7 i. The Ld. Officers below erred failed to appreciate that the first house was continuously let out ever since it was acquired in 2011 and it could not be let out from October 2013 to May 2015 despite best of the efforts

ACIT, MANGALORE vs. SRI. J. KRISHNA PALEMAR, MANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Arun Kumar Garodiaassessment Year :2011-12

c,e) are owned by the assessee and part of fixed asset schedule of the Balance Sheet and residential in nature. The assessee might be using these properties for different purposes but it does not make the properties as non residential. (7) Based on the facts and circumstances of the case, the Ld.CIT(A) has failed to appreciate that

THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU vs. M/S. BLUELINE FOODS (INDIA) PVT. LTD.,, MANGALURU

11 of\n1922), or this Act (hereinafter in this section referred\nto as the undisclosed income or property), .......\n\"(Emphasis given)\n5. In the instant case, the person on whom the Pr. DIT(Inv.)\nhad reasons to believe that such person was in possession of\nunaccounted income/assets was Blueline Foods (India) Pvt. Ltd.\nHowever, in the case of Blueline Foods

KARNATAKA CHINMAYA SEVA TRUST,BENGALURU vs. DCIT-(EXEMPTIONS) CIRCLE-1, BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessmentyear:2016-17

c) omitted by Act 20 of 2002, Section 9 (w.e.f. 1.4.2002).](2)Where an application has been made on or after the 1st day of June, 2007, the provisions of sections 11 and 12 shall apply in relation to the income of such trust or institution from the assessment year immediately following the financial year in which such application

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

section 6(1)(c) would not apply and rejected the assessee’s submission that the Act permitted dual employment i.e., employment in India as well as outside India. The AO relied on K. Sambasiva Rao v. ITO [2014] 62 SOT 167 (Hyd) and Second ITO v. K.Y. Patel [1990] 33 ITD 714. As per the AO, the assessee

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

section 6(1)(c) would not apply and rejected the assessee’s submission that the Act permitted dual employment i.e., employment in India as well as outside India. The AO relied on K. Sambasiva Rao v. ITO [2014] 62 SOT 167 (Hyd) and Second ITO v. K.Y. Patel [1990] 33 ITD 714. As per the AO, the assessee

SHRI. JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

section 6(1)(c) would not apply and rejected the assessee’s submission that the Act permitted dual employment i.e., employment in India as well as outside India. The AO relied on K. Sambasiva Rao v. ITO [2014] 62 SOT 167 (Hyd) and Second ITO v. K.Y. Patel [1990] 33 ITD 714. As per the AO, the assessee

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

section 6(1)(c) would not apply and rejected the assessee’s submission that the Act permitted dual employment i.e., employment in India as well as outside India. The AO relied on K. Sambasiva Rao v. ITO [2014] 62 SOT 167 (Hyd) and Second ITO v. K.Y. Patel [1990] 33 ITD 714. As per the AO, the assessee

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

section 6(1)(c) would not apply and rejected the assessee’s submission that the Act permitted dual employment i.e., employment in India as well as outside India. The AO relied on K. Sambasiva Rao v. ITO [2014] 62 SOT 167 (Hyd) and Second ITO v. K.Y. Patel [1990] 33 ITD 714. As per the AO, the assessee

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

section 6(1)(c) would not apply and rejected the assessee’s submission that the Act permitted dual employment i.e., employment in India as well as outside India. The AO relied on K. Sambasiva Rao v. ITO [2014] 62 SOT 167 (Hyd) and Second ITO v. K.Y. Patel [1990] 33 ITD 714. As per the AO, the assessee