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

b) of section 11(4AA of the IT Act. As the maximum marginal rate of tax under the new proviso to section 164(2) applies to the whole or a part of the relevant income of a charitable or religious trust which forfeits exemption by virtue of the provisions of the IT Act in regard to investment pattern

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

b) of section 11(4AA of the IT Act. As the maximum marginal rate of tax under the new proviso to section 164(2) applies to the whole or a part of the relevant income of a charitable or religious trust which forfeits exemption by virtue of the provisions of the IT Act in regard to investment pattern

SADIYA EDUCATIONAL AND CHARITABLE TRUST vs. CIT,

In the result, the assessee's appeals are allowed

Bench: Smt. P. Madhavi Devi & Shri Jason P. Boazi.T. A. Nos.422 & 1632/Bang/2013 M/S. Sadiya Educational & Charitable Trust, Mattadgadde Road, Sadiya Nagar, Shiralkoppa-577 428 …. Appellant.

House of Lords in Barralet v. IR, 54 TC 446, has observed that “the study and dissemination of ethical principles and the cultivation of rational religious sentiment” would fall in the category of educational purposes. The Madarsa as a Mohommedan institution of teaching does not confine instruction to only dissipation of religious teachings but also contributes to the holistic education

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)

House property Rs.3,48,933 Income from Business Rs.3,12,000 Add: Income from Other sources Rs.5,35,221 Add: Unexplained cash credits in bank accounts Rs.1,12,02,680 Add: Unexplained capital accretion Rs.2,50,00,000 Rs.3,67,37,901 Rs.3,73,98,834 Gross total income 4. Aggrieved by the order of the AO the assessee filed

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

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

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

13,84,664/- instead of Rs.18,38,292/- , by deducting interest on housing loan claimed as deduction u/s 24(b) to the tune of Rs.4,53,628/- , and it was submitted that a new proviso which is added to section 48 of the 1961 Act clause (ii) is prospective in nature. 11. We have considered rival contentions and perused

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

b,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

M/S RABIYA BASARI BRAHAMATH-ULLAH ALLAYHA CHARITABLE TRUST vs. CIT,

In the result, the assessee's appeals are allowed

Bench: Smt. Asha Vijayaraghavan & Shri Jason P. Boaz

House of Lords in Barralet v. IR, 54 TC 446, has observed that “the study and dissemination of ethical principles and the cultivation of rational religious sentiment” would fall in the category of educational purposes. The Madarsa as a Mohommedan institution of teaching does not confine instruction to only dissipation of religious teachings but also contributes to the holistic education

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

1) of section 13 of IT Act 1961. 5. That, in the facts and circumstances of the case, the Ld.CIT(E) was erred in cancellation of registration of the trust u/s 12A(ab) of IT Act 1961, even though objects of the trust are charitable in nature and are being carried out its activities as per the object

SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1 & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

house property, income from business and income from other ITA No. 2396 & 2397/ bang/2024 A Y : 2019-20 & 2020-21 Shri Chandrakant Shamappa Kpntha Versus DCIT Circle (1) (1) & TPS Hubli sources. This return of income was processed under section 143 (1) of the act on 14 July 2020 determining the assessee's total income

SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1(1) & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

house property, income from business and income from other ITA No. 2396 & 2397/ bang/2024 A Y : 2019-20 & 2020-21 Shri Chandrakant Shamappa Kpntha Versus DCIT Circle (1) (1) & TPS Hubli sources. This return of income was processed under section 143 (1) of the act on 14 July 2020 determining the assessee's total income

M/S PRESTIGE ESTATES PROJECTS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-18(1), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri N.V.Vasudevan, Vp & Shri Chandra Poojari, Am

section 53A of the Transfer of Property Act. This agreement cannot, therefore, be said to be in the nature of a contract referred to in section 53A of the Transfer of Property Act. It cannot, therefore, be said that the provisions of section 2(47)(v) will apply in the situation before us. Considering the facts and circumstances

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

Bench: Mrs. Beena Pillai & Shri Ramit Kochar

houses, printing presses, hostels, residential quarters and the like. (ii) To provide medical relief to the poor, distressed, afflicted and mentally, physically, or psychologically handicapped persons, in India including supply of spectacles and other medical, surgical and remedial appliances and for this purpose to start, establish, conduct, maintain and manage and help dispensaries, hospitals, medical centres, diagnostic centres or other

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

Bench: Mrs. Beena Pillai & Shri Ramit Kochar

houses, printing presses, hostels, residential quarters and the like. (ii) To provide medical relief to the poor, distressed, afflicted and mentally, physically, or psychologically handicapped persons, in India including supply of spectacles and other medical, surgical and remedial appliances and for this purpose to start, establish, conduct, maintain and manage and help dispensaries, hospitals, medical centres, diagnostic centres or other

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

1 House Rent Name, address and Allowance permanent account number of the landlord/landlords where the aggregate rent paid during the previous year exceeds rupees one lakh 2 Leave travel Evidence of expenditure. concession or assistance 3 Deduction of interest Name, address and under the head permanent account number "Income from house of the lender. property". 4 Deduction under Evidence