M/S THOMSON REUTERS INDIA SERVICES PRIVATE LIMITED,BANGALORE vs. ADDL.C.I.T., BANGALORE

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

Bench: Smt. Asha Vijayaraghavan & Shri. S. Jayaraman

house R&D centre expenditure at Hyderabad under section 35(2AB) of the Income Tax Act.” • As per the Notes to Accounts - Schedule 15, under “Deferred Revenue Expenditure” (page 31 of PB-II), it is mentioned that, “Expenditure incurred on research and development of new products has been treated as deferred revenue expenditure and the same has been written

EMC SOFTWARE AND SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 2, BANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes as per the terms mentioned above

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

133(6) of the Act, which tantamount to choosing secret comparable companies whose information was not available in public domain while preparing the TP documentation for the relevant financial year. 3.7 Application of related party transaction filter by applying an inappropriate interpretation of computing the filter and thereby accepting Persistent Systems Ltd and Aspire Systems (India) Pvt. Ltd. as comparable

MCAFEE SOFTWARE (INDIA) PVT. LTD.,,BANGALORE vs. ACIT, BANGALORE

In the result, the appeal of the assessee stands allowed in the

Bench: Shri A.K.Garodia & Shri Vijay Pal Rao

house R&D centre expenditure at Hyderabad under section 35(2AB) of the Income Tax Act.” ii. As per the Notes to Accounts - Schedule 15, under “Deferred Revenue Expenditure” (page 31 of PB-II), it is mentioned that, “Expenditure incurred on research and development of new 24 IT(TP)A Nos.11(B)/12 products has been treated as deferred revenue

SOFTBRANDS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

Bench: Shri Abraham P George & Shri Vijay Pal Rao

houses the sections like 80HHC, 80-IA, etc. The Parliament was aware of the various restricting and limiting provisions like s. 80A and s. 80AB which were in Chapter VI-A which do not appear in Chapter III. The fact that even after its recast, the relief has been retained in Chapter III indicates the intention of Parliament that

DR. DEVIKA GUNASHEELA,BANGALORE vs. JCIT, BANGALORE

Bench: Shri N.V. Vasudevan & Shri A.K. Garodiaassessment Year: 2012-13

133(6) of the Act to Bruhat Bengaluru Mahanagar Palike (BBMP) and obtained the information that the property that was sold was a vacant land and not a residential house. 10. Before the A.O., the assessee claimed exemption u/s 54F instead of section

M/S. LSI TECHNOLOGIES INDIA PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result, both the appeals are partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

house development products and training. Further the software IT(TP)A Nos.1380 & 1381/Bang/2010 development business segment of this company also comprising of diversified activities such as hardware design, industrial design, engineering design and visual computing. Even this company in its response to notice under Section 133(6) has accepted that this company is not comparable with the software development services

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.

6(l)(c) and expln. (b) specifically. Thus no judgment contrary to Hon'ble Kerala High Court has been cited by the Revenue. It is a trite law that in Income tax proceedings the words shall be given plain and ordinary meaning and interpretation should be resorted only when the meaning is ambiguous. We are unable to see any ambiguity

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.

6(l)(c) and expln. (b) specifically. Thus no judgment contrary to Hon'ble Kerala High Court has been cited by the Revenue. It is a trite law that in Income tax proceedings the words shall be given plain and ordinary meaning and interpretation should be resorted only when the meaning is ambiguous. We are unable to see any ambiguity

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.

6(l)(c) and expln. (b) specifically. Thus no judgment contrary to Hon'ble Kerala High Court has been cited by the Revenue. It is a trite law that in Income tax proceedings the words shall be given plain and ordinary meaning and interpretation should be resorted only when the meaning is ambiguous. We are unable to see any ambiguity

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.

6(l)(c) and expln. (b) specifically. Thus no judgment contrary to Hon'ble Kerala High Court has been cited by the Revenue. It is a trite law that in Income tax proceedings the words shall be given plain and ordinary meaning and interpretation should be resorted only when the meaning is ambiguous. We are unable to see any ambiguity

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.

6(l)(c) and expln. (b) specifically. Thus no judgment contrary to Hon'ble Kerala High Court has been cited by the Revenue. It is a trite law that in Income tax proceedings the words shall be given plain and ordinary meaning and interpretation should be resorted only when the meaning is ambiguous. We are unable to see any ambiguity

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.

6(l)(c) and expln. (b) specifically. Thus no judgment contrary to Hon'ble Kerala High Court has been cited by the Revenue. It is a trite law that in Income tax proceedings the words shall be given plain and ordinary meaning and interpretation should be resorted only when the meaning is ambiguous. We are unable to see any ambiguity

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.

6(l)(c) and expln. (b) specifically. Thus no judgment contrary to Hon'ble Kerala High Court has been cited by the Revenue. It is a trite law that in Income tax proceedings the words shall be given plain and ordinary meaning and interpretation should be resorted only when the meaning is ambiguous. We are unable to see any ambiguity

SHARP SOFTWARE DEVELOPMENT INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

Bench: Shri. Vijay Pal Rao

house R&D centre expenditure at Hyderabad under section 35(2AB) of the Income Tax Act.” • As per the Notes to Accounts - Schedule 15, under “Deferred Revenue Expenditure” (page 31 of PB-II), it is mentioned that, “Expenditure incurred on research and development of new products has been treated as deferred revenue expenditure and the same has been written

MICROCHIP TECHNOLOGY (INDIA) PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

In the result, the cross appeals for the A

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

house R&D centre expenditure at Hyderabad under section 35(2AB) of the Income Tax Act.” • As per the Notes to Accounts - Schedule 15, under “Deferred Revenue Expenditure” (page 31 of PB-II), it is mentioned that, “Expenditure incurred on research and development of new products has been treated as deferred revenue expenditure and the same has been written

BHAGYA MAHANTESH KHODANPUR ,HUBBALLI vs. INCOME TAX OFFICER, WARD-2(1), HUBBALLI

In the result, appeal of the assessee is partly allowed

Bench: Dr. Dipak P. Ripote & Shri Prakash Chand Yadavassessment Year: 2015-16 Bhagya Mahantesh Khodanpur, Income Tax Officer, Indu Arcade, Vithoba Galli, Ward-2(1), Durgadbail, Vs. Hubballi. Hubballi-580020. Pan No : Apxpk0150P Appellant Respondent Appellant By : Sri Sudheendra B.R, Advocate Respondent By : Sri Ganesh R Ghale, Advocate-Standing Counsel For Revenue Date Of Hearing : 20.08.2025 Date Of Pronouncement : 21.08.2025 O R D E R Per Dr. Dipak P. Ripote: This Is An Appeal Filed By Bhagya Mahantesh Khodanpur Against The Order Of The Learned Commissioner Of Income Tax (Appeals) (Nfac) (In Short “Ld. Cit(A)”) Passed U/S. 250 Of The Income Tax Act, 1961 (In Short “The Act”) For Asst Year 2015-16 On 28/03/2025 Emanating From Assessment Order Dated 29/12/2017 Passed U/S. 143(3) Of The Act. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Order Passed By The Ld. Addl / Joint Commissioner Of Income Tax (Appeals)-2, Gurugram U/S. 250 Of The Act Dated 28/03/2025 Is Bad In Law & Liable To Be Quashed. Addition Of Rs. 4,42,500/- Is Bad In Law & 2. Liable To Be Deleted.

133(6) of the Act. The said letter mentions that loan was sanctioned against the property bearing Plot No.55-B, Tarihal Industrial Area. Thus, the Ld. AR submitted that the Assessing Officer directly collected the information from KSFC which explains the interest paid by the assessee. Therefore, the addition made by the Ld. AO needs to be deleted

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(2)(2), BANGALORE vs. M/S. NITESH INFRASTRUCTURE & CONSTRUCTIONS, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2012-13

133(6) of IT Act 1961, who had responded to the notice issued by the dept. by stating no such dues exist in Page 11 of 14 her books. On appeal, the CIT(Appeals) allowed the appeal of the assessee. Against this, the revenue is in appeal before us. 31. The ld. AR submitted that the building project Nitesh Time

M/S CONTINENTAL AUTOMOTIVE COMPONENTS INDIA PVT LTD ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

section 133(6) of the Act and call for relevant information on capacity utilisation in case of comparables finally selected. Needless to say that details so collected by Ld.TPO shall be provided to assessee and then to provide consider the issue as per law. Accordingly this ground raised by assessee stands allowed for statistical purposes.” 24. We have heard both