ITO, BANGALORE vs. SRI. C. NANJUNDIAH, BANGALORE

In the result we are of the opinion that assessee has to succeed in this appeal

Bench: Smt. P. Madhavi Devi

house property within the stipulated period of s. 54(2) i.e., before the extended due date for return under s. 139. The assessee technically may have defaulted in not filing the return under s.139(4). But, however, utilised the capital gains for purchase of property before the extended due date under s. 139(4). The contention of the Revenue that

SREENIVASULU SAGALETI,BENGALURU vs. INCOME TAX OFFICER, WARD-2(2)(2), BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri. Laxmi Prasad Sahuandshri.Keshav Dubeyassessment Year :2018-19

property immediately'.” 4. On perusal of the written submissions, it was noted that the assessee has filed return of income under section 139 of the Act and the entire amount which was subjected to capital gain tax has not been utilized for the purpose of construction of new house

SRI GOPAL BYRE GOWDA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the assessee's appeal for Assessment Year 2013-14 is allowed as indicated above

Bench: Shri George George K & Shri Jason P Boaz

house within the period specified under Section 139(4) of the Act, the benefit of Section 54F of the Act cannot be denied. In the case on hand, the original property

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Vs. CIT (88 taxmann.com 94) (Karn.), wherein held as under: Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 4 of 39 "10. Having heard the learned counsels for the parties, this Court is satisfied that the present writ petitions deserve to be dismissed for the following reasons:— (i) That the decision

SMT. REDDY SANGEETHA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Vs. CIT (88 taxmann.com 94) (Karn.), wherein held as under: Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 4 of 39 "10. Having heard the learned counsels for the parties, this Court is satisfied that the present writ petitions deserve to be dismissed for the following reasons:— (i) That the decision

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Vs. CIT (88 taxmann.com 94) (Karn.), wherein held as under: Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 4 of 39 "10. Having heard the learned counsels for the parties, this Court is satisfied that the present writ petitions deserve to be dismissed for the following reasons:— (i) That the decision

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Vs. CIT (88 taxmann.com 94) (Karn.), wherein held as under: Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 4 of 39 "10. Having heard the learned counsels for the parties, this Court is satisfied that the present writ petitions deserve to be dismissed for the following reasons:— (i) That the decision

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Vs. CIT (88 taxmann.com 94) (Karn.), wherein held as under: Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 4 of 39 "10. Having heard the learned counsels for the parties, this Court is satisfied that the present writ petitions deserve to be dismissed for the following reasons:— (i) That the decision

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

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

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

DEV KUMAR ROY ,BANGALORE vs. INCOME TAX OFFICER WARD-3(1)(1), BANGALORE

In the result, appeal of the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Jason P Boazassessment Year : 2012-13

4 of 31 exemption of Rs 134,139,988 claimed by the Appellant under section 54F of the Act without appreciating the detailed factual/ technical submissions furnished in support of the claim. 14. The learned CIT(A) has failed to appreciate the fact that as on the date of transfer of the shares of Nephrolife, the Appellant co-owned only

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

property held under trust or other legal obligation wholly for charitable or religious purposes or in part only for such purposes, or of income being voluntary contributions referred to in sub- clause (iia) of clause (24) of section 2, shall, if the total income in respect of which he is assessable as a representative assessee (the total income for this

SRI. M N SHESHAGIRI,MYSURU vs. INCOME TAX OFFICER, WARD- 2(3), MYSORE

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

Bench: Shri Chandra Poojari

property of the assessee is sold and when exactly the amounts were invested, whether it was invested in a residential house or otherwise. All these facts have to be considered with reference to provisions of Section 54F(4) along with Section 139

NAGAMMA,RAICHUR vs. INCOME TAX OFFICE-WARD 1, RAICHUR

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

property and allowed indexed cost of acquisition and deduction under section 54B, but disallowed deduction under section 54F for not depositing sale proceeds in CGAS.", "held": "The Tribunal held that the assessee is eligible for deduction under Section 54F, as the investment was made within the stipulated period for construction of a residential house, and Section 54F(4

IBM CANADA 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

4 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nIBM Corporation\nVs.\nDCIT (International Taxation)\nCircle-1(2)\nBangalore\nC/o IBM India Private Limited\nBangalore 560 029\nPAN NO : AABCI0847B\nAPPELLANT\nRESPONDENT\nIT(IT)A No.503/Bang/2024\n Assessment Years: 2017-18\nIBM Netherland B V\nVs.\nDCIT (International Taxation)\nCircle

IBM CANADA 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

4 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nIBM Corporation\nC/o IBM India Private Limited\nBangalore 560 029\nPAN NO : AABCI0847B\nAPPELLANT\nVs.\nDCIT (International Taxation)\nCircle-1(2)\nBangalore\nRESPONDENT\nIT(IT)A No.503/Bang/2024\n Assessment Years: 2017-18\nIBM Netherland B V\nC/o IBM India Private Limited