DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE vs. M/S INFOSYS LIMITED , BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

14A as per rule 8D in the absence of satisfaction of the Ld.AO on incorrectness of the claim made by the assessee. 8.5. Without prejudice, Special bench of Hon’ble Delhi Tribunal in the case of ACIT vs. Vireet Investment (P) Ltd., reported in (2017) 82 taxmann.com 415, among other cases has held that only those investments

NADATHUR ESTATES P LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE

In the result, the appeals by the assessee are allowed for statistical purposes

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

house property’ [Rs. 1,16,85,877] and ‘income for other sources’ [Rs. 9.93.96,910]. The assessee also claimed exemption under income to the tune of Rs.3,58.19,598. 4. During the assessment proceedings, the assessee was asked to explain as to why provisions of section 14A

BRIGADE ENTERPRISES LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX,, BANGALORE

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

Bench: Smt. P. Madhavi Devi & Shri Abraham P Georgem/S.Brigade Enterprises Ltd., 29Th & 30Th Floor, World Trade Centre, Brigade Gateway Campus, 26/1, Dr.Rajkumar Road, Rajajinagar, Bangalore-560055. … Appellant Pan: Aaacb7459F Vs. Addl. Commissioner Of Income-Tax, Range-11, Bangalore. … Respondent

14A and section 94(7) of the Act operate in different fields and in our opinion, will have no bearing on the present case. 20. We are of the view that in the light of the discussion in the earlier part of this order, the question of disallowance to be made under Rule 8D(2)(iii) of the Rules

RAAJRATNA ENERGY HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

House, Road No 78, Jubilee\nHills,\nHyderabad - 500033.\nPAN : AAECM 6049 G\nAPPELLANT\nWard -3(2)(3),\nBangalore.\nRESPONDENT\nAssessee by : Shri. Ramesh Babu, CA\nRevenue by : Shri. Swaroop Manava, Addl. CIT(DR)(ITAT), Bangalore.\nDate of hearing : 07.08.2025\nDate of Pronouncement: 11=.09.2025\nORDER\nPer Laxmi Prasad Sahu, Accountant Member :\nBoth these appeals are filed by the assessee against

ASST.C.I.T., BANGALORE vs. M/S PRESTIGE ESTATE PROJECTS LTD.,, BANGALORE

In the result, the appeal filed by the Revenue is dismissed and

Bench: Shri Vijay Pal Rao & Shri G. Manjunatha

house property. Therefore, firstly what is the intention behind the lease and secondly what are the facilities given along with the buildings and documents executed in respect of each of them is to be seen. Thirdly, it is to be found out whether it is inseparable or not. If they are inseparable and the intention is to carry

PRESTIGE ESTATE PROJECTS LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal filed by the Revenue is dismissed and

Bench: Shri Vijay Pal Rao & Shri G. Manjunatha

house property. Therefore, firstly what is the intention behind the lease and secondly what are the facilities given along with the buildings and documents executed in respect of each of them is to be seen. Thirdly, it is to be found out whether it is inseparable or not. If they are inseparable and the intention is to carry

RAAJRATNA ENERGY HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

Accordingly, this\nground is allowed for statistical purposes

House, Road No 78, Jubilee\nHills,\nHyderabad - 500033.\nPAN : AAECM 6049 G\nAPPELLANT\nVs.\nITO,\nWard -3(2)(3),\nBangalore.\nRESPONDENT\nAssessee by\n: Shri. Ramesh Babu, CA\nRevenue by\n: Shri. Swaroop Manava, Addl. CIT(DR)(ITAT), Bangalore.\nDate of hearing\n: 07.08.2025\nDate of Pronouncement:\n11=.09.2025\nORDER\nPer Laxmi Prasad Sahu, Accountant Member :\nBoth these appealsare filed

V.ANANTHA KUMAR ,BANGALORE vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-2(2), BANGALORE

In the result, the appeal in ITA No

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

section 23(1)(a)(b) the hire of the sum for which the property might reasonably be expected to be let from year to year or actual rent received is the basis of determination of annual value. In the present case it cannot be disputed that the sum for which the property might reasonably be expected to be let from

V.ANANTHA KUMAR ,BANGALORE vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-2(2), BANGALORE

In the result, the appeal in ITA No

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

section 23(1)(a)(b) the hire of the sum for which the property might reasonably be expected to be let from year to year or actual rent received is the basis of determination of annual value. In the present case it cannot be disputed that the sum for which the property might reasonably be expected to be let from

SRI. GANGA POORNA PRASAD,MYSURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MYSURU

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

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2009-10 Sri Ganga Poorna Prasad, Vs. The Assistant Commissioner Of #718, Ii Main, 1St Cross, 1St Block, Income Tax, Ramakrishnagar, Circle-2(1), Mysuru – 570 026. Mysuru. Pan : Aiqpp 5131 K Assessee By : Shri. V. Srinivasan, Advocate Revenue By : Shri. Sankar Ganesh, Jcit(Dr)(Itat), Bengaluru

section 148 of the Act, return of income was filed declaring Total Income of Rs. 1,17,59,366.00. The Total income comprised of Income from House Property, Business income and Income for Other Sources offered for taxation in the return of income originally filed earlier and Long Term Capital Gain amounting to Rs. 1,15,74,390.00. 7. After

M/S. G CROP PRIVATE LIMITED,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal filed by the assessee is dismissed

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessmentyear: 2014-15

house property”. As per section 23 of the Act, the “annual letting value” of the property is liable to be taxed. Further, permissible deductions are given in section 24 of the Act. The annual value of the property is the actual rent receivable by the assessee and hence the Mall owner should have offered 100% of the license fees/rent receipts

ASST. COMMISSIONER OF INCOME-TAX,BANGALORE vs. M/S.KAUSTHUBHA PROJECT PRIVATE LIMITED, BANGALORE

In the result, appeal of the Revenue is dismissed

Bench: Shri. Inturi Rama Rao

Property development. The AO disallowed an amount of Rs.62,38,066/- by invoking the provisions of section 14A r.w.r 8D. Feeling aggrieved by the disallowance, the assessee filed appeal before the CIT (A), who has allowed the ground of appeal of the assessee vide the impugned order. Therefore the Revenue is in appeal before

M/S MFAR DEVELOPERS PVT LTD ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for assessment year 2012-13 is partly allowed

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale1. Ita Nos.1649/Bang/2017 (Assessment Year: 2012-13) 2. Ita No.730/Bang/2018 (Assessment Year: 2013-14) & 3. Ita No.731/Bang/2018 (Assessment Year; 2014-15) M/S.Mfar Developers Pvt. Ltd. No.3, Lavelle Road, Bengaluru-560 001. … Appellant Pan:Aafcm 6271 M Vs. 1-2. Assistant Commissioner Of Income-Tax, Circle 4(1)(2), Bengaluru. 3. Deputy Commissioner Of Income-Tax, Circle 4(1)(2), Bengaluru. … Respondent Appellant By : Shri K.K.Chythanya, Advocate. Respondent By : Dr. P.V.Pradeep Kumar, Addl.Cit(Dr) Date Of Hearing: 22/03/2019 Date Of Pronouncement: 24/04/2019 O R D E R Per Pavan Kumar Gadale, Jm: The Assessee Has Filed Appeals Against Different Orders Of The Cit(A) For Assessment Years 2012-13, 2013-14 & 2014- 15. Ita Nos.1649/Bang/2017 & 730 & 731/Bang/2018 Page 2 Of 16 2. As Far As Ground No.2 In Respect Of Disallowance Of Proportionate Interest U/S 24(B) Of The Income-Tax Act,1961 ['The Act' For Short], The Assessee Has Raised Similar Grounds Of Appeal For Assessment Years 2012-13, 2013-13 & 2014-15. Similarly, For The Assessment Year 2012-13, The Assessee Has Raised An Alternative Plea To Allow Interest U/S 36(1)(Iii) Which Is Also Ground Of Appeal In Assessment Years 2013-14 & 2014-15. For The Assessment Year 2012-13, The Assessee Raised Ground For Allowance Of Deduction Towards Processing Fees & Pre-Payment Charges U/S 24(B) Of The Act. For The Assessment Year 2013-14, The Assessee Has Raised A Ground For Disallowance Of Rs.25,77,78/- Under The Provisions Of Section 14A Of The Act.

sections 23 or 24 to grant benefit of such deduction under head income from house property - Assessee thus offered and requested Assessing Officer to treat- impugned rental income as income from other sources and allow aforesaid maintenance expenses as a deduction - Whether where assessee wanted its income to be assessed under different head as per provisions of law, then

M/S MFAR DEVELOPERS PVT LTD ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for assessment year 2012-13 is partly allowed

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale1. Ita Nos.1649/Bang/2017 (Assessment Year: 2012-13) 2. Ita No.730/Bang/2018 (Assessment Year: 2013-14) & 3. Ita No.731/Bang/2018 (Assessment Year; 2014-15) M/S.Mfar Developers Pvt. Ltd. No.3, Lavelle Road, Bengaluru-560 001. … Appellant Pan:Aafcm 6271 M Vs. 1-2. Assistant Commissioner Of Income-Tax, Circle 4(1)(2), Bengaluru. 3. Deputy Commissioner Of Income-Tax, Circle 4(1)(2), Bengaluru. … Respondent Appellant By : Shri K.K.Chythanya, Advocate. Respondent By : Dr. P.V.Pradeep Kumar, Addl.Cit(Dr) Date Of Hearing: 22/03/2019 Date Of Pronouncement: 24/04/2019 O R D E R Per Pavan Kumar Gadale, Jm: The Assessee Has Filed Appeals Against Different Orders Of The Cit(A) For Assessment Years 2012-13, 2013-14 & 2014- 15. Ita Nos.1649/Bang/2017 & 730 & 731/Bang/2018 Page 2 Of 16 2. As Far As Ground No.2 In Respect Of Disallowance Of Proportionate Interest U/S 24(B) Of The Income-Tax Act,1961 ['The Act' For Short], The Assessee Has Raised Similar Grounds Of Appeal For Assessment Years 2012-13, 2013-13 & 2014-15. Similarly, For The Assessment Year 2012-13, The Assessee Has Raised An Alternative Plea To Allow Interest U/S 36(1)(Iii) Which Is Also Ground Of Appeal In Assessment Years 2013-14 & 2014-15. For The Assessment Year 2012-13, The Assessee Raised Ground For Allowance Of Deduction Towards Processing Fees & Pre-Payment Charges U/S 24(B) Of The Act. For The Assessment Year 2013-14, The Assessee Has Raised A Ground For Disallowance Of Rs.25,77,78/- Under The Provisions Of Section 14A Of The Act.

sections 23 or 24 to grant benefit of such deduction under head income from house property - Assessee thus offered and requested Assessing Officer to treat- impugned rental income as income from other sources and allow aforesaid maintenance expenses as a deduction - Whether where assessee wanted its income to be assessed under different head as per provisions of law, then

M/S MFAR DEVELOPERS PVT LTD ,BANGALORE vs. THE ASSISTAT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for assessment year 2012-13 is partly allowed

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale1. Ita Nos.1649/Bang/2017 (Assessment Year: 2012-13) 2. Ita No.730/Bang/2018 (Assessment Year: 2013-14) & 3. Ita No.731/Bang/2018 (Assessment Year; 2014-15) M/S.Mfar Developers Pvt. Ltd. No.3, Lavelle Road, Bengaluru-560 001. … Appellant Pan:Aafcm 6271 M Vs. 1-2. Assistant Commissioner Of Income-Tax, Circle 4(1)(2), Bengaluru. 3. Deputy Commissioner Of Income-Tax, Circle 4(1)(2), Bengaluru. … Respondent Appellant By : Shri K.K.Chythanya, Advocate. Respondent By : Dr. P.V.Pradeep Kumar, Addl.Cit(Dr) Date Of Hearing: 22/03/2019 Date Of Pronouncement: 24/04/2019 O R D E R Per Pavan Kumar Gadale, Jm: The Assessee Has Filed Appeals Against Different Orders Of The Cit(A) For Assessment Years 2012-13, 2013-14 & 2014- 15. Ita Nos.1649/Bang/2017 & 730 & 731/Bang/2018 Page 2 Of 16 2. As Far As Ground No.2 In Respect Of Disallowance Of Proportionate Interest U/S 24(B) Of The Income-Tax Act,1961 ['The Act' For Short], The Assessee Has Raised Similar Grounds Of Appeal For Assessment Years 2012-13, 2013-13 & 2014-15. Similarly, For The Assessment Year 2012-13, The Assessee Has Raised An Alternative Plea To Allow Interest U/S 36(1)(Iii) Which Is Also Ground Of Appeal In Assessment Years 2013-14 & 2014-15. For The Assessment Year 2012-13, The Assessee Raised Ground For Allowance Of Deduction Towards Processing Fees & Pre-Payment Charges U/S 24(B) Of The Act. For The Assessment Year 2013-14, The Assessee Has Raised A Ground For Disallowance Of Rs.25,77,78/- Under The Provisions Of Section 14A Of The Act.

sections 23 or 24 to grant benefit of such deduction under head income from house property - Assessee thus offered and requested Assessing Officer to treat- impugned rental income as income from other sources and allow aforesaid maintenance expenses as a deduction - Whether where assessee wanted its income to be assessed under different head as per provisions of law, then

M/S VALUE POINT SYSTEMS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result Ground.7 of the assessee is dismissed

Bench: Shri. A. K. Garodia & Shri. Lalit Kumari.T.A No.376/Bang/2017 (Assessment Year : 2011-12)

14A of the Act.' 23. The decisions of the ITAT in Ratan Housing Development Ltd. (supra) and Relaxo Footwears Ltd. (supra), to the extent that they are inconsistent with what has been held hereinbefore do not merit acceptance. Further, the mere fact that in the audit report for the AY in question, the auditors may have suggested that there should

M/S STERLING DEVELOPERS PVT. LTD.,,BANGALORE vs. JCIT, BANGALORE

In the result, appeal filed by the assessee is partly allowed, whereas the appeal of Revenue stands dismissed

Bench: Shri. N. V. Vasudevan

housing projects on certain conditions being fulfilled. The provisions of section 80 IB (13) of the Act, that makes the provisions of section 80 IA(5) applicable to section 80 IB also, applies only ‘so far as may be’. Thus, by virtue of the fact that there is no concept of initial assessment year under section 80IB

DCIT, BANGALORE vs. M/S BOSCH LIMITED, BANGALORE

In the result, the assessee's appeals are partly allowed and revenue’s appeal for the A

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

property in the hand of the transferor and it gets vested in the hand of transferee. Therefore, in the case of transfer the right or ownership of transferor is completely extinguished and it is vested with the transferee. In the case on hand, the assessee is vested with the right to use the patented technical know how / technology under

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE vs. M/S COFFEEDAY GLOBAL LIMITED , BANGALORE

In the result, the appeals of the Revenue are partly allowed

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

Properties India (P) Ltd. 1,00,00,000 1,00,00,000 Total 6,94,24,909 6,94,24,909 4.1.1 The Assessing Officer noticed that all the investments above were in group companies/concerns and had been made in the interest of the business activity of 3 I.T.A. Nos.3040 & 3041/Bang/2018 the assessee. Further, majority of the investments above were