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 read with rule 8D should not be invoked to determine the amount

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), 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

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

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

3,95,013 ----------------- Loss from this source (-) 35,013 ------------------ Accordingly the Assessing Officer has assessed the loss from house property at Rs. 35,013/- as against the loss claimed by the Assessee of Rs.2,19,813/-. Thus there was disallowance of loss of Rs.1,84,800/-. 13. On appeal by the Assessee, the CIT(A) confirmed the addition with

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

3,95,013 ----------------- Loss from this source (-) 35,013 ------------------ Accordingly the Assessing Officer has assessed the loss from house property at Rs. 35,013/- as against the loss claimed by the Assessee of Rs.2,19,813/-. Thus there was disallowance of loss of Rs.1,84,800/-. 13. On appeal by the Assessee, the CIT(A) confirmed the addition with

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

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

14A of the Act Disallowance of sponsorship 703,22,73,164 7,03,22,731 expenses (before depreciation) 3.8 The AO accordingly assessed the income of the assessee at Rs.519,01,98,509/- against the income of Rs.1122,29,03,119/- determined in the assessment order. The Assessee has filed the appeal in IT(TP)A No.308/Bang-2023 before this Tribunal

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

14A of the Act Disallowance of sponsorship 703,22,73,164 7,03,22,731 expenses (before depreciation) 3.8 The AO accordingly assessed the income of the assessee at Rs.519,01,98,509/- against the income of Rs.1122,29,03,119/- determined in the assessment order. The Assessee has filed the appeal in IT(TP)A No.308/Bang-2023 before this Tribunal

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.

3 is thus dismissed'.” 12. The headnote of the decision of the co-ordinate bench of Tribunal in the case of Peepul Tree Properties (P.) Ltd. vs. ACIT (71 taxmann.com 332)(Mumbai – Trib) read as under: “Section 24 of the Income-tax Act, 1961 - Income from house property - Deductions (Interest) - Assessment year 2010-11 - Whether prepayment charges and processing

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.

3 is thus dismissed'.” 12. The headnote of the decision of the co-ordinate bench of Tribunal in the case of Peepul Tree Properties (P.) Ltd. vs. ACIT (71 taxmann.com 332)(Mumbai – Trib) read as under: “Section 24 of the Income-tax Act, 1961 - Income from house property - Deductions (Interest) - Assessment year 2010-11 - Whether prepayment charges and processing

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.

3 is thus dismissed'.” 12. The headnote of the decision of the co-ordinate bench of Tribunal in the case of Peepul Tree Properties (P.) Ltd. vs. ACIT (71 taxmann.com 332)(Mumbai – Trib) read as under: “Section 24 of the Income-tax Act, 1961 - Income from house property - Deductions (Interest) - Assessment year 2010-11 - Whether prepayment charges and processing

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

14a. Copy of the Free English translation of the above Corporation Tax paid receipt In 108 110 vernacular dated 30/12/2010 15. Copy of the endorsement dated 17/12/1996 issued by the Mysore City 111 113 Corporation transferring the Khata in the name of Sri H.Gangadharan of property 16. Copy of the Free English translation of the above endorsement dated 17/12/1996

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)

3) of Section 14A were inserted with effect from 1st April, 2007 to provide for methodology for computing of disallowance under Section 14A. However, the actual methodology was provided in ITA.376/Bang/2017 Page - 5 terms of Rule 8D only from 24th March 2008. There was a further amendment to Rule 8D with effect from 2nd June 2016 limiting the disallowance

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY, CENTRAL CIRCLE, BELLARY vs. M/S VIRGO PROPERTIES PRIVATE LIMITED, CHENNAI

In the result, appeal filed by the Revenue is dismissed

House,\nChennai - 600 017.\nPAN : ANOPS 2178 Q\nAPPELLANT\nRESPONDENT\nAssessee by\nShri. V. Sridhar, CA\nRevenue by\nShri. Muthu Shankar, CIT(DR)(ITAT), Bangalore.\nDate of hearing\n29.10.2025\nDate of Pronouncement: 21.11.2025\nORDER\nPer Laxmi Prasad Sahu, Accountant Member :\nThis is an appeal filed by the Revenue against the Order passed by the\nlearned CIT(A) 2, Panaji, vide

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