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

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 or use of the trust property for the benefit of the settlor, etc., contained in section 13(1)(c) and (d) of that

BINDUMALYAM PANDURANGA ALLANHARINARAYAN ,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

In the result, appeal filed by the assessee is partly\nallowed

1)(a) of the Act, the notional value of\nRs.28,07,780/- (8.5% of Rs.3,30,32,716/-) is adopted as annual\nvalue for the purpose of computing deemed income from house\nproperty and accordingly computed the income as below:\n\nALV as discussed above\n28,07,780/-\nLess 30% for Repairs & Maintenance\n8,42,334/-\nNet Annual Value

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

Section\n153D. It is not an exercise dealing with a immaterial matter which\ncould be corrected by taking recourse to Section 292B of the Act.\n16. We are not inclined to interdict the order of the Tribunal.\n17. Accordingly, the appeal is closed.\n6.5 The above view taken by the Hon’ble Delhi High Court in the case of PCIT

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

164 taxmann.com 85 (Karnataka). He submitted that the Order must have been digitally signed. Section 282A(1) of the Act requires authentication of notices and other documents. He also referred to page 229 along with 233 of the paper Book and submitted that the notice issued under section 142(1) of the Act dated 19.01.2022 is digitally singed as mentioned

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

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

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

164/-. The Ld.Counsel submitted that the said additional adjustment was suo moto made by assessee in the revised return for the sake of determining the ALP of the transaction, since margin of assessee was very low. 32. The Ld.Counsel submitted that, the Ld.TPO should have considered Rs.38,21,89,088/- that was offered in the revised return, which included voluntary

M/S. THE SANDUR MANGANESE & IRON ORES LTD,SANDUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1,, BELLARY

In the result, both the appeals filed by the assessee stands partly allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

house. The clauses relating to maintenance and repair also were similar to the terms of the agreement involved in the case before us. 19. The Bombay High Court held that, having regard to the agreement, which limited its period of operation only for 15 years, and the amounts spent by the assessee being towards the welfare of the workmen

M/S. THE SANDUR MANGANESE & IRON ORES LTD,SANDUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BELLARY

In the result, both the appeals filed by the assessee stands partly allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

house. The clauses relating to maintenance and repair also were similar to the terms of the agreement involved in the case before us. 19. The Bombay High Court held that, having regard to the agreement, which limited its period of operation only for 15 years, and the amounts spent by the assessee being towards the welfare of the workmen

THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1 , BELLARY vs. SRI B RUDRA GOWDA , BELLARY

In the result, the appeal filed by assessee stands partly allowed and the appeal by revenue stands dismissed

property against the claim by the third party as capital expenditure;  By levying of interest under section 234B of Rs. 3,44,80,540/-. Aggrieved by the order of Ld.AO, assessee preferred appeal before Ld.CIT(A). The Ld.CIT(A) upheld the disallowance in respect of Corporate Social Responsibility as well as Reclamation and Rehabilitation expenditure but treated the legal expenses

B RUDRA GOUDA ,BELLARY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1 , BELLARY

In the result, the appeal filed by assessee stands partly allowed and the appeal by revenue stands dismissed

property against the claim by the third party as capital expenditure;  By levying of interest under section 234B of Rs. 3,44,80,540/-. Aggrieved by the order of Ld.AO, assessee preferred appeal before Ld.CIT(A). The Ld.CIT(A) upheld the disallowance in respect of Corporate Social Responsibility as well as Reclamation and Rehabilitation expenditure but treated the legal expenses

M/S.VASCULAR CONCEPTS LTD.,,BANGALORE vs. DCIT-CENTRAL CIRCLE-1(4), BANGALORE

In the result, appeals of the assessee are partly allowed

Bench: Shri Sunil Kumar Yadav & Shri Jason P. Boaz

164 to 173]. (3) CIT v. Singhad Technical Education Society, Civil Appeal No.11080 of 2015 dated 29 August, 2017 [Paperbook-V, pages 790 to 806]. (4) Jagran Prakashan Ltd. v. CIT, 368 ITR 0687 (All) [Paperbook-V, pages 807 to 811]. (5) Kusum Gupta v. DCIT, 35 CCH 0432 (Del) [Paperbook-V, pages 812 to 820]. 6. The ld. Counsel

M/S.VASCULAR CONCEPTS LTD.,,BANGALORE vs. DCIT-CENTRAL CIRCLE-1(4), BANGALORE

In the result, appeals of the assessee are partly allowed

Bench: Shri Sunil Kumar Yadav & Shri Jason P. Boaz

164 to 173]. (3) CIT v. Singhad Technical Education Society, Civil Appeal No.11080 of 2015 dated 29 August, 2017 [Paperbook-V, pages 790 to 806]. (4) Jagran Prakashan Ltd. v. CIT, 368 ITR 0687 (All) [Paperbook-V, pages 807 to 811]. (5) Kusum Gupta v. DCIT, 35 CCH 0432 (Del) [Paperbook-V, pages 812 to 820]. 6. The ld. Counsel

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENAGLURU

House, Barrow Street,\nCircle 1(1),\nDublin.]\nBengaluru.\nC/o. AZB & Partners,\n7th Floor, Embassy Icon,\nInfantry Road,\nBengaluru - 560 001.\nPAN: AADCG 7672A\nAPPELLANT\nRESPONDENT\nAppellant by\n: Shri Deepak Chopra, Ms. Priya Tandon, Shri\nAnmol Anand, Sri Aadith Sridhar, Advocates.\nRespondent by\n: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru.\nDate of hearing\n: 21.03.2024\nDate of Pronouncement

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

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

House, Barrow Street,\nDublin.]\nC/o. AZB & Partners,\n7th Floor, Embassy Icon,\nInfantry Road,\nBengaluru - 560 001.\nPAN: AADCG 7672A\nAPPELLANT\nRESPONDENT\nAppellant by\n: Shri Deepak Chopra, Ms. Priya Tandon, Shri\nAnmol Anand, Sri Aadith Sridhar, Advocates.\nRespondent by\n: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru.\nDate of hearing\n: 21.03.2024\nDate of Pronouncement : 26.03.2024\nORDER\nThese appeals

ACIT, BANGALORE vs. SHRI. PRASHANTH PRAKASH, BANGALORE

In the result, the appeal by the Revenue is dismissed, while the Cross Objection by assessee is treated as allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Abraham P. Georgeassessment Year : 2009-10

164, 165 & 166 of Doddathogur Village, Begur Hobli, Bangalore South Taluk. The assessee purchased a house site bearing No.197. Concorde Housing also agreed to convey the land and construct a Villa for the assessee. One of its sister concerns, Concorde Shelters Pvt. & CO 86/Bang/2015 Page 14 of 24 Ltd. (hereinafter referred to “Concorde Shelters”) agreed to construct a villa

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

House, Barrow Street, Dublin 4 Ireland ("Google''),and Google Online India Private Limited, a company incorporated under the Indian Companies Act, 1956 and having its registered office at 1st Floor, Prestige Sigma, No. 3 Vittal Mallya Road, Bangalore 560 001 ("Distributor''). WHEREAS 1. Google wishes to enter into the Distribution Agreement for its AdWords Program with Distributor; 2. Whereas Google

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

House, Barrow Street, Dublin 4 Ireland ("Google''),and Google Online India Private Limited, a company incorporated under the Indian Companies Act, 1956 and having its registered office at 1st Floor, Prestige Sigma, No. 3 Vittal Mallya Road, Bangalore 560 001 ("Distributor''). WHEREAS 1. Google wishes to enter into the Distribution Agreement for its AdWords Program with Distributor; 2. Whereas Google