M/S RAMBUS CHIP TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the revenue’s appeal is dismissed and assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri Jason P.Boaz

property rights (IPRs). It was also submitted by the learned Authorised Representative that :- (i) the co-ordinate bench of this Tribunal in the case of 24/7 Customer.Com Pvt. Ltd. in ITA No.227/Bang/2010 has held that a company owning intangibles cannot be compared to a low risk captive service provider who does not own any intangible and hence does not have

DCIT, BANGALORE vs. M/S RAMBUS CHIP TECHNOLOGIES (INDIA) PVT. LTD.,, BANGALORE

In the result, the revenue’s appeal is dismissed and assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri Jason P.Boaz

property rights (IPRs). It was also submitted by the learned Authorised Representative that :- (i) the co-ordinate bench of this Tribunal in the case of 24/7 Customer.Com Pvt. Ltd. in ITA No.227/Bang/2010 has held that a company owning intangibles cannot be compared to a low risk captive service provider who does not own any intangible and hence does not have

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

M/S CONSULATE CONSTRUCTIONS,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeals for Assessment Years 2001-02 and 2003-04 are partly allowed for statistical purposes

house property’ as against ‘business income’ by relying on the decision of the Hon'ble Apex Court in the case of Shambu Investments Pvt. Ltd. V CIT reported in 263 ITR 143. In this manner, the income for Assessment Year 2001-02 was determined at Rs.6,94,757 as against the loss of Rs.15,51,760 declared in the return

SRI DHEERAJ GOVINDAPPA ,BANGALORE vs. THE INCOME TAX OFFICER WARD-4(2)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2015-16 is partly allowed

Bench: Shri Jason P Boazi.T. A. No.2724/Bang/2018 (Assessment Year : 2015-16) Shri Dheeraj Govindappa, Vs. The Income-Tax Officer, 1183, 3Rd Cross, 3Rd Stage, Ward – 4[2][2], Hal Layout, Bangalore. Bangalore – 560 075. Pan : Bpqpg 3893 F Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Satya Sai Rath, Jcit Date Of Hearing : 30.10.2018 Date Of Pronouncement : 02.01.2019

194-1A of the Act @ 1% of purchase consideration has been paid in the seller’s name viz., 1% of 80 lakhs by the assessee and of Rs.40 lakhs by assessee’s father. These facts are not disputed by the authorities below. The contention of the learned AR is that the authorities below have erred in restricting the assessee

SEKHON JAGTAR SINGH,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(5), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Years: 2017-18

housing loan, which was added to the total income of the assessee. As such, the income was determined in the assessment framed u/s 147 of the Act at Rs. 58,70,680/- only. As the assessee did not file original return of income, the AO initiated penalty proceedings for underreporting of income, which came to be confirmed

JAYARAMA REDDY BOOPESH REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), BENGALURU

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmed

houses or commercial property would decide to purchase real estate property based on the assessee's ownership or display of luxury cars. Thus, there is no real business connection between luxury car expenses and the assessee's real estate activities. 12.3 The learned DR also contended that the assessee had failed to produce any concrete evidence to establish business expediency

EXIDE LIFE INSURANCE COMPANY LIMITED,BANGALORE vs. CIT, BANGALORE

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

Bench: Shri. Vijay Pal Rao & Shri. S. Jayaraman

194,04,02,725/- and surplus in shareholders account for Rs 10,52,02,173/-. The net loss is shown at Rs 183,52,00,552/- which is the total income returned. In the assessment order, adjustments are made on transfer pricing and the loss is determined at Rs 181 ,03,3322.-. As per section 115B , the profits and gains

TIRUPATHI ENTERPRISES,BANGALORE vs. INCOME TAX OFFICER, WARD-7(2)(3), BANGALORE

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

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2018-19

194(b) of the Act. Assessee has offered return of income by applying 8% of the total receipt as income of the assessee under the presumptive taxation. According to the ld.AO, the provisions of presumptive taxation u/s. Page 3 of 6 44AD does not apply to the assessee as the income of the assessee is chargeable to tax under

M/S CONVENTION HOTELS INDIA PVT LTD ,BANGALORE vs. INCOME TAX OFFICER WARD-2(1)(2), BANGALORE

In the result appeal filed by assessee stands partly allowed

Bench: Shri A. K. Garodia & Smt. Beena Pillai

house property against which standard deduction is only allowable. Ground no.2 10 As regards trial run expenditure which has been treated as business loss as against treating it as a part of capital work in progress is not acceptable. The trial run expenditure is incurred by assessee was out of operations hotel act Goa during the year under consideration

PRAVESH KOTHARI L/H OF SOHANRAJ KHIMRAJ KOTHARI ,HUBLI vs. JOINT COMMISSIONER OF INCOME TAX RANGE-3, HUBLI

In the result appeal filed by assessee stands dismissed

Bench: Shri B.R.Baskaran & Smt.Beena Pillai, Judical Member

section 194 J is not applicable to present facts. Furthere there do not exist any employee employer relationship between assessee and the person for any other provisions to be applicable. We direct Ld.AO to delete the addition made u/s.40 a (ia) of the Act. Accordingly, this ground raised by assessee stands allowed. 5. Ground No.3 is in respect of addition

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

194 have examined in detail the legislative intent behind the provisions in Chapter-X. It is also a matter of common knowledge and record that provisions of sections 10A/10AA/10B except rack are incentives with an aim to augment the foreign exchange for the country. These provisions cannot be a licensed to an assessee to charge a lower price

BADERUNNISA ,BENGALURU vs. INCOME TAX OFFICER, WARD-3(2)(1), BANGALORE

In the result appeal of the assessee is allowed

Bench: Shri Waseem Ahmedassessment Year: 2023-24

house property was sold for a consideration of Rs. 2 crores. The appellant assessee claimed that entire sale consideration was received in her bank account only after deduction of TDS amounting to Rs. 2 Lakh only in her name only. As per the assessee, she computed the capital gain on the sale of the property along tax liability

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

194 I and the 2014-15 8.2. NA NA NA NA appellant is not able to deduct tax on the payment of rent 2015-16 8.2. NA NA NA NA towards generators under Section 1941 since the amount paid to the payee does not 8.2. NA NA NA NA 2016-17 exceed the threshold limit prescribed

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

194 I and the 2014-15 8.2. NA NA NA NA appellant is not able to deduct tax on the payment of rent 2015-16 8.2. NA NA NA NA towards generators under Section 1941 since the amount paid to the payee does not 8.2. NA NA NA NA 2016-17 exceed the threshold limit prescribed

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

194 I and the 2014-15 8.2. NA NA NA NA appellant is not able to deduct tax on the payment of rent 2015-16 8.2. NA NA NA NA towards generators under Section 1941 since the amount paid to the payee does not 8.2. NA NA NA NA 2016-17 exceed the threshold limit prescribed

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

194 I and the 2014-15 8.2. NA NA NA NA appellant is not able to deduct tax on the payment of rent 2015-16 8.2. NA NA NA NA towards generators under Section 1941 since the amount paid to the payee does not 8.2. NA NA NA NA 2016-17 exceed the threshold limit prescribed