INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

Section 194C is clearly applicable. 6. The Ld. CIT(A) erred in relying on the decision of the jurisdictional High Court in the case of M/s. Karnataka State Judicial Department Employees House Building Co-Operative Societies in ITA No. 1275 of 2036 and the ITAT's order in the case of M/s. Kautilya House Building Co-Operative Society Limited

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

Section 194C is clearly applicable. 6. The Ld. CIT(A) erred in relying on the decision of the jurisdictional High Court in the case of M/s. Karnataka State Judicial Department Employees House Building Co-Operative Societies in ITA No. 1275 of 2036 and the ITAT's order in the case of M/s. Kautilya House Building Co-Operative Society Limited

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

Section 194C is clearly applicable. 6. The Ld. CIT(A) erred in relying on the decision of the jurisdictional High Court in the case of M/s. Karnataka State Judicial Department Employees House Building Co-Operative Societies in ITA No. 1275 of 2036 and the ITAT's order in the case of M/s. Kautilya House Building Co-Operative Society Limited

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

Section 194C is clearly applicable. 6. The Ld. CIT(A) erred in relying on the decision of the jurisdictional High Court in the case of M/s. Karnataka State Judicial Department Employees House Building Co-Operative Societies in ITA No. 1275 of 2036 and the ITAT's order in the case of M/s. Kautilya House Building Co-Operative Society Limited

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

Section 194C is clearly applicable. 6. The Ld. CIT(A) erred in relying on the decision of the jurisdictional High Court in the case of M/s. Karnataka State Judicial Department Employees House Building Co-Operative Societies in ITA No. 1275 of 2036 and the ITAT's order in the case of M/s. Kautilya House Building Co-Operative Society Limited

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

Section 194C is clearly applicable. 6. The Ld. CIT(A) erred in relying on the decision of the jurisdictional High Court in the case of M/s. Karnataka State Judicial Department Employees House Building Co-Operative Societies in ITA No. 1275 of 2036 and the ITAT's order in the case of M/s. Kautilya House Building Co-Operative Society Limited

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

Section 194C is clearly applicable. 6. The Ld. CIT(A) erred in relying on the decision of the jurisdictional High Court in the case of M/s. Karnataka State Judicial Department Employees House Building Co-Operative Societies in ITA No. 1275 of 2036 and the ITAT's order in the case of M/s. Kautilya House Building Co-Operative Society Limited

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

M/S SCANIA COMMERCIAL VEHICLES INDIA PVT LTFD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

The Appeal of the Assessee is allowed

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

house property because income has been correctly offered by the Assessee under the head business income. Accordingly, ground no. 19 of the Assessee is allowed. 18. The Ground no. 20 of the Appeal is with respect to the correct carry forward of losses. The Assessee has computed the carry forward of the losses

SRI. K. SATISH KUMAR,BENGALURU vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE-9, BANGALORE

In the result, the assessee’s appeal is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2007-08

194C. Once the provisions of sec.194C is involved, all these payments can also be disallowed u/s 40(a)(ia) of the Act. This line of action is not considered by the AO. The disallowance made by the AO is based on documents found during the survey. Therefore, the view of the appellant that disallowances were made on surmise, assumption

PREMA KUMARI ,BANGALORE vs. ACIT, CIRCLE-4(3)(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

house property, capital gain and from other sources. She also claimed gross agricultural income of Rs. 1,14,61,407/- on account of supply of cattle feed and grass to the M/s Bannerghatta Biological Park. As such, the assessee has entered into an agreement with M/s Bannerghatta Biological Park for supply of food grains, pulses, and feeds

PREMA KUMARI,BANGALORE vs. INCOME TAX OFFICER, WARD-2(2)(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

house property, capital gain and from other sources. She also claimed gross agricultural income of Rs. 1,14,61,407/- on account of supply of cattle feed and grass to the M/s Bannerghatta Biological Park. As such, the assessee has entered into an agreement with M/s Bannerghatta Biological Park for supply of food grains, pulses, and feeds

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

house intangibles and owns proprietary software products. Some of the products developed and owned by the company are Unitrax (R), ACCURUSI, Service First TM. Further, as a result of high brand value, the company enjoys a high bargaining power in the market. The company has also incurred significant expenses in foreign currency amounting to 41.37% of its total sales which

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

DCIT, MANGALORE vs. M/S DELTA INFRALOGISTICS WORLDWIDE LTD, MANGALORE

In the result, the assessee’s appeals for Assessment Years 2003-04 to 2008-

Bench: Shri N. V. Vasudevan & Shri Jason P Boazappeal Nos. & Appellant Respondent Assessment Years

house agents at Mangalore. A search and seizure action under section 132 of the Income Tax Act, 1961 (in short ‘the Act’) was conducted at the premises of the assessee on 17.01.2008. Survey under section 133A of the Act was also conducted at the port premises of the assessee. In the course of the search, certain documents were found

M/S DELTA INFRALOGISTICS WORLDWIDE LIMITED,MANGALORE vs. ACIT, MANGALORE

In the result, the assessee’s appeals for Assessment Years 2003-04 to 2008-

Bench: Shri N. V. Vasudevan & Shri Jason P Boazappeal Nos. & Appellant Respondent Assessment Years

house agents at Mangalore. A search and seizure action under section 132 of the Income Tax Act, 1961 (in short ‘the Act’) was conducted at the premises of the assessee on 17.01.2008. Survey under section 133A of the Act was also conducted at the port premises of the assessee. In the course of the search, certain documents were found

DCIT, MANGALORE vs. M/S DELTA INFRALOGISTICS WORLDWIDE LTD, MANGALORE

In the result, the assessee’s appeals for Assessment Years 2003-04 to 2008-

Bench: Shri N. V. Vasudevan & Shri Jason P Boazappeal Nos. & Appellant Respondent Assessment Years

house agents at Mangalore. A search and seizure action under section 132 of the Income Tax Act, 1961 (in short ‘the Act’) was conducted at the premises of the assessee on 17.01.2008. Survey under section 133A of the Act was also conducted at the port premises of the assessee. In the course of the search, certain documents were found