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

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

SHILPA NARA,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

house property and income from other sources. A search under section 132 of the Act was carried out as on 12th 3. March 2020 in connection with M/s Sree Raghavendra Enterprise group including the residential premises of the assessee in the impugned search. 4. In consequence to the search, the proceeding under section 153A of the Act was initiated

SHILPA NARA,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

house property and income from other sources. A search under section 132 of the Act was carried out as on 12th 3. March 2020 in connection with M/s Sree Raghavendra Enterprise group including the residential premises of the assessee in the impugned search. 4. In consequence to the search, the proceeding under section 153A of the Act was initiated

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

IVORYBRICK HOMES LLP,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(2)(1), BANGALORE

In the result appeal filed by assessee stands allowed

Bench: Shri. B. R. Baskaran & Smt. Beena Pillaiassessment Year : 2016-17

House, Income Tax, Millers Road, Circle-1(2)(1), Vasanth Nagar, Vs. Bengaluru. Bengaluru-560 052. PAN – AAEFI 4636 E APPELLANT RESPONDENT : Shri C Sandeep, C.A Appellant by Respondent by : Shri Priyadarshi Mishra, Addl.CIT (DR) Date of Hearing : 13-01-2021 Date of Pronouncement : 01-02-2021 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeals have been filed by assessee

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 INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), 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

194J of the Act. 12. Facts of the case are that during the year under consideration, the assessee had incurred a sum of Rs. 585,30,20,535 towards purchase of software. Out of the said sum, the assessee had initially not deducted tax at source on a sum of Rs. 4,67,690/- 13. The AO in his order

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

194J of the Act. 12. Facts of the case are that during the year under consideration, the assessee had incurred a sum of Rs. 585,30,20,535 towards purchase of software. Out of the said sum, the assessee had initially not deducted tax at source on a sum of Rs. 4,67,690/- 13. The AO in his order

M/S. DELHI INTERNATIONAL AIRPORT PRIVATE LIMITED,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the assessees' appeals in ITA Nos

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

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. " 19. Gujarat High Court has also examined this issue in the case of Pr. CIT Vs. Saumya Construction Pvt. Ltd., and having relied upon the judgment of the Kabul Chawla, Delhi High Court

ASSISTANT COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S. GMR HYDERABAD INTERNATIONAL AIRPORT LTD,, BANGALORE

In the result, the assessees' appeals in ITA Nos

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

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. " 19. Gujarat High Court has also examined this issue in the case of Pr. CIT Vs. Saumya Construction Pvt. Ltd., and having relied upon the judgment of the Kabul Chawla, Delhi High Court

ASSISTANT COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S. GMR HYDERABAD INTERNATIONAL AIRPORT LTD,, BANGALORE

In the result, the assessees' appeals in ITA Nos

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

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. " 19. Gujarat High Court has also examined this issue in the case of Pr. CIT Vs. Saumya Construction Pvt. Ltd., and having relied upon the judgment of the Kabul Chawla, Delhi High Court

M/S.GMR HYDERABAD INTERNATIONAL AIRPORT LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the assessees' appeals in ITA Nos

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

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. " 19. Gujarat High Court has also examined this issue in the case of Pr. CIT Vs. Saumya Construction Pvt. Ltd., and having relied upon the judgment of the Kabul Chawla, Delhi High Court

ASSISTANT COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S. GMR HYDERABAD INTERNATIONAL AIRPORT LTD,, BANGALORE

In the result, the assessees' appeals in ITA Nos

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

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. " 19. Gujarat High Court has also examined this issue in the case of Pr. CIT Vs. Saumya Construction Pvt. Ltd., and having relied upon the judgment of the Kabul Chawla, Delhi High Court

ASSISTANT COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD., BANGALORE

In the result, the assessees' appeals in ITA Nos

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

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. " 19. Gujarat High Court has also examined this issue in the case of Pr. CIT Vs. Saumya Construction Pvt. Ltd., and having relied upon the judgment of the Kabul Chawla, Delhi High Court

M/S. DELHI INTERNATIONAL AIRPORT PRIVATE LIMITED,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the assessees' appeals in ITA Nos

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

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. " 19. Gujarat High Court has also examined this issue in the case of Pr. CIT Vs. Saumya Construction Pvt. Ltd., and having relied upon the judgment of the Kabul Chawla, Delhi High Court

ASSISTANT COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD., BANGALORE

In the result, the assessees' appeals in ITA Nos

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

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. " 19. Gujarat High Court has also examined this issue in the case of Pr. CIT Vs. Saumya Construction Pvt. Ltd., and having relied upon the judgment of the Kabul Chawla, Delhi High Court

ASSISTANT COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S. GMR HYDERABAD INTERNATIONAL AIRPORT LTD,, BANGALORE

In the result, the assessees' appeals in ITA Nos

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

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment. " 19. Gujarat High Court has also examined this issue in the case of Pr. CIT Vs. Saumya Construction Pvt. Ltd., and having relied upon the judgment of the Kabul Chawla, Delhi High Court