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

In the result the appeal of the assessee is hereby partly allowed\nfor statistical purposes

houses or commercial\nproperty would decide to purchase real estate property based on the\nassessee's ownership or display of luxury cars. Thus, there is no real\nbusiness connection between luxury car expenses and the assessee's\nreal estate activities.\n12.3 The learned DR also contended that the assessee had failed to\nproduce any concrete evidence to establish business expediency

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

In the result the appeal of the assessee is hereby partly allowed\nfor statistical purposes

houses or commercial\nproperty would decide to purchase real estate property based on the\nassessee's ownership or display of luxury cars. Thus, there is no real\nbusiness connection between luxury car expenses and the assessee's\nreal estate activities.\n\n12.3 The learned DR also contended that the assessee had failed to\nproduce any concrete evidence to establish business

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

In the result the appeal of the assessee is hereby partly allowed\nfor statistical purposes

houses or commercial\nproperty would decide to purchase real estate property based on the\nassessee's ownership or display of luxury cars. Thus, there is no real\nbusiness connection between luxury car expenses and the assessee's\nreal estate activities.\n12.3 The learned DR also contended that the assessee had failed to\nproduce any concrete evidence to establish business expediency

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

In the result the appeal of the assessee is hereby partly allowed\nfor statistical purposes

houses or commercial\nproperty would decide to purchase real estate property based on the\nassessee's ownership or display of luxury cars. Thus, there is no real\nbusiness connection between luxury car expenses and the assessee's\nreal estate activities.\n12.3 The learned DR also contended that the assessee had failed to\nproduce any concrete evidence to establish business expediency

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

houses or commercial\nproperty would decide to purchase real estate property based on the\nassessee's ownership or display of luxury cars. Thus, there is no real\nbusiness connection between luxury car expenses and the assessee's\nreal estate activities.\n12.3 The learned DR also contended that the assessee had failed to\nproduce any concrete evidence to establish business expediency

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

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 KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRLCE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

194J come into operation together. The\nsituation currently under adjudication is similar, the income in the hands of\nthe seconded employees( based on the duration of stay) in any case is\ntaxable in India under section 5 read with section 9(1) of the Income Tax Act\nas the income has accrued or arose in India. On the other hand

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

194J come into operation together. The\nsituation currently under adjudication is similar, the income in the hands of\nthe seconded employees( based on the duration of stay) in any case is\ntaxable in India under section 5 read with section 9(1) of the Income Tax Act\nas the income has accrued or arose in India. On the other hand

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

194J come into operation together. The\nsituation currently under adjudication is similar, the income in the hands of\nthe seconded employees( based on the duration of stay) in any case is\ntaxable in India under section 5 read with section 9(1) of the Income Tax Act\nas the income has accrued or arose in India. On the other hand