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139 results for “house property”+ Section 195(2)clear

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Key Topics

Section 143(3)69Addition to Income69Section 201(1)61Section 153A56Deduction37Section 4030Section 9(1)(vi)29Section 6828Transfer Pricing

M/S PRESTIGE ESTATES PROJECTS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-18(1), BANGALORE

In the result, the appeal of the assessee is allowed

ITA 813/BANG/2019[2014-15]Status: DisposedITAT Bangalore02 Mar 2021AY 2014-15

Bench: Shri N.V.Vasudevan, Vp & Shri Chandra Poojari, Am

For Appellant: Sri.Padamchand Khincha, CAFor Respondent: Smt.R.Premi, JCIT-DR
Section 191Section 194Section 201Section 201(1)Section 206ASection 4

section 53A of the Transfer of Property Act. This agreement cannot, therefore, be said to be in the nature of a contract referred to in section 53A of the Transfer of Property Act. It cannot, therefore, be said that the provisions of section 2(47)(v) will apply in the situation before us. Considering the facts and circumstances

Showing 1–20 of 139 · Page 1 of 7

28
Section 234B26
Double Taxation/DTAA26
Section 10A25

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 497/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 496/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 499/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 544/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1448/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

housing project. The ultimate profits of assessee after adjusting disallowance under section 4orallia] of the Act would qualify for deduction under section 8oIB of the Act. This view was taken by the courts in the following cases: ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 17 of 45 [a] Income-tax Officer-Ward 5[1] 1Keval Construction

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1519/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

housing project. The ultimate profits of assessee after adjusting disallowance under section 4orallia] of the Act would qualify for deduction under section 8oIB of the Act. This view was taken by the courts in the following cases: ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 17 of 45 [a] Income-tax Officer-Ward 5[1] 1Keval Construction

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1520/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

housing project. The ultimate profits of assessee after adjusting disallowance under section 4orallia] of the Act would qualify for deduction under section 8oIB of the Act. This view was taken by the courts in the following cases: ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 17 of 45 [a] Income-tax Officer-Ward 5[1] 1Keval Construction

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1447/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

housing project. The ultimate profits of assessee after adjusting disallowance under section 4orallia] of the Act would qualify for deduction under section 8oIB of the Act. This view was taken by the courts in the following cases: ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 17 of 45 [a] Income-tax Officer-Ward 5[1] 1Keval Construction

INSTAKART SERVICES PRIVATE LIMITED,BANGALORE vs. ACIT, SPECIAL RANGE-3, BANGALORE

In the result appeal of the Revenue is hereby dismissed

ITA 544/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Vohra, Sr. Advocate and Ms. AnkitaFor Respondent: Shri Shivanad Kalakeri, CIT

house property, Profits and gains of business or profession, Capital gains and Income from other sources. Sec. 28 of the Act lays down various categories of income that shall be chargeable to income-tax under the head "Profits and gains of business or profession". The income of the Assessee in the present case would fall within

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

ITA 1345/BANG/2019[2017-18]Status: DisposedITAT Bangalore31 May 2022AY 2017-18

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

For Appellant: Shri Ajay Rotti, CA
Section 195Section 201(1)

195 of the Act on the amount aid to J&P Coats Ltd. Page 20 IT(IT)A Nos. 1344 & 1345/Bang/2019 20. Aggrieved by the order passed by the Ld.CIT(A), the assessee is in appeal before this Tribunal. 21. Before us, the Ld.AR submitted that, the view taken by authorities below is based on the amendment made to section

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

ITA 1344/BANG/2019[2016-17]Status: DisposedITAT Bangalore31 May 2022AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

For Appellant: Shri Ajay Rotti, CA
Section 195Section 201(1)

195 of the Act on the amount aid to J&P Coats Ltd. Page 20 IT(IT)A Nos. 1344 & 1345/Bang/2019 20. Aggrieved by the order passed by the Ld.CIT(A), the assessee is in appeal before this Tribunal. 21. Before us, the Ld.AR submitted that, the view taken by authorities below is based on the amendment made to section

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

ITA 191/BANG/2024[2013-14]Status: DisposedITAT Bangalore26 Mar 2024AY 2013-14

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

For Appellant: Shri Deepak Chopra, Ms. Priya Tandon, ShriFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 148Section 195Section 201Section 9(1)(vi)

2 to section 9(1)(vi) of the Act. The AO noted that the ITAT, Bangalore has held the payments made to GIL towards Adwords program as royalty vide its order dated 23.10.2017. 4. Based on the above information in the case of GIPL, the AO observed that the assessee-GIL has not filed return of income for the respective

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

ITA 194/BANG/2024[2016-17]Status: DisposedITAT Bangalore26 Mar 2024AY 2016-17

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

For Appellant: Shri Deepak Chopra, Ms. Priya Tandon, ShriFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 148Section 195Section 201Section 9(1)(vi)

2 to section 9(1)(vi) of the Act. The AO noted that the ITAT, Bangalore has held the payments made to GIL towards Adwords program as royalty vide its order dated 23.10.2017. 4. Based on the above information in the case of GIPL, the AO observed that the assessee-GIL has not filed return of income for the respective

GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE - 1(1), BANGALORE

In the result, the appeals of the assessee are allowed and the appeal filed by the revenue is dismissed

ITA 949/BANG/2017[2014 - 15]Status: DisposedITAT Bangalore15 Dec 2022

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(It)A No.1190/Bang/2014 Assessment Year: 2013-14

For Appellant: Shri Percy Pardiwala, Senior CounselFor Respondent: Smt. Susan D. George, D.R

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 INDIA PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE - 1(1), BANGALORE

In the result, the appeals of the assessee are allowed and the appeal filed by the revenue is dismissed

ITA 950/BANG/2017[2015 - 16]Status: DisposedITAT Bangalore15 Dec 2022

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(It)A No.1190/Bang/2014 Assessment Year: 2013-14

For Appellant: Shri Percy Pardiwala, Senior CounselFor Respondent: Smt. Susan D. George, D.R

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

M/S GOOGLE INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1) (INTERNATIONAL TAXATION) , BANGALORE

In the result, the appeals of the assessee are allowed and the appeal filed by the revenue is dismissed

ITA 97/BANG/2019[2016-17]Status: DisposedITAT Bangalore15 Dec 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(It)A No.1190/Bang/2014 Assessment Year: 2013-14

For Appellant: Shri Percy Pardiwala, Senior CounselFor Respondent: Smt. Susan D. George, D.R

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

DEPUTY DIRECTOR OF INCOME TAX(INTERNATIONAL TAXATION), BANGALORE vs. M/S GOOGLE INDIA P LTD, BANGALORE

In the result, the appeals of the assessee are allowed and the appeal filed by the revenue is dismissed

ITA 1295/BANG/2014[2013-14]Status: DisposedITAT Bangalore15 Dec 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(It)A No.1190/Bang/2014 Assessment Year: 2013-14

For Appellant: Shri Percy Pardiwala, Senior CounselFor Respondent: Smt. Susan D. George, D.R

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 INDIA PVT LTD,BANGALORE vs. JOINT DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION), BANGALORE

In the result, the appeals of the assessee are allowed and the appeal filed by the revenue is dismissed

ITA 1190/BANG/2014[2013-14]Status: DisposedITAT Bangalore15 Dec 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(It)A No.1190/Bang/2014 Assessment Year: 2013-14

For Appellant: Shri Percy Pardiwala, Senior CounselFor Respondent: Smt. Susan D. George, D.R

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

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, BANGALORE

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

ITA 2532/BANG/2019[2015-16]Status: DisposedITAT Bangalore19 May 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai for Shri K.R. VasudevanFor Respondent: Shri Sankar Ganesh K., D.R
Section 143(3)Section 144C(13)Section 14ASection 37Section 92C

House [1986] 157 ITR 86 were under the Income Tax Act and the observations made and the test indicated therein were in the context of the wide definition of the word plant given in that Act and, therefore, not of universal application. Obviously, if plant is defined differently under a different provision or if the context so requires