M/S. TATA ELXSI LIMITED,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

housing projects or a\nship in Nava Sheva. Ownership of a ship per se will not attract Section 80-/B (6). It\nis the profits arising from the business of a ship which attracts sub-section (6). In\nother words, deduction under sub-section (6) at the specified rate has linkage to the\nprofits derived from the shipping operations. This

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

391 ITR 218 held that only expenditure incurred to earn exempt income should be disallowed and expenditure incurred to protect, preserve, IT(TP)A No.735/Bang/2018 & M/s. Infosys Limited, Bangalore Page 10 of 85 maintain and utilize the tax free investment should not be disallowed under section 14A. • Infosys Ltd is a fully owned subsidiary of the appellant. Investment in shares

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

391 ITR 218 held that only expenditure incurred to earn exempt income should be disallowed and expenditure incurred to protect, preserve, IT(TP)A No.735/Bang/2018 & M/s. Infosys Limited, Bangalore Page 10 of 85 maintain and utilize the tax free investment should not be disallowed under section 14A. • Infosys Ltd is a fully owned subsidiary of the appellant. Investment in shares

LATE SMT.K.LEELAVATHY BY L/R SHRI M.THIMMEGOWDA ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE

In the result, all the appeals by the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Co-operative Society (‘VBEHCS’). As a result, proceedings under section 153C of the Income- tax Act, 1961 (‘the Act’) were initiated in the Appellant’s case. 4. From the return of income, the AO noted that the Appellant has claimed the income arising from sale of agricultural lands as exempt. It was submitted that the agricultural lands are located

LATE SMT.K.LEELAVATHY BY L/R SHRI M.THIMMEGOWDA ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE

In the result, all the appeals by the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Co-operative Society (‘VBEHCS’). As a result, proceedings under section 153C of the Income- tax Act, 1961 (‘the Act’) were initiated in the Appellant’s case. 4. From the return of income, the AO noted that the Appellant has claimed the income arising from sale of agricultural lands as exempt. It was submitted that the agricultural lands are located

LATE SMT.K>LEELAVATHY BY L/R SHRI.M.THIMMEGOWDA ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE

In the result, all the appeals by the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Co-operative Society (‘VBEHCS’). As a result, proceedings under section 153C of the Income- tax Act, 1961 (‘the Act’) were initiated in the Appellant’s case. 4. From the return of income, the AO noted that the Appellant has claimed the income arising from sale of agricultural lands as exempt. It was submitted that the agricultural lands are located

LATE SMT.K.LEELAVATHY, BY L/R SHRI M.THIMMEGOWDA ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE

In the result, all the appeals by the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Co-operative Society (‘VBEHCS’). As a result, proceedings under section 153C of the Income- tax Act, 1961 (‘the Act’) were initiated in the Appellant’s case. 4. From the return of income, the AO noted that the Appellant has claimed the income arising from sale of agricultural lands as exempt. It was submitted that the agricultural lands are located

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

property of assessee and Spreadtrum under the Settlement Agreement. This is clear from the term "Independently Owned IPR" as understood under the Settlement Agreement which means background IPR which in turn means that is owned or controlled by a party existing prior to the beginning of the joint development project or resulting from activities which are independent from and concurrent

M/S. WIPRO LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(2), BANGALORE

In the result, the appeal filed by the assessee is treated as partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

property of assessee and Spreadtrum under the Settlement Agreement. This is clear from the term "Independently Owned IPR" as understood under the Settlement Agreement which means background IPR which in turn means that is owned or controlled by a party existing prior to the beginning of the joint development project or resulting from activities which are independent from and concurrent

VAIDYA SRIKANTAPPA SADASHIVAIAH SRIKANTH,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE- 1, , BANGALORE

391], (Forward Construction\nCo.) the Apex court found fault with the High Court in holding that the\nearlier judgment would not operate as res judicata as one of the grounds\ntaken in the subsequent petition was conspicuous by its absence in the earlier\npetition. Explanation IV to Section 11 CPC was relied upon to observe that\nany matter which might

M/S. HANUMANTHAPPA CHANDRASHEKAR,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 3(2)(1), BANGALORE

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

Bench: Shri Chandra Poojari

391], (Forward Construction Co.) the Apex court found fault with the High Court in holding that the earlier judgment would not operate as res judicata as one of the grounds taken in the subsequent petition was conspicuous by its absence in the earlier petition. Explanation IV to Section 11 CPC was relied upon to observe that any matter which might

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Housing Development Company Vs. DCIT (274 CTR 122), wherein held as follows:- “10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Housing Development Company Vs. DCIT (274 CTR 122), wherein held as follows:- “10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section

INCOME TAX OFFICER, W-1, VIJAYANAGAR vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Housing Development Company Vs. DCIT (274 CTR 122), wherein held as follows:- “10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section

INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Housing Development Company Vs. DCIT (274 CTR 122), wherein held as follows:- “10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Housing Development Company Vs. DCIT (274 CTR 122), wherein held as follows:- “10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section

SMT. SUNITH SINGH MURALIDHARA ,HOSPET vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2015-16

House, 9th Cross, Income Tax, 16th Ward, Basaveshwara Badavane, Central Circle – 1(4), Bengaluru. Hospet – 583 201. . PAN – ASXPM 3139 K APPELLANT RESPONDENT Assessee by : Shri G Venkatesh, Advocate Revenue by : Shri V Parithivel, JCIT (DR) Date of hearing : 04.09.2024 Date of Pronouncement : 19.11.2024 O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed

FATHIMATH SOUDHA ,DAKSHINA KANNADA vs. INCOME TAX OFFICER, WARD-2(5), MANGALORE

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

section 69A of the Act was limited to\nRs.9,05,500/- (thereby granting a relief of Rs.1,54,500/-). The relevant finding of\nthe CIT(A) reads as follows:\n“5.4 I have considered the assessment order, facts of the case, submissions\nand documents filed by the appellant during the appeal proceedings. It is\nobserved that the appellant deposited cash