M/S. UDUPI NIRMITHI KENDRA,UDUPI vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS) CIRCLE-1, MANGALORE

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

M/S. UDUPI NIRMITHI KEDRA,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE - 1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1,, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

M/S. DAKSHINA KANNADA NIRMITHI KENDRA,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE -1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK ,BENGALURU vs. INCOME-TAX OFFICE, WARD-5(2)(1), BENGALURU

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

housing etc. The Ld.AR submitted that the PCARD Banks\nare forwarding such loan applications along with technical and\nfinancial appraisal reports to the district officer of the assessee.\nThe amount required for the PCARD Banks for sanction of loans\ninvolved in such loan application is provided by the assessee to\nthe concerned PCARD Banks in the form of loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

housing etc. The Ld.AR submitted that the PCARD Banks\nare forwarding such loan applications along with technical and\nfinancial appraisal reports to the district officer of the assessee.\nThe amount required for the PCARD Banks for sanction of loans\ninvolved in such loan application is provided by the assessee to\nthe concerned PCARD Banks in the form of loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

housing etc. The Ld.AR submitted that the PCARD Banks\nare forwarding such loan applications along with technical and\nfinancial appraisal reports to the district officer of the assessee.\nThe amount required for the PCARD Banks for sanction of loans\ninvolved in such loan application is provided by the assessee to\nthe concerned PCARD Banks in the form of loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

housing etc. The Ld.AR submitted that the PCARD Banks\nare forwarding such loan applications along with technical and\nfinancial appraisal reports to the district officer of the assessee.\nThe amount required for the PCARD Banks for sanction of loans\ninvolved in such loan application is provided by the assessee to\nthe concerned PCARD Banks in the form of loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD- 5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

housing etc. The Ld.AR submitted that the PCARD Banks\nare forwarding such loan applications along with technical and\nfinancial appraisal reports to the district officer of the assessee.\nThe amount required for the PCARD Banks for sanction of loans\ninvolved in such loan application is provided by the assessee to\nthe concerned PCARD Banks in the form of loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME-TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

housing etc. The Ld.AR submitted that the PCARD Banks\nare forwarding such loan applications along with technical and\nfinancial appraisal reports to the district officer of the assessee.\nThe amount required for the PCARD Banks for sanction of loans\ninvolved in such loan application is provided by the assessee to\nthe concerned PCARD Banks in the form of loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

housing etc. The Ld.AR submitted that the PCARD Banks\nare forwarding such loan applications along with technical and\nfinancial appraisal reports to the district officer of the assessee.\nThe amount required for the PCARD Banks for sanction of loans\ninvolved in such loan application is provided by the assessee to\nthe concerned PCARD Banks in the form of loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. THE INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

housing etc. The Ld.AR submitted that the PCARD Banks\nare forwarding such loan applications along with technical and\nfinancial appraisal reports to the district officer of the assessee.\nThe amount required for the PCARD Banks for sanction of loans\ninvolved in such loan application is provided by the assessee to\nthe concerned PCARD Banks in the form of loans

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

housing etc. The Ld.AR submitted that the PCARD Banks\nare forwarding such loan applications along with technical and\nfinancial appraisal reports to the district officer of the assessee.\nThe amount required for the PCARD Banks for sanction of loans\ninvolved in such loan application is provided by the assessee to\nthe concerned PCARD Banks in the form of loans

SHOBHA JAIN ,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(5), BENGALURU

In the result, the appeal by the assessee is allowed for statistical\npurposes

section 56(2)(vii)(b) of the\nAct.\n10.\nIn view of the above, the appellant demonstrated with\ndocumentary evidence that the difference in actual consideration\npaid and the guidance value of the property\nbeen covered by 5% bandwidth (amendment retrospective in\nnature) the addition as made by the Assessing officer and as\nconfirmed

MR K. P. MANJUNATHA REDDY,BANGALORE vs. THE INCOME TAX OFFICER, WARD 4(3)(2), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

vii) Whether the land, though entered in the revenue records, had never been actually used for agriculture, that is, it had never been ploughed or tilled; whether the owner meant or intended to use it for agricultural purposes? (viii) Whether the land was situated in a developed area; whether its physical characteristics, surrounding situation and use of the lands

IBM CHINA HONG KONG LIMITED,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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\nPage 26 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada