EPSILON ADVISORS P. LTD.,,BANGALORE vs. CIT, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

penalty u/s 271 (1) (c) of I. T. Act for A. Y. 2006 – 07 and remaining two appeals are also cross appeals filed by the assessee and revenue in quantum proceedings for the same year i.e. A. Y. 2006 – 07. All these appeals were heard together and are being disposed of by this common order for the sake of convenience

EPSILON ADVISORS P. LTD.,,BANGALORE vs. CIT, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

penalty u/s 271 (1) (c) of I. T. Act for A. Y. 2006 – 07 and remaining two appeals are also cross appeals filed by the assessee and revenue in quantum proceedings for the same year i.e. A. Y. 2006 – 07. All these appeals were heard together and are being disposed of by this common order for the sake of convenience

DCIT, BANGALORE vs. M/S EPSILON ADVISORS PVT. LTD.,, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

penalty u/s 271 (1) (c) of I. T. Act for A. Y. 2006 – 07 and remaining two appeals are also cross appeals filed by the assessee and revenue in quantum proceedings for the same year i.e. A. Y. 2006 – 07. All these appeals were heard together and are being disposed of by this common order for the sake of convenience

DCIT, BANGALORE vs. M/S EPSILON ADVISORS PVT. LTD.,, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

penalty u/s 271 (1) (c) of I. T. Act for A. Y. 2006 – 07 and remaining two appeals are also cross appeals filed by the assessee and revenue in quantum proceedings for the same year i.e. A. Y. 2006 – 07. All these appeals were heard together and are being disposed of by this common order for the sake of convenience

KOTARKI CONSTRUCTION PVT LTD ,BIDAR vs. JOINT COMMISSIONER OF INCOME TAX GULBARGA RANGE , GULBARGA

In the result, the appeal by the assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2010-11

depreciation claimed in respect 2,19,231/- of Guest House 10 Disallowance of expenditure U/s 40(a)(ia) of the 6,50,565/- IT Act in respect of lab testing charges 1,05,08,865/ Total Disallowances Deduction admissible U/s 80IA of the IT Act 189203125/- 3. Accordingly, the AO levied penalty of Rs.5,03,279 observing that the assessee

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

U/s 270A of the Act. In the opinion of ld. CIT(A)/NFAC the AO has failed to establish that any mens rea was involved & the assessee willfully misrepresented or suppressed the facts. 9.4 For the purpose of evaluating the correctness of rival submissions addressed we deem it apposite to extract section 270A of the Act herein below: 270A. Penalty

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE vs. M/S. MANIPAL HOSPITALS (BANGALORE) PRIVATE LIMITED, BENGALURU

In the result appeal of the Ld

Bench: Shri Prashant Maharishi, Hon’Ble & Shri Soundararajan K, Hon’Bledcit – Central Circle – 1(2) Vs. M/S. Manipal Hospitals Room No. 307, 3Rdfloor. (Bangalore) Private Limited C.R. Building, Queens Road 98/2, The Annex Bengaluru – 560001 Ruso Bagh Karnataka Off. Hal Airport Road Bengaluru – 560017 Karnataka Pan: Aaccv9562D (Applicant) (Respondent) Assessee Represented By: Sri S.K. Tulsiyan, Advocate Department Represented By: Smt Prajakta Thakur, Jcit Date Of Hearing:09.07.2025 Date Of Pronouncement 30.07.2025 O R D E R Per Prashant Maharishi: 1. Captioned Appeal Is Filed By Dcit – Central Circle – 1(2), Bengaluru Against The Appellate Order Passed By The Commissioner Of Income Tax (Appeals)-15, Bengaluru (“The Ld.Cit(A)”) Dated 28.02.2025 Wherein The Appeal Filed By The Assessee Against The Penalty Order Dated 25.03.2022 Passed By Dcit – Central

u/s 271(1)(c). It is seen that there is a mere mention as "Issue penalty notice u/s.271(1)(c) of the IT Act, 1961 accordingly." Further, the notice under 271(1)(c) has also been perused and it is seen that the appropriate limb has not been selected. 4.4. Therefore, respectfully following the Hon'ble Jurisdictional High Court

GOOGLE INDIA PVT. LTD. vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalties and consequences. 29. As per the services agreement, the assessee was providing information and information technology enabled services to Google Ireland. As regards ownership of intellectual property and ownership of derivate works, it was agreed that all intellectual property shall remain the exclusive property of Google Ireland. The confidential information provided by Google Ireland was to be employed

M/S GOOGLE INDIA PRIVATE LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 , BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalties and consequences. 29. As per the services agreement, the assessee was providing information and information technology enabled services to Google Ireland. As regards ownership of intellectual property and ownership of derivate works, it was agreed that all intellectual property shall remain the exclusive property of Google Ireland. The confidential information provided by Google Ireland was to be employed

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalties and consequences. 29. As per the services agreement, the assessee was providing information and information technology enabled services to Google Ireland. As regards ownership of intellectual property and ownership of derivate works, it was agreed that all intellectual property shall remain the exclusive property of Google Ireland. The confidential information provided by Google Ireland was to be employed

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalties and consequences. 29. As per the services agreement, the assessee was providing information and information technology enabled services to Google Ireland. As regards ownership of intellectual property and ownership of derivate works, it was agreed that all intellectual property shall remain the exclusive property of Google Ireland. The confidential information provided by Google Ireland was to be employed

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalties and consequences. 29. As per the services agreement, the assessee was providing information and information technology enabled services to Google Ireland. As regards ownership of intellectual property and ownership of derivate works, it was agreed that all intellectual property shall remain the exclusive property of Google Ireland. The confidential information provided by Google Ireland was to be employed

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalties and consequences. 29. As per the services agreement, the assessee was providing information and information technology enabled services to Google Ireland. As regards ownership of intellectual property and ownership of derivate works, it was agreed that all intellectual property shall remain the exclusive property of Google Ireland. The confidential information provided by Google Ireland was to be employed

MS GOOGLE INDIA PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BENGALURU

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalties and consequences. 29. As per the services agreement, the assessee was providing information and information technology enabled services to Google Ireland. As regards ownership of intellectual property and ownership of derivate works, it was agreed that all intellectual property shall remain the exclusive property of Google Ireland. The confidential information provided by Google Ireland was to be employed

GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalties and consequences. 29. As per the services agreement, the assessee was providing information and information technology enabled services to Google Ireland. As regards ownership of intellectual property and ownership of derivate works, it was agreed that all intellectual property shall remain the exclusive property of Google Ireland. The confidential information provided by Google Ireland was to be employed

M/S. SUBEX LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(2), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2579/Bang/2019 Assessment Year : 2015-16 M/S. Subex Ltd., The Deputy Rmz Ecoworld, Commissioner Of Outer Ring Road, Income Tax, Devarabisanahalli, Circle – 6(1)(2), Bangalore – 560 103. Vs. Bangalore. Pan: Aabcs9255R Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Sumer Singh Meena, Revenue By Cit-Dr Date Of Hearing : 11-07-2022 Date Of Pronouncement : 11-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 23/10/2019 Passed By Ld.Dcit, Circle – 6(1)(2), Bangalore For A.Y. 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Erroneous Transfer Pricing Adjustments Arising From Interest On Trade Receivables 1.1. The Deputy Commissioner Of Income Tax, Circle - 6(1)(2), Bangalore (Learned Assessing Officer' Or 'Ld. Ao') / Assistant Commissioner Of Income Tax, Transfer Pricing Circle - 1(3)(1) ('Learned Transfer Pricing Officer' Or 'Ld.

depreciation. The Hon'ble DRP has erred in not adjudicating this ground of objection raised by the Appellant before it. 3. Erroneous non-set-off of MAT credit entitlement 3.1. The Ld. AO has erred in law in not setting-off MAT credit entitlement pertaining to earlier AYs. The Hon'ble Page 3 of 9 IT(TP)A No. 2579/Bang/2019

THE INCOME TAX OFFICER WARD-2 , BAGALKOT vs. M/S RYTARA SAHAKARI SAKKARE KARKHANE NIYAMITHA , BAGALKOT

In the result, the appeal by the revenue is dismissed, while the CO is allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazassessment Year : 2010-11

u/s. 271(1)(c) of the Income Tax Act, 1961 (Act). In the Cross objection the Assessee has submitted that the penalty proceedings u/s.271(1)(c) of the Act has to be quashed on the ground that the show cause notice issued u/s.274 of the Act, before imposing penalty does not specify the exact charge against the Assessee and therefore

JOHN DEVELOPERS ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

penalty proceedings u/s 271(1)(c) of the Act is initiated separately. 14.5 With regard to Undisclosed income from transport business the ld. D.R. submitted that during the course of search, a document A/JDPL/12 was found and seized. It contained entries relating to income earned by the assessee while returning from the variousITA No.838 to 843/Bang/2023 M/s. Paul Resorts & Hotels