RAICHUR CITY URBAN CO-OPERATIVE BANK LTD.,,RAICHUR vs. DIT, BANGALORE

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

Bench: Shri Inturi Rama Raoshri Laliet Kumarraichur City Urban Co-Operative Bank Ltd., Gunj Road, Raichur-584 102. . Appellant Vs. The Dy. Director Of Income-Tax Intelligence & Criminal Investigation, Bengaluru. . Respondent Appellant By : Shri B.S Sudheendra, C.A Respondent By : Shri G Kamaladar, Standing Counsel

80G] or] under section 263[or under section 272A] [or under section 271] [***] or an order passed by him under section 154 amending his order under section 263] [or an order passed by a [Principal Chief Commissioner or] Chief Commissioner or a [Principal Director General or] Director General or a [Principal Director or] Director under section 272A; [or]] an order

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

80G -- -- Representative 8. -- -- assessee Claim for deduction – 9. -- -- proviso to 40(a)(i) 10. MAT Credit -- -- 11. TDS Credit -- -- Incorrect Refund 12. -- -- Calculation 13. Education Cess -- -- Interest u/s. 234B -- -- Interest u/s. 234D -- -- 14. Initiation of penalty proceedings u/s. -- -- 271(1)(c). 2.1 However, for the sake of convenience, grounds raised by the assessee for A.Y. 2010-11 are reproduced

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

80G -- -- Representative 8. -- -- assessee Claim for deduction – 9. -- -- proviso to 40(a)(i) 10. MAT Credit -- -- 11. TDS Credit -- -- Incorrect Refund 12. -- -- Calculation 13. Education Cess -- -- Interest u/s. 234B -- -- Interest u/s. 234D -- -- 14. Initiation of penalty proceedings u/s. -- -- 271(1)(c). 2.1 However, for the sake of convenience, grounds raised by the assessee for A.Y. 2010-11 are reproduced

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

80G -- -- Representative 8. -- -- assessee Claim for deduction – 9. -- -- proviso to 40(a)(i) 10. MAT Credit -- -- 11. TDS Credit -- -- Incorrect Refund 12. -- -- Calculation 13. Education Cess -- -- Interest u/s. 234B -- -- Interest u/s. 234D -- -- 14. Initiation of penalty proceedings u/s. -- -- 271(1)(c). 2.1 However, for the sake of convenience, grounds raised by the assessee for A.Y. 2010-11 are reproduced

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

80G -- -- Representative 8. -- -- assessee Claim for deduction – 9. -- -- proviso to 40(a)(i) 10. MAT Credit -- -- 11. TDS Credit -- -- Incorrect Refund 12. -- -- Calculation 13. Education Cess -- -- Interest u/s. 234B -- -- Interest u/s. 234D -- -- 14. Initiation of penalty proceedings u/s. -- -- 271(1)(c). 2.1 However, for the sake of convenience, grounds raised by the assessee for A.Y. 2010-11 are reproduced

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

80G -- -- Representative 8. -- -- assessee Claim for deduction – 9. -- -- proviso to 40(a)(i) 10. MAT Credit -- -- 11. TDS Credit -- -- Incorrect Refund 12. -- -- Calculation 13. Education Cess -- -- Interest u/s. 234B -- -- Interest u/s. 234D -- -- 14. Initiation of penalty proceedings u/s. -- -- 271(1)(c). 2.1 However, for the sake of convenience, grounds raised by the assessee for A.Y. 2010-11 are reproduced

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

80G -- -- Representative 8. -- -- assessee Claim for deduction – 9. -- -- proviso to 40(a)(i) 10. MAT Credit -- -- 11. TDS Credit -- -- Incorrect Refund 12. -- -- Calculation 13. Education Cess -- -- Interest u/s. 234B -- -- Interest u/s. 234D -- -- 14. Initiation of penalty proceedings u/s. -- -- 271(1)(c). 2.1 However, for the sake of convenience, grounds raised by the assessee for A.Y. 2010-11 are reproduced

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

80G -- -- Representative 8. -- -- assessee Claim for deduction – 9. -- -- proviso to 40(a)(i) 10. MAT Credit -- -- 11. TDS Credit -- -- Incorrect Refund 12. -- -- Calculation 13. Education Cess -- -- Interest u/s. 234B -- -- Interest u/s. 234D -- -- 14. Initiation of penalty proceedings u/s. -- -- 271(1)(c). 2.1 However, for the sake of convenience, grounds raised by the assessee for A.Y. 2010-11 are reproduced

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

80G -- -- Representative 8. -- -- assessee Claim for deduction – 9. -- -- proviso to 40(a)(i) 10. MAT Credit -- -- 11. TDS Credit -- -- Incorrect Refund 12. -- -- Calculation 13. Education Cess -- -- Interest u/s. 234B -- -- Interest u/s. 234D -- -- 14. Initiation of penalty proceedings u/s. -- -- 271(1)(c). 2.1 However, for the sake of convenience, grounds raised by the assessee for A.Y. 2010-11 are reproduced

M/S ASTRAZENECA PHARMA INDIA LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX LARGE TAX PAYERS UNIT (LTU) CIRCLE-1 , BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.3250/Bang/2018 Assessment Year: 2014-15

penalty proceedings under section 274 read with section 271(1)(c) of the Act. 2. The first grounds for our consideration are ground Nos.1, 2 & 3, which reads as follows:- 1. “Impugned order of learned ("Ld.") AO/Transfer Pricing Officer ("TPO") and directions of Ld. DRP are based on incorrect appreciation of facts and incorrect interpretation of law 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

M/S. PAUL RESORTS & HOTELS PVT. LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

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 various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

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

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

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 various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1) , BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

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 various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

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

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

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 various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

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

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

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 various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

M/S. PAUL RESORTS & HOTELS PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

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 various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

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 various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts