MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD. ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

MANIPAL HOSPITALS PVT. LTD (FORMERLY KNOWN AS COLUMBIA ASIA HOSPITALS PVT. LTD),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD.,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

MANIPAL GLOBAL EDUCATION SERVICES PVT LTD., ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(2), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

M/S. PLAZA AGENCIES PVT LTD., ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1) , BENGALURU

In the result, the appeal of the assessee is partly allowed

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year : 2018-19

disallowing Rs. 1,32,40,428/- u/s. 14A r.w. Rule 8D under the facts & circumstances 9. We have heard the rival submissions and perused the material on record. 10. The ground nos. 1 and 4 are general in nature and do not require any adjudication. 11. During the course of hearing, the Ld.AR of the assessee has not pressed ground

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BANGALORE

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance u/s 14A of the Income Tax Act, 1961 (in short “The Act”) read with Rule 8D of the Income Tax Rules. 3. Facts of the case are that on 21 .09.2017, a search action u/s. 132 of the Act was conducted in the case of M/S. Coffee Day Enterprises Ltd. at No. 23/2, Coffee Day Square, Vital Mallya Road

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY ENTERPRISES, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance u/s 14A of the Income Tax Act, 1961 (in short “The Act”) read with Rule 8D of the Income Tax Rules. 3. Facts of the case are that on 21 .09.2017, a search action u/s. 132 of the Act was conducted in the case of M/S. Coffee Day Enterprises Ltd. at No. 23/2, Coffee Day Square, Vital Mallya Road

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance u/s 14A of the Income Tax Act, 1961 (in short “The Act”) read with Rule 8D of the Income Tax Rules. 3. Facts of the case are that on 21 .09.2017, a search action u/s. 132 of the Act was conducted in the case of M/S. Coffee Day Enterprises Ltd. at No. 23/2, Coffee Day Square, Vital Mallya Road

DEPUTY COMMISSIONER OF INCOME-TAX, , BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance u/s 14A of the Income Tax Act, 1961 (in short “The Act”) read with Rule 8D of the Income Tax Rules. 3. Facts of the case are that on 21 .09.2017, a search action u/s. 132 of the Act was conducted in the case of M/S. Coffee Day Enterprises Ltd. at No. 23/2, Coffee Day Square, Vital Mallya Road

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

disallowance made by the assessee u/s. 14A on the premise that there is no any incurred expend are incurred by the assessee towards earning exempt income. The assessee’s own fund is more than the investments made and there is decrease in quantum of investments during the year by Rs.59.36 crores and the increase in the internal fund

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

disallowance made by the assessee u/s. 14A on the premise that there is no any incurred expend are incurred by the assessee towards earning exempt income. The assessee’s own fund is more than the investments made and there is decrease in quantum of investments during the year by Rs.59.36 crores and the increase in the internal fund

HEWLETT-PACKARD (INDIA) SOFTWARE OPERATION PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-(1)(1) , BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2014-15

147 of the Act dated 25.3.2022, the assessee preferred an appeal before the ld. CIT(A)/NFAC questioning the legal validity of the reassessment order dated 25.3.2022. 3.5 The ld. CIT(A) dismissed the appeal of the assessee on legal grounds as well as on merits raised during the appellate proceedings. The main contention

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/ and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

SYEDA MARIAM,BANGALORE vs. INCOME-TAX OFFICER, WARD-3(1)(4), BENGALURU

In the result we accepted the legal issue and held that the assessment order dated 30

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Syeda Mariam The Income Tax Officer No. 482, 14Th Main Ward - 3(1)(4) Koramangala 3Rd Block Vs. Bmtc Building, 80Ft. Road Bangalore 560034 6Th Block, Koramangala Pan – Aazpm2737P Bengaluru 560095 (Appellant) (Respondent) Assessee By: Shri Zain Ahmed Khan, Ca Revenue By: Shri V. Parithivel, Jcit-Dr Date Of Hearing: 18.06.2024 Date Of Pronouncement: 25.07.2024 O R D E R Per: Soundararajan K.,J.M. This Appeal Filed By The Assessee Challenges The Order Of The Cit(A)-11, Bengaluru Dated 28.12.2023 In Respect Of The Assessment Year (Ay) 2014-15. 2. The Brief Facts Of The Case Are That The Assessee Filed Her Return Of Income On 28.07.2014. Thereafter A Survey U/S. 133A Was Conducted At The Company M/S. Intact Developers P. Ltd., In Which The Assessee Is A Director & Based On The Survey It Was Found That The Assessee Had Lent Unsecured Loans To The Company & In Support Of The Unsecured Loans The Assessee Filed Confirmation Letters From The Company. Insofar As The Source For The Loan, The Assessee Submitted That She Got Capital Gain In Ays 2013-14 & 2014-15 & Out Of This She Offered Loans To The Company. The Ld. Assessing Officer (Ao) Verified The Details Filed By The Assessee & Came To The Conclusion That There

disallowing exemption u/s. 548 of the Act and the Ld. CIT(A) erred in confirming the same. 5 The Ld. AO and Ld. CIT(A) ought to have appreciated that the capital gains were reinvested in agricultural land in satisfaction of conditions laid down in section 54B of the IT Act. 6 Without prejudice to the above grounds

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/- and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order