M/S KBD SUGARS & DISTILLERIES LTD. vs. ACIT,

In the result, the appeals of the assessee for the Assessment Years 2008-

reassess under section 147 or pass an order enhancing the assessment or reducing the refund already made or otherwise increasing the liability of the assessee under section 154.” 10. It has been made clear by the Hon’ble High Court that sub-section (2) does not ifso facto empower the AO to apply the method prescribed by Rules straightaway without

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

2. First, we will take up ITA Nos.780 to 785/Bang/2024 (Revenue’s appeals). In these appeals, the only issue is with regard to 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

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

2. First, we will take up ITA Nos.780 to 785/Bang/2024 (Revenue’s appeals). In these appeals, the only issue is with regard to 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

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

2. First, we will take up ITA Nos.780 to 785/Bang/2024 (Revenue’s appeals). In these appeals, the only issue is with regard to 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

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

2. First, we will take up ITA Nos.780 to 785/Bang/2024 (Revenue’s appeals). In these appeals, the only issue is with regard to 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

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.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

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.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

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.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

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.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

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.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

M/S KBD SUGARS & DISTILLERIES LTD,BANGALORE vs. ASST. COMMISSIONER OF INCOME-TAX, BANGALORE

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

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

reassess under section 147 or pass an order enhancing the assessment or reducing the refund already made or otherwise increasing the liability of the assessee under section 154.” 10. It has been made clear by the Hon’ble High Court that sub-section (2) does not if so facto empower the AO to apply the method prescribed by Rules straightaway

PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 1(3), BENGALURU, BANGALORE

In the result the appeal of the assessee is allowed

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)

reassessment proceedings under section 147 of the Act are invalid and bad in law. 3. Assessment Order passed by the Learned AO under section 144 rws 147 rws 144C(13) of the Act is barred by limitation under section 153 of the Act 3.1. On the facts and in the circumstances of the case and in law, the Assessment Order

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

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A of the Act, it is evident that for the purposes of computing

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

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A of the Act, it is evident that for the purposes of computing

MR.M J ARAVIND ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(3)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2011-12

2. Difference in credits made to capital account. 3. Interest income from Woodstock Ambience Pvt. Ltd. 4. The disallowance u/s 14A r.w.r. 8D. Page 10 of 24 5. However, in the final assessment order passed u/s. 143(3) r.w.s. 147 dated 28.12.2016, the AO has not made any addition with regard to first three issues and only made addition

M/S. MPHASIS SOFTWARE & SERVICES (INDIA) PRIVATE LIMITED ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 4(1)(2),, BENGALURU

In the result, the appeal of the Assessee is allowed

Bench: Shri N.V.Vasudevan & Shri B.R.Baskaranita No.1948(Bang)/2018 (Assessment Year : 2014-15) Mphasis Software & Services (India) Pvt.Ltd., Bagmane World Technology Centre, 1St Floor, Wing A, Wtc 3, Kr Puram, Marathahalli Outer Ring Road, Mahadevapura, Bengaluru-560 048 Pan No.Aaccm5986K Appellant Vs The Asst. Commissioner Of Income Tax Officer, Circle-4,(1)(2), Bangalore Respondent Appellant By : Shri K.R.Girish, Ca Revenue By : Shri Manjeet Singh, Addl.Cit

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154 for any assessment year beginning on or before the 1st day of April, 2001." 12. The circumstances in which the provisions of sub-sections (2) and (3) were introduced by an amendment

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A of the Act, it is evident that for the purposes of computing

UNITED BREWERIES LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-7(1)(1), BENGALURU

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise .increasing the liability of the assessee under section 154 for any assessment year beginning on or before the 1st day of April, 2001. 6.2.4 Accordingly, it was proposed to the assessee that the disallowance u/s 14A will be made by invoking

CANARA BANK (ERSTWHILE SYNDICATE BANK),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

In the result, appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A of the Act, it is evident that for the purposes of computing