IBM CORPORATION,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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

u/s 273B was applied ‘reasonable cause’ under section 273B of based on the facts of that case. the Act. - The reference to the above case by the (Page 17-18 of the CIT(A) order) Assessee was only in the context of the principle emanating from the same which could also be used in the context of section 270A

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

u/s 273B was applied ‘reasonable cause’ under section 273B of based on the facts of that case. the Act. - The reference to the above case by the (Page 17-18 of the CIT(A) order) Assessee was only in the context of the principle emanating from the same which could also be used in the context of section 270A

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

u/s 273B was applied ‘reasonable cause’ under section 273B of based on the facts of that case. the Act. - The reference to the above case by the (Page 17-18 of the CIT(A) order) Assessee was only in the context of the principle emanating from the same which could also be used in the context of section 270A

DCIT, CENTRAL CIRCLE, BELLARI vs. M/S. NAVODAYA EDUCATION TRUST, RAICHUR

In the result, the appeal of the revenue is partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2009-10

147 of the Act.' 3.10 The ld. CIT(A) has considered the Para 2.1 of CBDT Circular No.11/2008, dated 19.12.2008 wherein states as under: “2.1 The newly inserted proviso to section 2(15) will not apply in respect of the first three limbs of section 2(15), i.e., relief of the poor, education or medical relief. Consequently, where the purpose

INTACT DEVELOPERS PRIVATE LIMITED ,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

250 of the Income Tax Act, 1961 (in short “The Act”). Since the legal issues involved & the grounds taken in all these three appeals of the same assessee are common, these are clubbed together, heard together and disposed of by this common order for the sake of convenience & brevity. 2. The assessee in ITA No.823/Bang/2025

INTACT DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

250 of the Income Tax Act, 1961 (in short “The Act”). Since the legal issues involved & the grounds taken in all these three appeals of the same assessee are common, these are clubbed together, heard together and disposed of by this common order for the sake of convenience & brevity. 2. The assessee in ITA No.823/Bang/2025

M/S. EUROFINS PEENYA RESOURCES PRIVATE LIMITED(FORMERLY KNOW AS EUROFINS ADVINUS LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal for AY 2013-14 is partly allowed

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadav

u/s 144B r.w.s. 147 of the Income-tax Act, 1961 (the Act) by the National Faceless Assessment Centre (ld. AO) was dismissed. Therefore, assessee is aggrieved and has preferred this appeal before us. 3. The assessee has raised the following grounds:- “1. General Ground 1.1. The order passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre

EUROFINS PEENYA RESOURCES PRIVATE LIMITED (FORMERLY KNOWN AS EUROFINS ADVINUS LIMITED) ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1) , BANGALORE

In the result, the appeal for AY 2013-14 is partly allowed

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadav

u/s 144B r.w.s. 147 of the Income-tax Act, 1961 (the Act) by the National Faceless Assessment Centre (ld. AO) was dismissed. Therefore, assessee is aggrieved and has preferred this appeal before us. 3. The assessee has raised the following grounds:- “1. General Ground 1.1. The order passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre

INTACT DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

Accordingly, the appeals of the assessee for the AY 2015-16\nto AY 2017-18 are allowed

u/s 144 r/w 147 are null & void.\n12.\nAccordingly, the appeals of the assessee for the AY 2015-16\nto AY 2017-18 are allowed.\nOrder pronounced in the open court on 24th Nov, 2025\nSd/-\n(Waseem Ahmed)\nAccountant Member\nBangalore,\nDated 24th Nov, 2025.\nVG/SPS\nSd/-\n(Keshav Dubey)\nJudicial Member\nCopy to:\n1. The Applicant

NVIDIA GRAPHICS PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), BANGALORE

In the result, appeal filed by the assessee s party allowed

Bench: Shri George George K & Ms. Padmavathi. Sr Assessment Year : 2014-15 M/S. Nvidia Graphics Pvt. Ltd., Vs. Acit, Mahadevpura Village, Central Circle – 2(4), K. R. Puram Hobli, Marathalli Bangalore. Bagmane Goldstone Building, North Tower, Mahadevpura S.O, Bangalore – 560 048. Pan : Aabcn 9200 H Appellant Respondent Assessee By : Shri. Nageshwar Rao, Advocate Revenue By : Ms. Neha Sahay, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 17.10.2024 Date Of Pronouncement : 23.10.2024

250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2014-15. 2. The grounds raised read as follows: General Grounds 1. Impugned order of CIT(A) is based on incorrect interpretation of facts and law, and bad in law. Re-assessment under section 147 r.w.s. 144B vide order dated

JADAGADDER PAKKERAPPA, LEGAL HEIR SAROJAMMA,SHIKARIPURA vs. INCOME TAX OFFICER, WARD-1 & TPS,, SHIMOGA

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17

250 of the Income Tax Act, 1961 (in short “The Act”) for the assessment year 2016-17. 2. The assessee has raised the following grounds of appeal: Jadagadder Pakkerappa, Shikaripura Page 2 of 20 Jadagadder Pakkerappa, Shikaripura Page 3 of 20 Jadagadder Pakkerappa, Shikaripura Page 4 of 20 3. The assessee late Shri Jadagadder Pakkerappa represented by his wife

M/S. TOYOTA KIRLOSKAR MOTOR PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, , BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2011-12 M/S. Toyota Kirloskar Motor Pvt. Ltd. Plot No.1, Bidadi Industrial Area So Bidadi Acit Vs. Ramanagar Ltu, Circle-1 Bengaluru 562 109 Banalore Pan No : Aaact5415B Appellant Respondent Appellant By : Sri Padam Chand Kincha, A.R. Respondent By : Smt. Kumutha D., D.R. Date Of Hearing : 24.09.2024 Date Of Pronouncement : 20.12.2024

u/s 250 of the Income Tax Act, 1961 (in short “The Act”). 2. The assessee has raised the following grounds of appeal: General Ground: 1. The Order of the learned Commissioner of Income Tax (Appeals)-12 (hereinafter referred to as CIT-(A)) to the extent prejudicial to the Appellant is bad in law. M/s. Toyota Kirloskar Motor Pvt. Ltd., Bangalore

SRI. ANNESH,UDUPI vs. INCOME-TAX OFFICER, WARD-1, CHIKMANGALUR

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojari

147 of the Act is bad in law since the mandatory conditions as envisaged in the Act to assume jurisdiction under section 148 did not exist or having not been complied with and consequently, the reassessment requires to be cancelled on the facts and circumstances of the case. f. The learned CIT(A) failed to appreciate the order of assessment

IBM CANADA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION, CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

reassessment\nproceedings.\nThe CIT(A) has distinguished the facts\nof the case from Karnataka HC's\nruling in Manjunatha Cotton &\nGinning Factory [2013] 35\nTaxmann.com 250 (Karnataka HC)\nThe CIT(A) has concluded that the\nprovisions of 270A(8) need not be\ninvoked and that the case of the\nAssessee is covered under section\n270A

ANANTULA VIJAY MOHAN ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

In the result, appeals filed by the assessee are allowed

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\Nita Nos.2059 & 2060/Bang/2024\N Assessment Years : 2016-17 & 2017-18\Nanantula Vijay Mohan\N9, Banjara Avenue Road\Nno.1, Banjara Hills\Nhyderabad 500 034\Npan No:Aelpm6515K\Nappellant\Nvs.\Ndcit\Ncircle-6(1)(1)\Nbangalore\Nrespondent\Nsp No.67/Bang/2024\N(Arising Out Of Ita No.2060/Bang/2024)\N Assessment Year: 2017-18\Nanantula Vijay Mohan\N9, Banjara Avenue Road\Nno.1, Banjara Hills\Nhyderabad 500 034\Npan No: Aelpm6515K\Nappellant\Nvs.\Ndcit\Ncircle-6(1)(1)\Nbangalore\Nrespondent\Nappellant By\Nrespondent By\N: Sri Padma Khincha, A.R.\N: Sri Sridhar E., D.R.\Ndate Of Hearing\Ndate Of Pronouncement:\N: 18.02.2025\N: 07.05.2025\Norder\Nper Laxmi Prasad Sahu:\Nthese Appeals At The Instance Of The Assessee Are Directed\Nagainst The Orders Of Ld. Cit(A)/Nfac, Delhi Both Dated 23.09.2024\Nvide Din & Order No. Itba/Nfac/S/250/2024-25/1068988279(1)\Nfor The Assessment Year 2016-17 & Vide Din & Order\Nno.Itba/Nfac/S/250/2024-25/1068999127(1) For The Assessment\Nyear 2017-18 Passed U/S 250 Of The Income Tax Act, 1961 (In Short\N\"The Act\"). Since Both These Appeals & The Stay Petition Are Of The\Nsame Assessee For The Different Assessment Years, These Are Clubbed\Ntogether, Heard Together & Disposed Of By This Common Order For\Nthe Sake Of Convenience & Brevity.\Nita No.2059/Bang/2024 (Ay 2016-17):\N2. First, We Take Up Ita No.2059/Bang/2024 For The Ay 2016-\N17 Wherein The Assessee Has Raised The Following Grounds Of Appeal:\N1. General\N1.

250 of the Income Tax Act, 1961 (in short\n\"The Act\"). Since both these appeals and the stay petition are of the\nsame assessee for the different assessment years, these are clubbed\ntogether, heard together and disposed of by this common order for\nthe sake of convenience and brevity.\nITA No.2059/Bang/2024 (AY 2016-17):\n2. First, we take

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2