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

M/S SYNDICATE BANK,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, UDUPI

In the result, appeal of the revenue in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment 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

KARNATAKA BANK LTD,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX , MANGALURU

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

reassess under Section 147 or pass an order\nenhancing the assessment or reducing a refund already made or\notherwise increasing the liability of the assessee under Section 154, for\nany assessment year beginning on or before the 1st day of April 2001.\n9.\nFrom perusal of Section 14A of the Act, it is evident that for the\npurposes of computing

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

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

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2020-21

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

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

In the result, revenue’s appeal in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment 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

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

In the result, revenue’s appeal in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment 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

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1), MANGALURU, MANGALURU vs. KARNATAKA BANK LTD., MANGALURU

Appeals of the revenue are partly allowed for\nstatistical purposes

reassess under Section 147 or pass an\norder enhancing the assessment or reducing a refund already\nmade or otherwise increasing the liability of the assessee under\nSection 154, for any assessment year beginning on or before the\n1st day of April 2001.\n9. From perusal of Section 14A of the Act, it is evident that for\nthe purposes of computing

KARNATAKA BANK LTD,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, MANGALORE

Appeals of the revenue are partly allowed for statistical purposes

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.\n\n9. From perusal of Section 14A of the Act, it is evident that for the purposes

KARNATAKA BANK LTD,MANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, MANGALORE

In the result, the appeal of the revenue for AYs 2016-17 and\n2017-18 are partly allowed for statistical purposes

reassess under Section 147 or pass an\norder enhancing the assessment or reducing a refund already\nmade or otherwise increasing the liability of the assessee under\nSection 154, for any assessment year beginning on or before the\n1st day of April 2001.\n9.\nFrom perusal of Section 14A of the Act, it is evident that for\nthe purposes of computing

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1), MANGALURU, MANGALURU vs. KARNATAKA BANK LTD., MANGALURU

In the result, the appeal of the revenue for AYs 2016-17 and\n2017-18 are partly allowed for statistical purposes

reassess under Section 147 or pass an\norder enhancing the assessment or reducing a refund already\nmade or otherwise increasing the liability of the assessee under\nSection 154, for any assessment year beginning on or before the\n1st day of April 2001.\n9. From perusal of Section 14A of the Act, it is evident that for\nthe purposes of computing

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeal filed by the Revenue is allowed for statistical purpose

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahuthe Dy. Commissioner Of Vs Shri C. Gangadhara Murthy Income-Tax, No. 322, 3Rd A Corss, 2Nd Block Circle - 6(2)(1) 3Rd Stage, Basaveshwaranagar Bangalore . Bangalore 560079. Pan – Agipg 2668 N (Appellant) (Respondent)

u/s 143(3) of the Act as per the return filed by the assessee under Section 139 of the Act. Similar issue has been decided by the coordinate Bench of the ITAT Lucknow reported in the case of Kailash Auto Finance Ltd. vs. Assistant Commissioner of Income Tax-4, Kanpur (2009) 32 SOT 80 (Lucknow). After going through this judgement

DEPUTY COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. ALGONOMY SOFTWARE PRIVATE LIMITED (FORMERLY KNOWN AS MANTHAN SOFTWARE SERVICES PVT LTD), BANGALORE

In the result, all the appeals filed by the revenue stands\ndismissed and the cross objections being C

reassessment\nproceeding u/s. 147 was initiated by the Ld.AO and\nconsequently by and under the order passed under section\n143(3) r.w.s. 147 of the Act, disallowance of sales commission\npaid to MSI was made under section 40(a)(ia) of the Act which\nwas challenged by the assessee before the First Appellate\nAuthority. However, the order was made reversed

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

In the result, appeals filed by assessee and revenue stands partly allowed for statistical purposes

Bench: Chandra Poojari & Smt. Beena Pillai

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the ITA Nos. 391, 392 & 663/Bang/2023 Page 9 of 31 assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, appeals filed by assessee and revenue stands partly allowed for statistical purposes

Bench: Chandra Poojari & Smt. Beena Pillai

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the ITA Nos. 391, 392 & 663/Bang/2023 Page 9 of 31 assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, appeals filed by assessee and revenue stands partly allowed for statistical purposes

Bench: Chandra Poojari & Smt. Beena Pillai

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the ITA Nos. 391, 392 & 663/Bang/2023 Page 9 of 31 assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section

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

vii) of the Act read with Article of the DTAA. These judgements are as follows:  Karnataka HC judgment in Flipkart Internet (P.) Ltd (2022) 139 taxmann.com 595;(page 57-77 case law compilation)  Delhi ITAT in Ernst & Young US LLP [2023] 153 taxmann.com 95 (Delhi-Trib); (page 78-87 case law compilation)  Delhi HC in Boeing India

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

vii) of the Act read with Article of the DTAA. These judgements are as follows:  Karnataka HC judgment in Flipkart Internet (P.) Ltd (2022) 139 taxmann.com 595;(page 57-77 case law compilation)  Delhi ITAT in Ernst & Young US LLP [2023] 153 taxmann.com 95 (Delhi-Trib); (page 78-87 case law compilation)  Delhi HC in Boeing India

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

vii) of the Act read with Article of the DTAA. These judgements are as follows:  Karnataka HC judgment in Flipkart Internet (P.) Ltd (2022) 139 taxmann.com 595;(page 57-77 case law compilation)  Delhi ITAT in Ernst & Young US LLP [2023] 153 taxmann.com 95 (Delhi-Trib); (page 78-87 case law compilation)  Delhi HC in Boeing India