INCOME TAX OFFICER, WARD - 3(2)(3), BANGALORE vs. SRI MADE GOWDA THIBBE GOWDA, BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2008-09

189 TAXMAN 1 (BOM.), the Hon’ble Bombay High Court held as under:- “For all these reasons, it is evident that there was absolutely no basis for the first respondent to form a belief that any income chargeable to tax has escaped assessment within the meaning of the substantive provisions of section 147. Explanation (2) to section

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

In the result, all the appeals filed by the assessee stands\npartly allowed and all the stay petitions filed by the assessee\nstands dismissed as infructuous

section\n201 of the Act without analyzing the facts of\npresent case and jurisprudence in this regard\nGround-3\nOn the facts and in the circumstances of the case & in law,\nthe Ld. DRP/AO erred in holding that the interconnect\nusage charges amounting to INR 39.58.39.947 received\nby the Appellant from various Indian Telecom Operators\n(\"ITOs\") accrues

SHRI. K. MUNIRAJU,BANGALORE vs. PRINCIPAL COMMISSIONER INCOME TAX, CENTRAL, BANGALORE

In the result appeals filed by assessee for asst

Bench: Shri A.K Garodia & Smt. Beena Pillai

68 was agated, the Pune ITAT in view of the Bombay High Court judgment set aside the order of the Assessing Officer passed u/s 153A of the Income Tax Act, 1961. 2. The Delhi Tribunal in case of Lord Krishna Dwellers (P) Ltd. Vs DCITITA No. 5294/DEL/2013 and 2403/DEL/2014 stated that "the transactions found in the sale deeds are duly

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

68,30,289/- for various FYs in the case of BNHL. A Sworn statement was also recorded from Shri Kayum Dhanani, Director of BNHL and the above issue was confronted to him. He agreed to offer the same as additional income in the hands of assessee. During the course of assessment proceedings, the assessee was asked to give the year

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

68,30,289/- for various FYs in the case of BNHL. A Sworn statement was also recorded from Shri Kayum Dhanani, Director of BNHL and the above issue was confronted to him. He agreed to offer the same as additional income in the hands of assessee. During the course of assessment proceedings, the assessee was asked to give the year

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

68,30,289/- for various FYs in the case of BNHL. A Sworn statement was also recorded from Shri Kayum Dhanani, Director of BNHL and the above issue was confronted to him. He agreed to offer the same as additional income in the hands of assessee. During the course of assessment proceedings, the assessee was asked to give the year

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of the Act has already been completed. The loan transactions were carried out through banking channel and duly recorded in the books of accounts. The learned accordingly argued that for the under consideration a regular item already disclosed in the books cannot be disturbed in the absence of incriminating material found during the search. There was no incriminating material

M/S INFOSYS LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

3,15,57,928 Fees Commission Software Africa TREVALLY FINANCIAL South 35,15,794 Fees Commission SOFTWARE Africa WAREEF UNITED Saudi (30,88,272) BAP Commission COMPANY, Arabia TOTAL 23,68,35,533 13.5. The Ld.AR relied on the decision of Hon’ble Delhi High Court in case of DIT(IT) v Panalfa Autoelektrik Ltd reported in (2014) 49 taxmann.com

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

In the result, appeals filed by the assessee are partly allowed

68,30,289/-\nfor various FYs in the case of\nBNHL. A Sworn statement was also recorded from Shri Kayum Dhanani,\nDirector of BNHL and the above issue was confronted to him. He agreed to\noffer the same as additional income in the hands of assessee. During the course\nof assessment proceedings, the assessee was asked to give the year