M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

68,020/- and tax liability of Rs.14,08,015/- was paid and there was refund of Rs. 42,340/- . ITA Nos.294 to 296/Bang/2023 Nandi Hospitality Services Pvt. Ltd., Bangalore Page 4 of 22` 4.2. The Learned Deputy Commissioner of Income Tax, CPC has sent communication under section 143(1)(a) of the Act. Since the Authorized Representative does

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

68,020/- and tax liability of Rs.14,08,015/- was paid and there was refund of Rs. 42,340/- . ITA Nos.294 to 296/Bang/2023 Nandi Hospitality Services Pvt. Ltd., Bangalore Page 4 of 22` 4.2. The Learned Deputy Commissioner of Income Tax, CPC has sent communication under section 143(1)(a) of the Act. Since the Authorized Representative does

M/S. CONCORDE HOUSING CORPORATION PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

195, 7th Main, 4th Block, Jayanagar, Bangalore - 560011. Consequent to search action, a notice under Section 153A was issued to a t on 24.10.2016. In response, the appellant company submitted its Corporation Private Limited A.M. 2015-16 return of income on 12.12.2016, declaring a total income of Rs. 23,94,26,383/-. Subsequently, on 10.1 1.2017, the company' revised

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made

ACIT, CIRCLE-2(2)(1), BANGALORE vs. VASTIMAL BHIM RAJ SANCHETI, BANGALORE

In the result, the appeals of the Revenue are dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K

1) Section 68 can be invoked when following three conditions are satisfied (a) when there is credit of amounts in the books maintained by the assessee, (b) such credit has to be a sum of money during the previous year, (c) either the assessee offers no explanation about the nature and source of such credits found in the books

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

ACIT, CIRCLE 2(2)(1), BANGALORE vs. VASTIMAL BHIM RAJ SANCHETI, BANGALORE

In the result, the appeals of the Revenue are dismissed\nPronounced in the open court on the date mentioned on the caption\npage

1) Section 68 can be invoked when following three\nconditions are satisfied (a) when there is credit of amounts in\nthe books maintained by the assessee, (b) such credit has to be\na sum of money during the previous year, (c) either the\nassessee offers no explanation about the nature and source of\nsuch credits found in the books

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

68 Taxmann.com 8 (Delhi)\nPage 10 of 32\nS.P. Nos. 7 to 9/Bang/2024 &\nIT(IT)A Nos. 100 to 102/Bang/2024\n5. Neo Sport Broadcast (P.) Ltd. [2019] 107 Taxmann.com 17\n(Bombay)\n6. Viacom18 Media (P.) Ltd. [2022] 134 taxmann.com 243\n(Mumbai -Trib.) - Para 9 page 656 of PB which has followed\nBom HC decision in Neo Sports

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

Section 14A disallowance and interest on ECB loan from out of the total corporate expenses of Rs.157.15 crores and accordingly arrived at the figure of Rs.83.62 crores (referred above). The A.O. proposed to allocate the above said expenditure in the ratio of turnover of various divisions and units. 11.3 The assessee objected to the proposal put forth

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

Section 14A disallowance and interest on ECB loan from out of the total corporate expenses of Rs.157.15 crores and accordingly arrived at the figure of Rs.83.62 crores (referred above). The A.O. proposed to allocate the above said expenditure in the ratio of turnover of various divisions and units. 11.3 The assessee objected to the proposal put forth

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

Section\n153D. It is not an exercise dealing with a immaterial matter which\ncould be corrected by taking recourse to Section 292B of the Act.\n16. We are not inclined to interdict the order of the Tribunal.\n17. Accordingly, the appeal is closed.\n6.5 The above view taken by the Hon’ble Delhi High Court in the case

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

Section 9(1)(vi) of the Act. 10. Erred in upholding the order of the Ld JDIT that the amount payable by the Appellant to Google Ireland Limited is towards right to use of trademark and copyrighted computer program and process. hence is in the nature of 'Royalty' as per the Article 12 of the India Ireland Double Taxation

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

68,394 2009-10 94,88,913 2010-11 3,19,95,710 2011-12 2,44,56,548 2012-13 54,55,010 2. The proceedings u/s. 201(1) of the Act was initiated by the Officer after issuing a notice on 09.12.2012, 26.2.2013, 23.5.2013 & 20.8.2013. In reply of various notices, the DDIT (Intl. Taxn.) in para 6 mentioned

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

68,394 2009-10 94,88,913 2010-11 3,19,95,710 2011-12 2,44,56,548 2012-13 54,55,010 2. The proceedings u/s. 201(1) of the Act was initiated by the Officer after issuing a notice on 09.12.2012, 26.2.2013, 23.5.2013 & 20.8.2013. In reply of various notices, the DDIT (Intl. Taxn.) in para 6 mentioned

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

68,394 2009-10 94,88,913 2010-11 3,19,95,710 2011-12 2,44,56,548 2012-13 54,55,010 2. The proceedings u/s. 201(1) of the Act was initiated by the Officer after issuing a notice on 09.12.2012, 26.2.2013, 23.5.2013 & 20.8.2013. In reply of various notices, the DDIT (Intl. Taxn.) in para 6 mentioned

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

68,394 2009-10 94,88,913 2010-11 3,19,95,710 2011-12 2,44,56,548 2012-13 54,55,010 2. The proceedings u/s. 201(1) of the Act was initiated by the Officer after issuing a notice on 09.12.2012, 26.2.2013, 23.5.2013 & 20.8.2013. In reply of various notices, the DDIT (Intl. Taxn.) in para 6 mentioned