EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

68,000/- Rs. 808,05,00,000/- Intangible asset- Trade name Rs. 125,95,00,000/- Intangible asset- customer Rs. 30,060,000/- Rs. 85,33,00,000/- contacts Goodwill Rs. 280,39,08,132/- Rs. 2016,21,78,480/- Total Rs. 412,05,36,132/- Rs. 3035,54,78,480/- 21. On the above identified intangible assets, the assessee

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

Bench: Shri Waseem Ahmed & Shri Soundararajan K

68,000/- Rs. 808,05,00,000/- Intangible asset- Trade name Rs. 125,95,00,000/- Intangible asset- customer Rs. 30,060,000/- Rs. 85,33,00,000/- contacts Goodwill Rs. 280,39,08,132/- Rs. 2016,21,78,480/- Total Rs. 412,05,36,132/- Rs. 3035,54,78,480/- 21. On the above identified intangible assets, the assessee

M/S VOLVO INDIA PVT. LTD. vs. ACIT, BANGALORE

In the result, appeal of the Assessee is partly allowed

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

ii) of the Act. The Hon’ble Karnataka High Court in the case of CIT v. Manipal Universal Learning (P.) Ltd : 215 Taxman 151 (Kar.)(Mag.), following the decision of the Supreme Court in Smiffs Securities (supra) held that goodwill is an asset under Explanation 3(b) to section 32(1) of the Act and therefore depreciation is allowable

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

32 of 64 43. We have heard both the parties and perused the material on record. Section 147 of the Act states that “if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

32 of 64 43. We have heard both the parties and perused the material on record. Section 147 of the Act states that “if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess

M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

ii) Clause (b) of sec. 36(1)(viia) shall be applicable to a bank incorporated by or under the laws of a country outside India. The quantum of deduction is 5% of the total income (computed before making any deduction under this clause and Chapter VIA). M/s. Bank of Baroda (iii) Clause (c) is applicable to a public financial institution

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

ii) Clause (b) of sec. 36(1)(viia) shall be applicable to a bank incorporated by or under the laws of a country outside India. The quantum of deduction is 5% of the total income (computed before making any deduction under this clause and Chapter VIA). M/s. Bank of Baroda (iii) Clause (c) is applicable to a public financial institution

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

ii) Clause (b) of sec. 36(1)(viia) shall be applicable to a bank incorporated by or under the laws of a country outside India. The quantum of deduction is 5% of the total income (computed before making any deduction under this clause and Chapter VIA). (iii) Clause (c) is applicable to a public financial institution or a State financial

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

ii) Clause (b) of sec. 36(1)(viia) shall be applicable to a bank incorporated by or under the laws of a country outside India. The quantum of deduction is 5% of the total income (computed before making any deduction under this clause and Chapter VIA). (iii) Clause (c) is applicable to a public financial institution or a State financial

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

Bench: Shri Waseem Ahmed & Shri Soundararajan K

68,000/- Rs. 808,05,00,000/- Intangible asset- Trade name Rs. 125,95,00,000/- Intangible asset- customer Rs. 30,060,000/- Rs. 85,33,00,000/- contacts Goodwill Rs. 280,39,08,132/- Rs. 2016,21,78,480/- Total Rs. 412,05,36,132/- Rs. 3035,54,78,480/- 21. On the above identified intangible assets, the assessee

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

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

RAGHAVAN NAMBATH MENON,BENGALURU vs. ITO, WARD INTL. TAXATION 1(2), BMTC BUILDING, KORAMANGALA, BENGALURU

In the result, I pass the following:-

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

68 of the Act as per the direction passed by the ld. DRP. The AO completed the assessment proceedings on a total assessed income of Rs.12,04,080/- as against total income declared as per return amounting to Rs. 1,91,920/-. 4. Aggrieved by the assessment completed u/s. 147 r.w.s 144C(13) of the Act vide order dated 17/12/2024

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

68,82,138/-. The ld. AO has raised a demand of Rs.1086,07,00,024/- after charging interest u/s 234B of the Act as per the normal provisions of the Act. 3.2 Aggrieved by the order of the ld. AO, the assessee went in appeal before ld. CIT(A)/NFAC. The ld. CIT(A) partly allowed the appeal

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

32,129 11 556 1,377 440 1,152 414 47 ,068 1,15,088 2016-17 27 ,600 1,396 209 768 184 1,45,245 Chithradurga: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/s 194C u/s. 194C Total Interest Interest Interest TDS TDS TDS u/s u/s 201(1A) deductib

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

32,129 11 556 1,377 440 1,152 414 47 ,068 1,15,088 2016-17 27 ,600 1,396 209 768 184 1,45,245 Chithradurga: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/s 194C u/s. 194C Total Interest Interest Interest TDS TDS TDS u/s u/s 201(1A) deductib

M/S. LIFE INSURANCE CORPORATION OF INDIA,SHIVAMOGGA vs. THE INCOME TAX OFFICER, (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

32,129 11 556 1,377 440 1,152 414 47 ,068 1,15,088 2016-17 27 ,600 1,396 209 768 184 1,45,245 Chithradurga: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/s 194C u/s. 194C Total Interest Interest Interest TDS TDS TDS u/s u/s 201(1A) deductib

M/S LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

32,129 11 556 1,377 440 1,152 414 47 ,068 1,15,088 2016-17 27 ,600 1,396 209 768 184 1,45,245 Chithradurga: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/s 194C u/s. 194C Total Interest Interest Interest TDS TDS TDS u/s u/s 201(1A) deductib