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. The next issue raised by the assessee through Ground No. 4 of the appeal pertains to disallowances of weighted deduction under section 35

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

68,000/- Rs. 808,05,00,000/-\nIntangible asset- Trade name\nRs. 125,95,00,000/-\nIntangible asset- customer Rs. 30,060,000/- Rs. 85,33,00,000/-\ncontacts\nGoodwill\nRs. 280,39,08,132/- Rs. 2016,21,78,480/-\nTotal\nRs. 412,05,36,132/- Rs. 3035,54,78,480/-\n21.\nOn the above identified intangible assets, the assessee

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

68,000/- Rs. 808,05,00,000/-\nIntangible asset- Trade name\nRs. 125,95,00,000/-\nIntangible asset- customer Rs. 30,060,000/-\nRs. 85,33,00,000/-\ncontacts\nGoodwill\nRs. 280,39,08,132/- Rs. 2016,21,78,480/-\nTotal\nRs. 412,05,36,132/- Rs. 3035,54,78,480/-\n21. On the above identified intangible assets, the assessee

MR. MOHAMMED HANIF MOHAMMED YUSUF DHARWADKAR,HUBLI vs. INCOME-TAX OFFICER, WARD-1(1), HUBLI

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2017-18

68 of the Act, would not vitiate the assessment order. In the present Mohammed Hanif Mahommed Yusuf Dharwadkar, Hubli Page 14 of 18 case, it is clear that AO has the power to question the deposit into bank account. While doing so, if the provision of law has been wrongly mentioned, it would be wholly immaterial, it would not make

AUGUST JEWELLERY PRIVATE LIMITED,BENGALURU vs. D.C.I.T., CIRCLE 1(1)(1), BENGALURU, BENGALURU

Section 68 means only the relevant previous\nyear. This ruling directly supports the assessee.\n(g) Similar view was taken by the Gujarat High Court in the\ncase of The Hon'ble Gujarat High Court in the case of CIT vs.\nJagatkumár Satishkumar Patel (2014) 45 taxman.com 441\n(Gujarat); The Gujarat High Court in the case

AUGUST JEWELLERY PVT LTD,BENGALURU vs. D.C.I.T., CIRCLE 1(1)(1), BENGALURU, BENGALURU

Section 68 means only the relevant previous\nyear. This ruling directly supports the assessee.\n(g) Similar view was taken by the Gujarat High Court in the\ncase of The Hon'ble Gujarat High Court in the case of CIT vs.\nJagatkumárSatishkumar Patel (2014) 45 taxman.com 441\n(Gujarat); The Gujarat High Court in the case

AUGUST JEWELLERY PVT LTD,BENGALURU vs. D.C.I.T., CIRCLE 1(1)(1), BANGALORE, BANGALORE

Section 68 means only the relevant previous\nyear. This ruling directly supports the assessee.\n(g) Similar view was taken by the Gujarat High Court in the\ncase of The Hon'ble Gujarat High Court in the case of CIT vs.\nJagatkumárSatishkumar Patel (2014) 45 taxman.com 441\n(Gujarat); The Gujarat High Court in the case

DCIT, BANGALORE vs. M/S BOSCH LIMITED, BANGALORE

In the result, the assessee's appeals are partly allowed and revenue’s appeal for the A

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

68,078/- on the ground that as per the definition of ‘regular workmen’ in Explanation(ii) to Sec.80JJAA, ‘regular workmen’ did not include ‘any other workmen employed for a period of less than three hundred days during the previous year’. The appellant plea that this definition applied to only casual labourers and not permanent employees was rejected on the round

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1(4), BENGALURU vs. M/S SNOWSHINE REALTORS PVT.LTD. , BENGALURU

In the result, the revenue appeals in ITA Nos

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

section 68 of the Act by A.O. 5.1 He submitted that incidentally in one of the group companies M/s.Jaico Realtors (P) Ltd there was an investment of 'Rs.4,06,98,779/- ($ 9,99,970) for the A.Y.2008-09 and similar issue was considered by Tribunal in ITA No.1444/Bang/2018 dated 8.5.2019 and deleted addition made by AO u/s 68

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1(4), BENGALURU vs. M/S KANSUR DEVELOPERS INDIA PVT. LTD. , BENGALURU

In the result, the revenue appeals in ITA Nos

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

section 68 of the Act by A.O. 5.1 He submitted that incidentally in one of the group companies M/s.Jaico Realtors (P) Ltd there was an investment of 'Rs.4,06,98,779/- ($ 9,99,970) for the A.Y.2008-09 and similar issue was considered by Tribunal in ITA No.1444/Bang/2018 dated 8.5.2019 and deleted addition made by AO u/s 68

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1-(4), BENGALURU vs. M/S KANSUR DEVELOPERS INDIA PVT. LTD., BENGALURU

In the result, the revenue appeals in ITA Nos

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

section 68 of the Act by A.O. 5.1 He submitted that incidentally in one of the group companies M/s.Jaico Realtors (P) Ltd there was an investment of 'Rs.4,06,98,779/- ($ 9,99,970) for the A.Y.2008-09 and similar issue was considered by Tribunal in ITA No.1444/Bang/2018 dated 8.5.2019 and deleted addition made by AO u/s 68

ARJUN SHETTY,MANGALURU vs. INCOME TAX OFFICER, TPS, CIRCLE - 1(1), MANGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri.Laxmi Prasad Sahu & Shri.Keshav Dubeyassessment Year : 2018-19 Arjun Shetty, Vs. Ito, 16-6-393/9 Shubha Krishna Building, Ward – Tps, Highland Falnir, Mangalore - 575002. Circle – 1(1), Pan :Ainps5294H Mangalore. Appellant Respondent Assessee By : S/Shri. Pranav G Ambekar, V. Narendra Sharma, Advocates Revenue By : Shri. Nilanjan Dey,Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 15.09.2025 Date Of Pronouncement : 29.10.2025

section 68 was invoked merely because of double mention of the same amount under two heads, without there being any unexplained actual flow funds. 18. The CIT(A) and AO failed to appreciate that by inadvertently including the agricultural income of Rs. 81,07,690/- from the partnership firm i.e. M/s. Classic Plantations for rate purposes, the appellant

VISHWANATHAREDDY CHENNAREDDY,BANGALORE vs. INCOME-TAX OFFICER, WARD-2(2)(7), BENGALURU

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

Bench: SHRI CHANDRA POOJARI (Accountant Member), SMT. BEENA PILLAI (Judicial Member)

68 of the Act at Rs.61.98 lakhs. 3.1 During the first appeal proceedings, the learned CIT (Appeals) accepted the contention of the Assessee that the deposit of Rs. 30,00,000/- offered for taxation under the PMGKY scheme, taxes were duly paid and additions to the extent were deleted. Further relating to the remaining additions

BHARAT ELECTRONICS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, LARGE PAYERS TAX UNIT, CIRCLE-1, BANGALORE

In the result, appeal of the assessee is partly allowed

Section_35{2AB) of the Act. Given this, it had\nclaimed a weighted deduction of Rs. 13,57,89,55,292/- as under:\nNature of expense\nAmount of expense\nDeduction\nClaimed\nRevenue Expenditure\nRs. 8,02,29,91,000/-\nRs. 12,03,44,86,500/-\nCapital Expenditure\nRs. 1,02,96,45,861/-\nRs. 1,54,44,68

M/S. BIOCON LIMITED,BENGALURU vs. COMMISSIONER OF INCOME TAX, LTU,, BENGALURU

In the result, the appeal filed by the assessee is allowed on the legal issue raised in ground no

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2010-11 The Joint M/S. Biocon Ltd., Commissioner Of 20Th Km, Hosur Road, Income-Tax, Electronic City, Large Tax Payers Bangalore – 560 100. Unit [Ltu], Pan: Aaacb7461R Vs. Bangalore. Appellant Respondent : Shri Padam Chand Khincha, Assessee By Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 20-04-2022 Date Of Pronouncement : 09-06-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 28.03.2018 Passed By Ld.Cit(A)-3, Bangalore For A.Y. 2010-11 On Following Grounds Of Appeal: “The Grounds Mentioned Herein Below Are Independent & Without Prejudice To The Other Grounds Preferred By The Appellant. 1. That On Facts & Circumstances Of The ' Case & In Law, The Order Passed By The Learned Commissioner Of Income-Tax Appeals ["Cit(A)"] Dated March 28, 2018 Under Section 250 Of The Income-Tax Act, 1961 ("The Act") For Ay 2010-11 To The Extent Prejudicial To The Appellant, Is Bad In Law & Facts & Liable To Be Quashed. 2. Scope Of Re-Assessment Proceedings

35(2AB) of the Act was claimed by the Appellant in relation to units eligible for deduction under section 10AA/10B of the Act. The assessee craves leave to add, alter, vary, omit, substitute or amend the above grounds, at any time before or at the time of hearing. Each of the above grounds is independent and without prejudice

MR. P. NARASIMHA RAO,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-1(1) & TPS, MANGALURU

In the result, the assessee’s appeal is partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2012 – 13

section 149 of the Act, the AO is competent to issue notice u/s 148 of the Act for the assessment year 2012-13 on or before 31.3.2019 and in the case of notice u/s 148 of the Act has been issued on 30.3.2019 and it has been issued in time. In view of our above findings, additional ground Nos.1

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

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

section\n132(4) of the Act. We have also gone through the statement recorded under\nsection 131 of the Act. During the course of survey, question and answer No.40\nis as under:\n40.It is seen from the table submitted by you in the above answer, that the cash\ndeposited in to different accoun is totalling to Rs.68

M/S. KHODAY INDIA LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD- 4(1)(2), BANGALORE

In the result appeal filed by assessee stands allowed

Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahuassessment Year : 2015-16 M/S. Khoday India Ltd., The Income-Tax 7Th Mile, Brewery House, Officer, Kanakapura Road, Ward 4 (1)(2), Bangalore – 560 062. Bangalore. Pan: Aaack6734C Vs. Appellant Respondent Assessee By : Shri V. Sridhar, Ca : Shri Ramesh B.R., Addl. Cit Revenue By (Dr) Date Of Hearing : 09-06-2022 Date Of Pronouncement : 30-06-2022 Order Per Beena Pillaipresent Appeal Is Filed By The Assessee Against Order Dated 09/12/2021 Passed By The Ld.Cit(A)-11, Bangalore For Assessment Year 2015-16 On Following Grounds Of Appeal: “1. The Order Of The Learned Commissioner Of Income-Tax (Appeals), Bengaluru-11, Bengaluru In Ita No.Cit(A)- 11/Bng/Tr.10036/2018-19 (Din: Itba /Apl /M/ 250 /2021-22/ 1037634908(1) Dated:09.12.2021 Is Opposed To Law, Weight Of Evidence, Probabilities & Facts & Circumstances Of The Case. 2. The Learned Commissioner Of Income-Tax (Appeals) Erred In Confirming The Order Of The Assessing Officer Passed U/S.154 Of The Income Tax Act, 1961 Dated:14.02.2018. 3. The Learned Commissioner Of Income-Tax (Appeals) Erred In Not Directing The Assessing Officer To Set Off The Entire

section 68 of the Act, as the assessee failed to grow satisfactorily the genuineness of the credit and the creditworthiness of L.K.Trust to advance the amount. 2.9 The Ld.AO thus assessed the loss of ₹ 24,64,35