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

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

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

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

35 of 64 Income-tax Officer in starting proceedings under section 34 of the Act is open to challenge in a court of law (see Calcutta Discount Co. Ltd. v. Income-tax Officer, Companies District 1, Calcutta)." 50. In Ganga Saran & Sons (P.) Ltd. v. Income-tax Officer [1981] 130 ITR 1 (SC), the Hon’ble Supreme Court observed

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

35 of 64 Income-tax Officer in starting proceedings under section 34 of the Act is open to challenge in a court of law (see Calcutta Discount Co. Ltd. v. Income-tax Officer, Companies District 1, Calcutta)." 50. In Ganga Saran & Sons (P.) Ltd. v. Income-tax Officer [1981] 130 ITR 1 (SC), the Hon’ble Supreme Court observed

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 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

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

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

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

35,72,468 on goodwill and certain other intangibles. The working of depreciation on goodwill was also filed before the assessing officer vide the said reply dated 15.10.2012 (refer pages 604-606 of PB– Vol 1 / pages 2818-2820 of PB-Vol 4). The assessing officer in the impugned order, did not, however, deal with the claim of depreciation

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1)(1), BENGALURU, BENGALURU vs. NUTRICRAFT INDIA PRIVATE LIMITED, BENGALURU

In the result appeal filed by the learned assessing officer is partly allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

35,647 1,78,59,812 14,15,12,648 7,09,47,118 Therefore Section 36(1)(ii) will be attracted. Section 36(1)(ii) reads as under: “any sum paid to an employee as bonus or commission21 for services rendered, where such sum would not have been payable to him as profits or dividend

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

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

35,973 25,848 2,329 1,656 65,806 2013-14 41,526 24,900 2,104 1,386 69,916 2014-15 46,243 22,176 2,339 1,380 9,418 4,512 86,06 8 2015-16 45,009 16,200 2,250 1,035 64,494 2016-17 1

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

35,973 25,848 2,329 1,656 65,806 2013-14 41,526 24,900 2,104 1,386 69,916 2014-15 46,243 22,176 2,339 1,380 9,418 4,512 86,06 8 2015-16 45,009 16,200 2,250 1,035 64,494 2016-17 1

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI 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

35,973 25,848 2,329 1,656 65,806 2013-14 41,526 24,900 2,104 1,386 69,916 2014-15 46,243 22,176 2,339 1,380 9,418 4,512 86,06 8 2015-16 45,009 16,200 2,250 1,035 64,494 2016-17 1

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

35,973 25,848 2,329 1,656 65,806 2013-14 41,526 24,900 2,104 1,386 69,916 2014-15 46,243 22,176 2,339 1,380 9,418 4,512 86,06 8 2015-16 45,009 16,200 2,250 1,035 64,494 2016-17 1