INCOME TAX OFFICER,WARD-1, HOSPET vs. GAYATRI PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA, HOSPET, HOSPET

In the result appeal filed by the Revenue is partly allowed for statistical purposes

68,976/- is not warranted and therefore the same was deleted.\niii) Further, as far as payments made on Audit fee of Rs.50,000/-\nand commission payment of Rs.5,12,299/-, the ld. CIT(A)/NFAC is of the view that the assessee has not complied with the provisions\n\nof the section 194J & 194H of the Act respectively

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity."\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD- 5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity."\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

80J.\nIn our view, since the expression of wider import, namely,\n\"attributable to\", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word \"attributable to\" is certainly wider in\nimport than the expression \"derived from\". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. THE INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME-TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity."\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK ,BENGALURU vs. INCOME-TAX OFFICE, WARD-5(2)(1), BENGALURU

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

80J.\nIn our view, since the expression of wider import, namely,\n"attributable to", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

80J.\nIn our view, since the expression of wider import, namely,\n\"attributable to\", has been used, the legislature intended to\ncover receipts from sources other than the actual conduct\nof the business of generation and distribution of\nelectricity.\"\n(emphasis supplied)\n\n17.3 Therefore, the word "attributable to" is certainly wider in\nimport than the expression "derived from". Whenever

INCOME TAX OFFICER, WARD 1, UDUPI, UUPI vs. KAMBADAKONE RYTARA SEVA SAHAKARI SANGHA LTD, UDUPI

68,58,216/- (-) 11,22,48,924/-) was disallowed.\n10.4.1 The ld. CIT(A)/NFAC on the other hand is of the opinion\nthat the assessee is within its legitimate right to credit interest on\ncash basis as per section 43D of the Act. However, in case of\npayable interest, there is no compulsion in the Income

INCOME TAX OFFICER, WARD-1, UDUPI vs. KAMBADAKONE RYTARA SEVA SAHAKARI SANGHA LTD, UPPUNDA

68,58,216/- (-) 11,22,48,924/-) was disallowed.\n10.4.1\nThe ld. CIT(A)/NFAC on the other hand is of the opinion\nthat the assessee is within its legitimate right to credit interest on\ncash basis as per section 43D of the Act. However, in case of\npayable interest, there is no compulsion in the Income

PRIMARY AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU -3, BENGALURU

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2020-21

68 and 70 of the paper book wherein the assessee submitted that all the facts stated in the show cause notice are not relevant to the assessee Page 6 of 15 and somebody else facts are noted in the show cause notice by the learned PCIT and therefore the notice u/s. 263 of the Act be withdrawn. 8. The learned

INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU, BENGALURU vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED, BENGALURU

In the result both the appeals of the Revenue as well as\nCos of the Assessee for the Asst

68,500\nTumkur Grain Merchant co-op\nBank Ltd\n32,72,084\n2,87,500\nBharat Co-op Bank (Mumbai)ltd\n9,23,847\n2,15,220\nSubramanyeshwara co-op Bank\nLtd\n2,50,000\nBharat Co-op Bank Ltd\n7,12,500\nGrain Merchant Co-op Bank Ltd\n5,62,500\n1,03,463\nKarnataka State Co-operative Apex

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE vs. M/S COFFEEDAY GLOBAL LIMITED , BANGALORE

In the result, the appeals of the Revenue are partly allowed

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

80J of the Act, was not appropriate. According to the CIT(A), the position of law has changed and the allowance, in the instant case, is under a different provisions of the Act. Before the CIT(A), it was further submitted that, even for the A.Ys.2011-12 & 2012-13, there was a connected claim of additional depreciation under

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE vs. M/S COFFEEDAY GLOBAL LIMITED , BANGALORE

In the result, the appeals of the Revenue are partly allowed

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

80J of the Act, was not appropriate. According to the CIT(A), the position of law has changed and the allowance, in the instant case, is under a different provisions of the Act. Before the CIT(A), it was further submitted that, even for the A.Ys.2011-12 & 2012-13, there was a connected claim of additional depreciation under

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

DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S INDO AMERICAN HYBRID SEEDS INDIA P LTD, BANGALORE

In the result, both the appeals of the revenue are allowed for statistical

Bench: Shri A. K. Garodia & Smt Asha Vijayaraghavan

68,641/- Thereafter, he submitted that the issue of cultivation on own land and leased land was not before Hon’ble High Court in these two cases and therefore, these judgments are not relevant in respect of these two incomes and in a subsequent judgment of Hon’ble Karnataka High Court rendered in the case of M/s Namdhari Seeds, similar