BSNL EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LIMITED ,HUBBALLI vs. PR. CIT, HUBBALLI , HUBBALLI

In the result the appeal filed by the assessee is allowed

revision\nproceedings u/s. 263 of the Act, the reasons cited by the ld. PCIT primarily is that\nthe assessee had received certain interest income on investment in banks which are\nrequired to be added to the income of the assessee u/s. 56 of the Act as held by the\nHon'ble Supreme Court in the case of Totagars Cooperative sale

ADARSHA SOUHARDA SAHAKARI NIYAMIT SIRSI,SIRSI vs. PR. COMMISSIONER OF INCOME TAX, , HUBALLI

In the result the appeal filed by the assessee is allowed

revision proceedings u/s. 263 of the Act, the reasons\ncited by the ld. PCIT primarily is that the assessee had received\ncertain interest income on investment in banks which are required\nto be added to the income of the assessee u/s. 56 of the Act as\nheld by the Hon'ble Supreme Court in the case of Totagars Co-\noperative

SRI RAMASEVA BAHUSARA KSHARIYA CO-OP. SOCIETY LIMITED,SHIMOGA vs. PR. CIT, BENGALURU-1, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21 M/S. Sri Ramaseva Bahusara Kshariya Co-Op. Society Ltd. 01, Ramanna Setty Park Spm Road, Doddapete So Vs. Principal Cit Shimoga 577 202 Bengaluru-1 Karnataka Pan No :Aaajs0083P Appellant Respondent Appellant By : Sri V. Srinivasan, A.R. Respondent By : Sri Kiran D., D.R. Date Of Hearing : 11.12.2025 Date Of Pronouncement : 30.01.2026

u/s 80P(2)(a)(i) of the Act is not allowed. 7.5 Now before proceedings further, it is apposite here to mention the relevant provision of Income Tax Act which is reproduced below:- Revision of orders prejudicial to revenue. 263. (1) The [ [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or] Commissioner may call for and examine the record

BHARATH CREDIT CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. PR. CIT, BANGALORE -1, BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2020-21

u/s. 56 of the Act in view of the Apex court decision cited supra. 7.5 Now before proceedings further, it is apposite here to mention the relevant provision of Income Tax Act which is reproduced below:- Revision of orders prejudicial to revenue. 263. (1) The [ [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or] Commissioner may call

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

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 15 of 31 [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised

BHAVANA CO-OP CREDIT SOCIETY NIYAMITA ,SIRSI vs. INCOME TAX OFFICER, WARD-1, SIRSI

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 15 of 31 [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised

AMAZON DEVELOPMENT CENTRE (INDIA) PRIVATE LIMITED,BENGALURU vs. COMMISSIONER OF INCOME TAX (TP), BENGALURU-1, BENGALURU

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Transfer Pricing order was passed after getting approval from learned CIT-TP but the learned CIT-TP proposed to revise the same order which was passed after his approval, thus such an action tantamount to review of own approval which is not desirable under the provision of section 263 of the Act and same is against the use of power

AMAZON SELLER SERVICES PRIVATE LIMITED,BENGALURU vs. COMMISSIONER OF INCOME TAX (TP), BENGALURU-1, BENGALURU

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Transfer Pricing order was passed after getting approval from learned CIT-TP but the learned CIT-TP proposed to revise the same order which was passed after his approval, thus such an action tantamount to review of own approval which is not desirable under the provision of section 263 of the Act and same is against the use of power

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transferred to assessee. The assessee has only right to use these for rendering ITES services. Applying ratio of the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra), this cannot result in royalty. We proceed to examine whether the definition of 'Royalty' as per Article 12 of India-Ireland DT AA is satisfied

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transferred to assessee. The assessee has only right to use these for rendering ITES services. Applying ratio of the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra), this cannot result in royalty. We proceed to examine whether the definition of 'Royalty' as per Article 12 of India-Ireland DT AA is satisfied

M/S GOOGLE INDIA PRIVATE LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 , BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transferred to assessee. The assessee has only right to use these for rendering ITES services. Applying ratio of the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra), this cannot result in royalty. We proceed to examine whether the definition of 'Royalty' as per Article 12 of India-Ireland DT AA is satisfied

MS GOOGLE INDIA PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BENGALURU

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transferred to assessee. The assessee has only right to use these for rendering ITES services. Applying ratio of the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra), this cannot result in royalty. We proceed to examine whether the definition of 'Royalty' as per Article 12 of India-Ireland DT AA is satisfied

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

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transferred to assessee. The assessee has only right to use these for rendering ITES services. Applying ratio of the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra), this cannot result in royalty. We proceed to examine whether the definition of 'Royalty' as per Article 12 of India-Ireland DT AA is satisfied

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

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transferred to assessee. The assessee has only right to use these for rendering ITES services. Applying ratio of the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra), this cannot result in royalty. We proceed to examine whether the definition of 'Royalty' as per Article 12 of India-Ireland DT AA is satisfied

GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transferred to assessee. The assessee has only right to use these for rendering ITES services. Applying ratio of the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra), this cannot result in royalty. We proceed to examine whether the definition of 'Royalty' as per Article 12 of India-Ireland DT AA is satisfied

GOOGLE INDIA PVT. LTD. vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transferred to assessee. The assessee has only right to use these for rendering ITES services. Applying ratio of the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra), this cannot result in royalty. We proceed to examine whether the definition of 'Royalty' as per Article 12 of India-Ireland DT AA is satisfied

SHRI. POLLAMREDDY SREEDHAR REDDY,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-1, BENGALURU

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2018-19

u/s 263 of the Act has relied upon Clause (a) of Explanation 2 to section 263(1) for invoking her revisionary powers. The relevant extract of section 263 is produced hereunder: "Revision of orders prejudicial to revenue 263(1)……….. Explanation 2.—For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer

COMER INDUSTRIES INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 2(2)(1), BANGALORE, BANGALORE

In the result, the appeal by the assessee is dismissed

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

263 of the Income Tax Act, 1961 [the Act] dated 25.03.2025 wherein it is held that the assessment order passed u/s. Page 2 of 10 143(3) r.w.s. 144C r.w.s. 144B of the Income-tax Act, 1961 [the Act] dated 20.7.2022 is erroneous and prejudicial to the interests of the revenue to the extent of the fact that there

SHREE HANUMAN CREDIT SOUHARD SAHAKARI LIMITED,CHIKODI vs. PR. COMMISSIONER OF INCOME-TAX, HUBLI

In the result, the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2017-18

Revision of orders prejudicial to revenue. 263. (1) The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 89[or the Transfer Pricing Officer, as the case may be,] is erroneous