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

13\n2\n103,01,34,0\n33\n309,04,02,09\n9\n2016\n309,04,02,09\n3035,54,78,4\n3344,58,80,5\n836,14,70,1\n2508,44,10,4\n-17\n9\n80\n79\n45\n34\n2017\n2508,44,10,4\n2508,44,10,4\n627,11,02,6\n1881

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

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

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

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

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

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the assessment order dated 20/06/2024 in DIN No. ITBA/AST/S/143(3)/2024-25/ 1065988655(1) for the assessment year 2020-21. 2. The issues raised by the assessee in Ground Nos. 1 to 3 of the appeal are general in nature and therefore, the same

NABHIRAJ RATNA BALRAJ BY LEGAL HEIR B.R.RAKESH,BANGALORE vs. INCOME-TAX OFFICER, WARD-7(2)(1), BANGALORE

In the result the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

13 of 33 (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section (2) exceeds the value adopted or assessed or assessable by the stamp valuation authority referred to in sub-section (1), the value so adopted or assessed or assessable by such authority shall be taken as the full value

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

13 103,01,34,0 309,04,02,09\n-16\n2\n2\n33\n9\n2016\n309,04,02,09 3035,54,78,4 3344,58,80,5 836,14,70,1 2508,44,10,4\n-17\n9\n80\n79\n45\n34\n2017\n2508,44,10,4\n2508

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

transferred by the Government under section 32 of the\nKIAD Act, that the role of the Board begins.\nRestraint on expenditure from funds of the assessee\n26. Section 23 stipulates that the assessee shall have the\nauthority to spend such sums as it thinks fit for the\npurposes authorised under this Act from out of Board's\nfunds. Every expense

SAP INDIA PRIVATE LIMITED,BANGALORE vs. JURISDICTIONAL ASSESSING OFFICER - DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1), BANGALORE

The appeal of the assessee is allowed to the extent indicated above

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

D E R PER PRASHANT MAHARISHI, Vice President: 01. This appeal is filed by SAP India private limited in ITA No. 1519 of Bangalore/2024 for assessment year 2020 – 21 against the assessment order passed under section 143 (3) read with section 144C (13) read with section 144B of the income tax act, 1961 (the Act) passed by the assessment unit

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

Accordingly, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

13. The principle of statutory construction invoked by Ms Ramachandran has no application in construing the expression "gross total income" in subsection (1) of Section 80-P. In view of the express provision defining the said expression in Section 80-B(5) for the purpose of Chapter VI-A, there is no scope for construing the said expression differently

M/S. TATA ELXSI LIMITED., ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri George George K. & Shri Chandra Poojari

13. The principle of statutory construction invoked by Ms Ramachandran has no application in construing the expression "gross total income" in subsection (1) of Section 80-P. In view of the express provision defining the said expression in Section 80-B(5) for the purpose of Chapter VI-A, there is no scope for construing the said expression differently

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

1) Bangalore PAN NO : AAACU6053C APPELLANT RESPONDENT Appellant by : Shri Ankur Pai, A.R. a/w Shri K.R. Vasudevan, A.R. Respondent by : Shri Saravanan B., DR Date of Hearing : 28.08.2023 Date of Pronouncement : 29.08.2023 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: IT(TP)A No.345/Bang/2021 for the assessment year 2016-17 by the assessee is directed against final assessment

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

1) Bangalore PAN NO : AAACU6053C APPELLANT RESPONDENT Appellant by : Shri Ankur Pai, A.R. a/w Shri K.R. Vasudevan, A.R. Respondent by : Shri Saravanan B., DR Date of Hearing : 28.08.2023 Date of Pronouncement : 29.08.2023 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: IT(TP)A No.345/Bang/2021 for the assessment year 2016-17 by the assessee is directed against final assessment

CONCUR TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(2)(1), BANGALORE

Appeal of the assessee is partly allowed as indicated above

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2021-22

D E R Per Prashant Maharishi, Vice President 1. ITA No. 2550/Bang/2024 is filed by Concur Technologies (India) Private Limited for assessment year 2021 – 22 against the assessment order passed by the Assessment Unit on 25 October 2024 under section 144 read with section 144C (13) read with section 144B of the Income Tax Act, 1961 (the Act) pursuant

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

1)(iv) as Scientific research expenses shall become academic and we are not adjudicating them”. Accordingly we partly allow the ground No. 4 to 4.4 raised by the assessee. 7. The fifth ground relates to the transfer pricing adjustment made by TPO/AO. In the original grounds of appeal that were filed before the Tribunal on 27.07.2021, the five aspects

ARIBA TECHNOLOGIES INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the assessment order dated 26/06/2024 in ITA No. ITBA/AST/S/143(3)/2024-25/ 1066102806(1) for the assessment year 2020-21. 2. The issue raised by the assessee through ground No. 1 of its appeal is general in nature and does not require any separate

M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

price, justifies the same. The Hon'ble Supreme Court in Vodafone International Holdings B.V. vs. Union of India (2012) 341 ITR 1 (SC) analysed the interplay between transfer of shares and the resultant host of consequences which inter alia included the concept of controlling interest. The relevant portion from the judgement, as authored by Hon'ble justice K.S. Radhakrishnan

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

price, justifies the same. The Hon'ble Supreme Court in Vodafone International Holdings B.V. vs. Union of India (2012) 341 ITR 1 (SC) analysed the interplay between transfer of shares and the resultant host of consequences which inter alia included the concept of controlling interest. The relevant portion from the judgement, as authored by Hon'ble justice K.S. Radhakrishnan