KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER 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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HUBBALLI, HUBBALLI vs. SMT. SHEELA PRASANNAKUMAR , CHITRADURGA

In the result, the appeals of the Revenue are dismissed

15) of section 155 shall, as far may\nbe. Apply in relation to the stamp duty value of such property for\nthe purpose of this sub-clause as they apply for valuation of capital\nasset under those sections\".\n5.2 In this case, the AO had reproduced in the assessment order,\nthe detailed objections raised by the appellant during the assessment

NALAPAD PROPERTIES ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-2(3) , BANGALORE

15,745/- and given deduction towards cost of land at\nRs.1,45,44,590/- and computed the business income at\nRs.393,84,71,155/-. On appeal, 1d. CIT(A) observed that transfer\ntook place in the AY 2017-18 as decided by ld. AO. However, while\ndetermining the value of sale consideration, he directed the ld. AO\nto adopt

TUNGABHADRA PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA,SINDHANUR vs. INCOME TAX OFFICER, WARD -1, RAICHUR

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

15) For the purposes of this section,— (a) “Dispute Resolution Panel” means a collegium comprising of three Commissioners of Income tax constituted by the Board for this purpose; (b) “eligible assessee” means,— (i) any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

15 of 86\nIT(TP)A Nos. 303 & 839/Bang/2022\nthe time period to pass an assessment order u/s. 143(3) as per section 153(1) comes to a halt.\n6.12 Be that as it may, after the receipt of an order u/s. 92CA(3) by the Ld.AO, as per section 92CA(4), the assessing officer has to pass an order

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

Price (Rs.)\n0\n(Zero)\nFirst Party\nTHE KSCA AND RD BANK LTD\nSecond Party\nTHE INCOME TAX OFFICER WARD 5 2 1 BENGALURU\nStamp Duty Paid By\nTHE KSCA AND RD BANK LTD\nStamp Duty Amount (Rs.)\n20\n(Twenty only)\nBEFORE THE HONOURABLE INCOME TAX APPELLATE TRIBUNAL\nBANGALORE BENCH\nThe Karnataka State Co-\noperative Agriculture and Rural\nDevelopment

VAIDYA SRIKANTAPPA SADASHIVAIAH SRIKANTH,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE- 1, , BANGALORE

15 at p.335 of the Report this Court made a distinction between\nthe purposes of the two enactments and held that all the provisions of the\nsaid Act do not apply to the BDA Act. Subsequently, the Constitution Bench\nof this Court in Offshore Holdings (P) Ltd. v. Bangalore Development\nAuthority, held that Section 11-A of the said

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

2,547,399,038, expenses reimbursement payable of ₹ 4,638,999, consultancy services provided to its AE and remuneration received of ₹ 13,823,504,210 and IT services and support services provided by its associated enterprises of ₹ 5,814,382,000 117/–. With the respect to the total international transactions of ₹ 4096 crores, the assessee adopted transactional net margin method

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 1(3), BENGALURU, BANGALORE

In the result the appeal of the assessee is allowed

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)

2), Bengaluru ("Transfer Pricing Office / TPO") for determination of Arm's Length Price under section 92CA of the Act on 30.03.2022. Several notices were issued under section 142(1) of the Act to the Assessee, which have been duly responded to. 3.7 The TPO passed the order under section 92CA(3) on 29.01.2023, proposing an adjustment

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

Price (Rs.)\nFirst Party\nSecond Party\nStamp Duty Paid By\nStamp Duty Amount (Rs.)\nIN-KA62211732245533V\n06-Dec-2023 02:47 PM\nNONACC (FI)/ kacrsf108/ CHAMRAJPET/KA-BV\nSUBIN-KAKACRSFL0891976534819913V\nTHE KSCA AND RD BANK LTD\nArticle 4 Affidavit\nAffidavit\n0\n(Zero)\nTHE KSCA AND RD BANK LTD\nTHE INCOME TAX OFFICER WARD 521 BENGALURU\nTHE KSCA AND RD BANK

SRI JIHVESHWARA CREDIT CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD 2(2)(5), BANGALORE, BANGALORE

In the result, this issue in ITA No

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

prices constituted receipt on a commercial basis or net profit. A. Venkata Subbarao v. State of Andhra Pradesh AIR 1965 SC 1773 applied. CIT v. South Arcot District Co-operative Marketing Society Ltd. [1989] 176 ITR 117 (SC) distinguished. Surath Venkar Sahakari Sangh Ltd v. CIT [1971] 79 ITR 722 (Guj) approved. Decision of the Rajsthan High Court

SRI JIHVESHWARA CREDIT CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD 2(2)(5), BANGALORE, BANGALORE

In the result, this issue in ITA No

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

prices constituted receipt on a commercial basis or net profit. A. Venkata Subbarao v. State of Andhra Pradesh AIR 1965 SC 1773 applied. CIT v. South Arcot District Co-operative Marketing Society Ltd. [1989] 176 ITR 117 (SC) distinguished. Surath Venkar Sahakari Sangh Ltd v. CIT [1971] 79 ITR 722 (Guj) approved. Decision of the Rajsthan High Court

SRI JIHVESHWARA CREDIT CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD 2(2)(5), BANGALORE, BANGALORE

In the result, this issue in ITA No

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

prices constituted receipt on a commercial basis or net profit. A. Venkata Subbarao v. State of Andhra Pradesh AIR 1965 SC 1773 applied. CIT v. South Arcot District Co-operative Marketing Society Ltd. [1989] 176 ITR 117 (SC) distinguished. Surath Venkar Sahakari Sangh Ltd v. CIT [1971] 79 ITR 722 (Guj) approved. Decision of the Rajsthan High Court