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

250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together. 2. First, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017- 18 as the lead case. The assessee, in the memo of appeal, has raised four grounds bearing numbers

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

250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together. 2. First, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017- 18 as the lead case. The assessee, in the memo of appeal, has raised four grounds bearing numbers

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

250 (Mumbai - Trib.) Dated 14.09.2021 wherein it was held that Amendment made in section 50C(1) by inserting third proviso by Finance Act, 2018, with effect from 1-4-2019 is curative in nature and same would apply retrospectively. xiii. Reliance is also placed on the decision rendered by jurisdictional Bangalore ITAT and other tribunals where in it was held

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

250 of\nthe Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to\n2021-22, which were heard together.\n2.\nFirst, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017-\n18 as the lead case. The assessee, in the memo of appeal, has raised\nfour grounds bearing numbers

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.

Section 92CA of the Act dated 31.10.2017 stated that acquisition of shares pursuant to the SPA, Diageo Pic (the ultimate holding company of Rely BV) acquired controlling stake in USL and, hence, the determination of ALP must be determined based on a valuation of USL as an entity. Therefore, the TPO held that the price of USL shares

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.

Section 92CA of the Act dated 31.10.2017 stated that acquisition of shares pursuant to the SPA, Diageo Pic (the ultimate holding company of Rely BV) acquired controlling stake in USL and, hence, the determination of ALP must be determined based on a valuation of USL as an entity. Therefore, the TPO held that the price of USL shares

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

250 of the Act by the learned CIT(A), NFAC to the extent prejudicial to the appellant be quashed or in the alternative the addition of Rs.1,09,55,534/- made under section 10AA and consequential levy of tax including interest thereon be deleted. The Appellant submits that each of the above grounds / sub-grounds are independent and without prejudice

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

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

250 of the Income Tax Act, 1961 (in short “the Act”) for the Assessment Year (AY) 2017-18. The assessee has not filed any cross objections (CO) against this appeal filed by the Revenue. 2. The Revenue has raised the following grounds of appeal: - Dcit(E), Circle-1, Bengaluru Page 2 of 24 Dcit(E), Circle-1, Bengaluru Page

IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

Transfer Pricing Officer,\nwhere the assessee had maintained information and documents as prescribed\nunder section 92D, declared the international transaction under Chapter X, and,\ndisclosed all the material facts relating to the transaction; and\n(e)the amount of undisclosed income referred to in section 271AAB.\n(7)The penalty referred to in sub-section (1) shall

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

M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojariassessment Year: 2018-19

250): ‘’We are inclined to accept the argument raised by counsel for the Revenue, because the advances to the partners, their relatives and the sister concerns are not for business purposes and the assessee has not derived any benefit out of the same. Admittedly, no interest was charged on these advances. The Tribunal appears to have placed reliance

M/S. TOYOTA TAUSHO INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(1)(1), BENGALURU

Accordingly, this ground is allowed for statistical purposes

Bench: Shri N.V Vasudevan & Shri Laxmi Prasad Sahu

transfer pricing adjustment should be restricted only to the AE related transactions of the assessee.” 11.3 Respectfully following the above judgment of coordinate bench of the Tribunal, we allow this ground of the assessee. Ground No.8 12. The ld.AR of the assessee submitted that Rohan Motors Ltd., and Sicagen India Ltd., were considered by the TPO as comparable companies after

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 CIRCLE- 1(1)(1), BANGALORE, BMTC BUILDING, KORAMANGALA, BAQNGALORE vs. BANGALORE ELECTRICITY SUPPLY COMPANY LIMITED , BESCOM CORPORATE OFFICE

In the result, the appeal by the assessee is partly allowed and appeal of the ld

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

prices but same is not paid to customers. However, these are bogus expenses, as assessee is bound by KERC rates. It was noted by him that this is one of the issues on the side of the liability. And there may be many such issues. As assessee failed to provide all the details, the learned that AO presumed that some

M/S. BANGALORE ELECTRICITY SUPPLY COMPANY LTD.,,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2), BANGALORE

In the result, the appeal by the assessee is partly allowed and appeal of the ld

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

prices but same is not paid to customers. However, these are bogus expenses, as assessee is bound by KERC rates. It was noted by him that this is one of the issues on the side of the liability. And there may be many such issues. As assessee failed to provide all the details, the learned that AO presumed that some

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

250 of the Income Tax Act, 1961 (hereinafter referred to as “Act”) dated 31.10.2023 for Assessment Year 2018- 19 in so far as it is against the appellant is opposed to law, weight ITA Nos.21 to 26/Bang/2024 Page 18 of 47 of evidence, natural justice, probabilities, facts and circumstances of the Appellant’s case. 2. The Appellant denies itself liable