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

section 14A as computed under Rule 8D(2)(iii) cannot be more than the actual expenditure which can be relatable for earning the exempt income and debited to the Profit and Loss account. In the case on hand the disallowance made by the assessee on its own is not the total expenditure debited to the profit and loss account

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BANGALORE vs. M/S TRISHUL DEVELOPERS, BANGALORE

In the result, appeals filed by the Revenue are dismissed

pricing addition of Rs.78.97\ncrores;\n(ii) Secondly, under the approved scheme of amalgamation, the transferee\nhas assumed the liabilities of the transferor company, including tax\nliabilities;\n(iii) Thirdly, the consequence of the scheme of amalgamation approved\nunder Section 394 of the Companies Act 1956 is that the amalgamating\ncompany ceased to exist. In Saraswati Industrial Syndicate Ltd., (supra

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S TRISHUL DEVELOPERS, BENGALURU

pricing addition of Rs.78.97\ncrores;\n(ii) Secondly, under the approved scheme of amalgamation, the transferee\nhas assumed the liabilities of the transferor company, including tax\nliabilities;\n(iii) Thirdly, the consequence of the scheme of amalgamation approved\nunder Section 394 of the Companies Act 1956 is that the amalgamating\ncompany ceased to exist. In Saraswati Industrial Syndicate Ltd., (supra

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

Transfer Pricing (TP). This TP adjustment was also subjected to the direction of the ld. DRP. 3. On review of the records, the ld. PCIT found that as per Form 3CD assessee has paid contribution of Rs. Rs.1,21,861 being employees’ contribution towards PF & ESI which were deposited beyond the due dates mentioned in the respective

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

transfer, then, for the purposes of the deduction under this section, the profits and gains of the industrial undertaking or the business of the hotel shall be computed as if the transfer, in either case, had been made at the market value of such goods as on that date : Provided that where, in the opinion of the Assessing Officer

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

transferred to a new business in that area or in any other backward area and the total value of the machinery or plant or part so transferred does not exceed twenty per cent of the total value of the machinery or Page 31 of 39 plant used in the business, then, for the purposes of clause (iii) of this

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX, (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for Assessment Years

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

transfer. Cash sales form only a small percentage of total sales (about 5% in ATC and 12% in STC), . ITA No.399-410/Bang/2025 Page 10 of 33 which means most cash purchases are matched against bank/cheque sales. 3.4 It is further argued that no defect has been pointed out in the stock records, and in fact, purchases are fully reconciled with sales

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for Assessment Years

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

transfer. Cash sales form only a small percentage of total sales (about 5% in ATC and 12% in STC), . ITA No.399-410/Bang/2025 Page 10 of 33 which means most cash purchases are matched against bank/cheque sales. 3.4 It is further argued that no defect has been pointed out in the stock records, and in fact, purchases are fully reconciled with sales

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\n\nwhich means most cash purchases are matched against bank/cheque\nsales.\n\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE 1(3), BENGALURU

In the result, all the appeals of the assessee for A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

BYSANI ADINARAYAGUPATHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nPage 10 of 33\nITA No.399-410/Bang/2025\nwhich means most cash purchases are matched against bank/cheque\nsales.\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

transfer. Cash sales form only a\nsmall percentage of total sales (about 5% in ATC and 12% in STC),\nwhich means most cash purchases are matched against bank/cheque\nsales.\n\n3.4 It is further argued that no defect has been pointed out in the\nstock records, and in fact, purchases are fully reconciled with sales. All\nthe purchases made

CISCO COMMERCE INDIA PRIVATE LIMITED,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PCIT, BENGALURU-2, BANGALORE

In the result, the appeal by the assessee is dismissed

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

391,462 on the ground that that the breakup of rebate and incentive issued to the direct customers amounting to ₹ 54.22 crores and incentive to distribution and channel rebates amounting to ₹ 115.40 crores has certain negative rebates and Page 10 of 24 therefore such negative rebates could not have been allowed for the purpose of reconciliation. Accordingly same was added

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

391], (Forward Construction\nCo.) the Apex court found fault with the High Court in holding that the\nearlier judgment would not operate as res judicata as one of the grounds\ntaken in the subsequent petition was conspicuous by its absence in the earlier\npetition. Explanation IV to Section 11 CPC was relied upon to observe that\nany matter which might