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

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

HUBLI ELECTRICITY SUPPLY ,HUBBALLI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), HUBALLI

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

43B of the Act. Same view has been taken by Cochin Bench of Tribunal in the case of ACIT Vs. Kunnel Engineers & Contractors Pvt. Ltd. in ITA No.653/Coch/2019 & 4/Coch/2020 dated 19.5.2020 and by the coordinate bench of Bangalore in the case of Mr. Asrah Nafisa Althaf in ITA No.614/Bang/2023 dated 9.11.2023. In view of this, we dismiss these grounds taken

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. 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

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

ACIT, CIRCLE-1(1)(1), BENGALURU vs. ACUITY KNOWLEDGE CENTRE(INDIA) PVT LTD, BENGALURU

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year: 2014-15

section 43B of the Act as the same has been actually paid on or before the due date of filing the return of income. 4. That on the facts and in circumstances of the case and in law, the CIT(A) has erred in directing the Learned AO to compute the consequential interest on the assessed income as against

ACUITY KNOWLEDGE CENTRE (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSION OF INCOME TAX, CIRCLE1(1)(1), BENGALURU , BENGALURU

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year: 2014-15

section 43B of the Act as the same has been actually paid on or before the due date of filing the return of income. 4. That on the facts and in circumstances of the case and in law, the CIT(A) has erred in directing the Learned AO to compute the consequential interest on the assessed income as against

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

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

M/S. INGERSOLL - RAND TECHNOLOGIES AND SERVICES PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2499/Bang/2019 Assessment Year : 2015-16 M/S. Ingersoll-Rand Technologies & Services Pvt. Ltd., The Assistant 8Th Floor, Tower D, Commissioner Of Ibc Knowledge Park, Income Tax, No. 4/1, Bannerghatta Circle 3(1)(1), Main Road, Vs. Bangalore. Bangalore – 560 029. Pan: Aaaci2961B Appellant Respondent Assessee By : Shri Ankur Pai, Advocate : Smt. S. Praveena, Cit Dr Revenue By Date Of Hearing : 04-11-2022 Date Of Pronouncement : 04-01-2023 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Order Dated 11/10/2019 Passed By The Ld.Acit, Circle-3 (1)(1), Bangalore Relating To Assessment Year 2015-16 On Following Grounds Of Appeal: “1. Order Is Bad In Law & On Facts 1.1 The Order Passed By Assistant Commissioner Of Income-Tax, Circle - 3(1)(1) ["Learned Ao"] Under Section 143(3) Of The Income Tax Act, 1961 ["The Act"] Is Bad In Law & On Facts & Therefore, Liable To Be Set Aside.

transfer pricing analysis without appreciating the fact that the principle of aggregation of closely linked transactions is a well-established rule prescribed by the Organisation for Economic Co-Operation and Development Guidelines ("OECD Guidelines"). 3.4 The learned AO/ learned TPO/ Hon'ble DRP erred in holding that Comparable Uncontrolled Price ('CUP') is the MAM with respect to the payments made

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (LTU) , BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2835/Bang/2017 : Asst.Year 2013-2014 M/S.Dell International Services The Additional Commissioner India Private Limited Of Income-Tax (Ltu) V. Bangalore. Divyashree Greens, Sy.Nos.12/1, 12/2A & 13/1A,Challaghatta Village,Varthur Hobli Bengaluru – 560 071. Pan : Aaach1925Q. (Appellant) (Respondent) Appellant By : Sri.T.Suryanarayana, Advocate Respondent By : Sri.Praveen Karanth, Cit-Dr Date Of Pronouncement : 20.01.2023 Date Of Hearing : 13.01.2023 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 30.11.2017 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company, Engaged In The Business Of Manufacturing & Trading In Computer Systems Including Support & Maintenance Services & Leasing Of Computers. For The Assessment Year 2013-2014, The Return Of Income Was Filed On 30.11.2013 Declaring Total Income Of Rs.22,31,24,760. The Assessment Was Selected For Scrutiny & Notice U/S 143(2) Of The I.T.Act Was Issued On 2 It(Tp)A No.2835/Bang/2017. M/S.Dell International Services India Private Limited. 11.09.2014. During The Course Of Assessment Proceedings, It Was Noticed That The International Transactions Entered By The Assessee With Its Associated Enterprises (Aes) Had Exceeded The Prescribed Limit, Hence, The Matter Was Referred To The Transfer Pricing Officer (Tpo) To Determine The Arm’S Length Price (Alp) Of The Said Transaction. The Tpo Passed Order U/S 92Ca Of The I.T.Act On 19.10.2016. In The Said Order, The Tpo Had Proposed Following Adjustments:-

transfer pricing segment was restored to the AO / TPO to examine whether the assesee had recovered expenditure incurred in respect of warranty services with the 27 IT(TP)A No.2835/Bang/2017. M/s.Dell International Services India Private Limited. mark-up of 5%. The relevant finding of the Tribunal in assessee’s own case for assessment year 2009-2010, which has confirmed

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

MCAFEE SOFTWARE INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BENGALURU

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

Bench: Shri George George K & Shri Waseem Ahmed

section 43B of the Act, results in double disallowance given that such disallowance is already made by the Appellant in the tax return for AY 2 017-18. 3. Brief facts of the case are as follows: The assessee is a company engaged in the business of rendering software development services to its group companies. For the assessment year

INCOME-TAX OFFICER, WARD-1 , BELLARY vs. M/S. SOUTH WEST MINING LIMITED, BELLARY

In the result, appeal of the revenue is dismissed and CO filed by the assessee is dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2011-12 Ito M/S. South West Mining Limited Aayakar Bhavan Staff Road Vidya Nagar Fort Bellary Near Talur Cross Karnataka Toranagallu Vs. Bellary 583 201 Karnataka Pan No : Aafcs9792M Appellant Respondent C.O. No.4/Bang/2023 (Arising Out Of Ita No.457/Bang/2023) Assessment Year: 2011-12 M/S. South West Mining Limited Ito Vs. Bellary 583 201 Ward-1 Karnataka Bellary Appellant Respondent Assessee By : Shri Rakesh Joshi, A.R. Revenue By : Ms. Neera Malhotra, D.R. Date Of Hearing : 20.12.2023 Date Of Pronouncement : 08.02.2024 O R D E R Per Chandra Poojari: This Appeal By Revenue & Co By Assessee Are Directed Against The Order Of Nfac For The Assessment Year 2011-12 Dated 21.4.2023 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). The Revenue In This Appeal Raised Following Ground: “Whether The Ld. Cit(A) Is Justified On The Facts Of The Case & In Law, In Deleting The Addition Of Rs.287.72 Crores Claimed Towards “Mine Development Expenditure” U/S 37(1) In The Computation Of Income Which Was Not Routed Through The Profit & Loss Account.”

Transfer Price at Rs.832.31 per metric ton was received by assessee in October, 2011. Therefore, the invoices were raised in respect of said lignite excavated during FY 2010-11 after that date i.e. October 2011. Both the expenses on mining operations and revenues on account of lignite excavated till completion of initial mine cut (as per the approved mine plan

IMS HEALTH ANALYTICS SERVICES PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD-3(1)(1), BANGALORE

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

Transfer Pricing Officer [in short \"TPO"] to exclude all the instant\nsix comparables and compute the assessee's arm's length price [in short\nALP] adjustment accordingly.\nThus, the Appellant submits that above companies ought to be excluded\nfrom the final list of comparable.\n15.2 Based on the above findings of the ITAT in the case of different\ncompanies being