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

46A, but not for setting aside the issue for fresh decision when all relevant material is already available on record. It is also pertinent note that vide Finance Act 2024 a proviso inserted below to section 251(1)(a) of the Act confirming power to commissioner/joint commissioner of appeal in respect of setting aside the assessment and refer back

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

46A, but not for setting aside the issue for fresh decision when all\nrelevant material is already available on record. It is also pertinent note\nthat vide Finance Act 2024 a proviso inserted below to section 251(1)(a)\nof the Act confirming power to commissioner/joint commissioner of\nappeal in respect of setting aside the assessment and refer back

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

46A in\nsection 10 and the consequential amendment made to the Explanation to\nthe 19th proviso of clause 23C of section 10 of the Act. The Ld.CIT(A)\nobserved that the amendments would take effect from 01/04/2024 and\ntherefore the same would be applicable from the A.Y. 2024-25. The\nLd.CIT(A), therefore confirmed the orders of the AO insofar

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

46A in\nsection 10 and the consequential amendment made to the Explanation to\nthe 19th proviso of clause 23C of section 10 of the Act. The Ld.CIT(A)\nobserved that the amendments would take effect from 01/04/2024 and\ntherefore the same would be applicable from the A.Y. 2024-25. The\nLd.CIT(A), therefore confirmed the orders of the AO insofar

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

46A, but not for setting aside the issue for fresh decision when all\nrelevant material is already available on record. It is also pertinent note\nthat vide Finance Act 2024 a proviso inserted below to section 251(1)(a)\nof the Act confirming power to commissioner/joint commissioner of\nappeal in respect of setting aside the assessment and refer back

AMRUTHA CONSTRUCTIONS PRIVATE LIMITED,SANJAYANAGAR vs. DCIT CENTRAL CIRCLE 2(2) , BANGALORE

In the result appeal of the Revenue is partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

pricing, alternate source of procurement, or contradictions in stock records. The case rests purely on presumptions and incomplete analysis. In view of the above, we find that the disallowance of Rs. 17.84 crore lacks legal and factual merit. The actions of the Revenue authorities suffer from inconsistency in approach, selective application of seized evidence, and shifting grounds of assessment without

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE, BANGALORE vs. AMRUTHA CONSTRUCTIONS PRIVATE LIMITED, BANGALORE

In the result, the CO of the assessee is partly allowed

pricing, alternate source of procurement,\nor contradictions in stock records. The case rests purely on presumptions\nand incomplete analysis. In view of the above, we find that the\ndisallowance of Rs.17.84 crore lacks legal and factual merit. The actions\nof the Revenue authorities suffer from inconsistency in approach,\nselective application of seized evidence, and shifting grounds of\nassessment without proper