M/S. UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing provision and not while allowability of business expense u/s 37(1). It is well known fact that companies use sports event as a platform to advertise their range of products as it has a very high viewership. Any such incurring of expenditure is ostensibly for promotion of business only and hence, no disallowance is called for. Accordingly, Grounds

M/S. SHINDENGEN INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(2), BANGALORE

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

Bench: Shri N.V. Vasudevan, Vice- & Ms. Padmavathy Sit(Tp)A No. 2514/Bang/2019 Assessment Year : 2015-16 M/S. Shindengen India Pvt. Ltd., Plot No. 283/2, Bommasandra, The Deputy Jigani Link Road, Commissioner Of Jigani Industrial Area, Income Tax, Anekal Taluk, Circle – 6(1)(1), Bengaluru – 560 105. Bengaluru. Vs. Pan: Aarcs8947E Appellant Respondent Assessee By : Smt. Shashi M Kapila, Advocate Revenue By : Ms. Neera Malhotra, Cit-Dr Date Of Hearing : 14-02-2023 Date Of Pronouncement : 28-02-2023 Order Per Padmavathy S

Section 271(1)(c) of the Act. 7. The Ld AO erred in not allowing set off of current year losses and brought forward losses amounting to Rs. 4,98,73,540 and Rs. 4,59,11,799 aggregating to Rs. 9,57,85,339 Page 3 IT(TP)A No. 2514/Bang/2019 The Appellant craves leave to amend, alter

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

AC 588 HL, Bansilalmotilal's case\nand Commissioner of Income Tax, Madras v Dewan Bahadur S.L. Mathias.\n\n10.3 Therefore an income could arise or accrue from a source in India\nwhen either of the following conditions are satisfied:\n\na) Paid by a person established in India (situs of payer) or\nDerived from work performed in India (situs

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

AC 588 HL, Bansilalmotilal's case\nand Commissioner of Income Tax, Madras v Dewan Bahadur S.L. Mathias.\n10.3 Therefore an income could arise or accrue from a source in India\nwhen either of the following conditions are satisfied:\na) Paid by a person established in India (situs of payer) or\nDerived from work performed in India (situs of activity)\n10.4

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRLCE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

In the result, all these 4 appeals filed by the Revenue are dismissed

AC 588 HL, Bansilalmotilal's case\nand Commissioner of Income Tax, Madras v Dewan Bahadur S.L. Mathias.\n\n10.3 Therefore an income could arise or accrue from a source in India\nwhen either of the following conditions are satisfied:\na) Paid by a person established in India (situs of payer) or\nDerived from work performed in India (situs of activity

M/S. TATA POWER SOLAR SYSTEMS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 7(1)(1), BANGALORE

In the result, the appeal of the assessee stands allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2004-05 M/S. Tata Power Solar Systems Limited, Acit, No.78, Hosur Road, Circle – 7(1)(1), Electronic City, Vs. Bengaluru. Bengaluru – 560 100. Pan : Aaact 4660 J Appellant Respondent Assessee By : Shri. Vikram Udupa, Advocate Revenue By : Shri. Sunil Kumar Singh, Cit-2(Dr)(Itat), Bengaluru Date Of Hearing : 08.05.2023 Date Of Pronouncement : 17.05.2023

2. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in making an adjustment of INR 9f9,7po,000 in respect of the international transactions of the Appellant. 3. On the facts and circumstances of the case, the learned CIT(A) erred in upholding the action of the Transfer Pricing Officer

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

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

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU vs. SRI. SURESH S KANAJI, BENGALURU

In the result, appeal of the revenue is hereby dismissed

AC in the return of income filed\nwithout any reasoning?\n(ii)\nWhether on the facts and circumstances of the case and in\nLaw, the CIT(A) was correct in accepting the contention of assessee\nthat he had declared income @6.05% of the receipts in Form 26AS and\nthe same was in addition to income of Rs. 1 crore declared

M/S. CORPORATE LEISURE & PROPERTY DEVELOPMENT PVT. LTD.,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(1)(1), BENGALURU

In the result, the appeal fails and is hereby dismissed

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

55,530/-before set off of brought forward losses under the facts and circumstances of the case. M/s. Corporate Leisure & Property Development Pvt. Ltd., Bangalore Page 2 of 32 2. a. The learned CIT(A) erred in confirming the addition made by the assessing officer of Rs.3,82,49,464/- by changing the accounting policy regularly followed by the appellant