ACE DESIGNERS LIMITED vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

31 (c) The substituted provision, being a beneficial amendment and being procedural in nature would have retrospective and retroactive operation. 5. On the other hand, the learned Additional Advocate General, Shri A.S. Ponnanna, appearing for the State would contend that Section 2(33) KVAT authorizes the State legislature to prescribe the tax period for the purpose of submission of filing

INGRAM MICRO INDIA PVT. LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

31 (c) The substituted provision, being a beneficial amendment and being procedural in nature would have retrospective and retroactive operation. 5. On the other hand, the learned Additional Advocate General, Shri A.S. Ponnanna, appearing for the State would contend that Section 2(33) KVAT authorizes the State legislature to prescribe the tax period for the purpose of submission of filing

INGRAM MICRO INDIA PVT.LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

31 (c) The substituted provision, being a beneficial amendment and being procedural in nature would have retrospective and retroactive operation. 5. On the other hand, the learned Additional Advocate General, Shri A.S. Ponnanna, appearing for the State would contend that Section 2(33) KVAT authorizes the State legislature to prescribe the tax period for the purpose of submission of filing

M/S. HINDUSTAN COCA COLA vs. STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

31 (c) The substituted provision, being a beneficial amendment and being procedural in nature would have retrospective and retroactive operation. 5. On the other hand, the learned Additional Advocate General, Shri A.S. Ponnanna, appearing for the State would contend that Section 2(33) KVAT authorizes the State legislature to prescribe the tax period for the purpose of submission of filing

DEPA INDIA PRIVATE LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

31 (c) The substituted provision, being a beneficial amendment and being procedural in nature would have retrospective and retroactive operation. 5. On the other hand, the learned Additional Advocate General, Shri A.S. Ponnanna, appearing for the State would contend that Section 2(33) KVAT authorizes the State legislature to prescribe the tax period for the purpose of submission of filing

M/S. HINDUSTAN COCA COLA vs. STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

31 (c) The substituted provision, being a beneficial amendment and being procedural in nature would have retrospective and retroactive operation. 5. On the other hand, the learned Additional Advocate General, Shri A.S. Ponnanna, appearing for the State would contend that Section 2(33) KVAT authorizes the State legislature to prescribe the tax period for the purpose of submission of filing

KAVERI PLASTO CONTAINERS PVT LTD vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

31 (c) The substituted provision, being a beneficial amendment and being procedural in nature would have retrospective and retroactive operation. 5. On the other hand, the learned Additional Advocate General, Shri A.S. Ponnanna, appearing for the State would contend that Section 2(33) KVAT authorizes the State legislature to prescribe the tax period for the purpose of submission of filing

M/S INDIA MOTOR PARTS & ACCESSORIES LTD vs. THE DEPUTY COMMISSIONER OF

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

31 (c) The substituted provision, being a beneficial amendment and being procedural in nature would have retrospective and retroactive operation. 5. On the other hand, the learned Additional Advocate General, Shri A.S. Ponnanna, appearing for the State would contend that Section 2(33) KVAT authorizes the State legislature to prescribe the tax period for the purpose of submission of filing

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

31 - head profit and gains of business or profession. In respect of the income of the unit qualifying for deduction under Section 10-A, income tax is neither paid nor incurred. The Apex Court in the case of CIT –vs- Williamson Financial Services & Ors. (297 ITR 17) dealing with computation of deduction under Section 80HHC in respect of profits from

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

31 - head profit and gains of business or profession. In respect of the income of the unit qualifying for deduction under Section 10-A, income tax is neither paid nor incurred. The Apex Court in the case of CIT –vs- Williamson Financial Services & Ors. (297 ITR 17) dealing with computation of deduction under Section 80HHC in respect of profits from

KARNATAKA STATE BEVERAGES CORPORTION LIMITED vs. THE COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr. Justice Anand Byrareddy Writ Petition No.12872 Of 2013 (T-It) Connected With Writ Petition No.14687 Of 2014 (T-It), Writ Petition No.15910 Of 2015 (T-It) & Writ Petition No.17514 Of 2015 (T-It) In W.P.No.12872 Of 2013 Between: Karnataka State Beverages Corporation Limited, Represented By It’S Executive Director (Finance), Sri. Shrikant B Vanahalli, Aged About 57 Years, No.78, Seethalakshmi Towers, Mission Road, Bangalore 560 027. …Petitioner

10(4) of the 1922 Act was similarly worded as Section 40(a)(ii) with one 17 major difference. In that, the word ‘cess’ was deleted. Thus, in order to bring it into the ambit of disallowance, it would have to be specifically included in the section. It is also pointed out that the words ‘royalty’ or ‘privilege

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

10-AA of the Act on the ground that the same was occasioned by TP adjustment. The said disallowance was founded on the proviso to Section 92C(4) of the Act. - 12 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 17. It is material to note that the TP adjustments

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S. TE CONNECTIVITY INDIA PVT. LTD.,

Accordingly dispose of the appeal as allowed

Bench: ACTING CHIEF JUSTICE,S RACHAIAH

disallowance under Section 40(a)(ia) ought to be made is incorrect and erroneous/ As stated by the respondent, the debit to the profit and loss account of Rs.36,34,10,000/- represents trade discounts given to distributors, where transactions are on a principal-to- principal basis and not commission and Section 194H would have no application to discounts. According

THE PR COMMISSIONER OF vs. M/S MAHAVEER CALYX

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

disallowance under Section 14A towards any interest expenditure can be made. Similar view was taken in CIT VS. HDFC BANK LTD., 366 ITR 505 (Bom). The aforesaid decisions were followed by a bench of this court in 'PRINCIPAL COMMISSINOER OF INCOME TAX AND ANOTHER VS. GOLDMEN SACHS SERVICES P. LTD.', 409 ITR 268 (KARN). In the light of the aforesaid

THE COMMISSIONER OF INCOME-TAX vs. TEXAS INSTRUMENTS INDIA PVT LTD

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

10. The above appeals were admitted on 8.10.2020 and the following substantial questions of law were formulated: “1. Whether, on the facts and in the circumstances of the case, the Tribunal is right in law in setting aside the disallowance of Rs.7,57,22,069 made under section 80JJAA of the Act by holding that the employees in software industry

THE PR. COMMISSIONER OF INCOME TAX vs. M/S CISCO SYSTEMS

The appeals are allowed; the impugned

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

disallowed the excess depreciation claimed on networking equipments. 3. The Principal Commissioner of Income Tax, Bengaluru, thereafter issued a notice under Section 263 of the Act of 1961 on 5.3.2015 and called upon the assessee to explain as to why the assessment order passed by the assessing officer under Section 143(3) of the Act of 1961 should

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

10 the Supreme Court in INDIA CEMENTS VS. CIT [(19660 60 ITR 52(SC)]. 3. Being aggrieved by the order passed by the Commissioner of Income Tax (Appeals), the assessee as well as the revenue filed theappeals before the tribunal The tribunal by an order dated 21.06.2017 partly allowed theappeal preferred by the assessee and revenue and held as under

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

10 the Supreme Court in INDIA CEMENTS VS. CIT [(19660 60 ITR 52(SC)]. 3. Being aggrieved by the order passed by the Commissioner of Income Tax (Appeals), the assessee as well as the revenue filed theappeals before the tribunal The tribunal by an order dated 21.06.2017 partly allowed theappeal preferred by the assessee and revenue and held as under