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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 154. Notice u/s 142(1) was issued on 21.12.2001 with a questionnaire. Further notices u/s 142 (1) were issued on various dates beginning from 7.10.2003 to 8.3.2004. The assessee- company filed written replies along with enclosures from time to time. The return furnished on 30.10.2001 was processed u/s 143(3) of the I.T.Act on 24.03.2004 and order was passed

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

d) Without prejudice to the above, the case does not fall under section 92CA of the Act. Section 33 92CA is applicable in the cases where arm length price has to be computed under section 92C of the Act, in the cases relating to an international transaction. The term international transaction has been defined in section

THE COMMISSIONER OF INCOME TAX (EXEMPTION) vs. CMR JNANADHARA TRUST

The appeals stand dismissed

Bench: S.G.PANDIT,K. V. ARAVIND

d) of 13(3), have a substantial interest is involved, the embargo contained under Section 13(1)(c) of the Act would stand attracted. 7.3 Section 13(1)(c) mandates that, in the case of a Trust, if any part of its income or property is applied, directly or indirectly, for the benefit of the persons referred

PR. COMMISSIONER OF INCOME TAX vs. SMT. G. LAKSHMI ARUNA

Bench: K.SOMASHEKAR,UMESH M ADIGA

13. It is further contended by the standing counsel for the appellant, that against the order passed by the Deputy Commissioner of Income Tax, Central Circle 1(3), Bangalore dated 31.03.2013, further an appeal was preferred before the Commissioner of Income Tax (Appeals) – VI wherein the appellate order and ground of decision was passed. The assessments under Section 153C read

PR. COMMISSIONER OF INCOME TAX vs. SHRI. GALI JANARDHANA REDDY

Bench: K.SOMASHEKAR,UMESH M ADIGA

D. The prayer sought for in this appeal is to set aside the said order by allowing the appeal and confirming the order of the Appellate Commissioner and thereby confirming the order passed by the Deputy Commissioner of Income Tax, Central Circle – 1(3), Bengaluru and with a further prayer seeking to set-aside the order passed by the Income

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S.J.J.GLASTRONICS PVT LTD

The appeal stands dismissed

Bench: S.SUJATHA,J.M.KHAZI

d) amend any intimation under sub-section (1) of section 206CB; - 8 - (1A) Where any matter has been considered and decided in any proceeding by way of appeal or revision relating to an order referred to in sub- section (1), the authority passing such order may, notwithstanding anything contained in any law for the time being in force, amend

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

In the result, I proceed to pass the following:

Bench: The Hon’Ble Mr.Justice Aravind Kumar

13,72,23,231/- came to be disallowed. 24. Thus, an amount of ` 48,41,82,071/- out of deduction of ` 89,35,48,193/- claimed under Section 38 35(2AB) was disallowed and added to the income of the assessee. It has been held by the second respondent that the mandate of the prescribed authority is limited to certifying

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

D) TO THE EXTENT QUESTIONED & ETC. THESE I.T.As. COMING ON FOR ORDERS, THIS DAY, ALOK ARADHE J., DELIVERED THE FOLLOWING: COMMON JUDGMENT These appeals under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) have been filed by the assessee as well as the revenue. I.T.A.No.313/2018 and I.T.A.No.315/2018 have been filed

PR. COMMISSIONER OF INCOME TAX vs. M/S AMALGAMATED BEAN COFFEE TRADING CO LTD

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

D) TO THE EXTENT QUESTIONED & ETC. THESE I.T.As. COMING ON FOR ORDERS, THIS DAY, ALOK ARADHE J., DELIVERED THE FOLLOWING: COMMON JUDGMENT These appeals under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) have been filed by the assessee as well as the revenue. I.T.A.No.313/2018 and I.T.A.No.315/2018 have been filed

COFFEEDAY GLOBAL LTD. vs. ADDITIONAL COMMISSIONER OF INCOME TAX

In the result, the orders dated 21

Bench: ALOK ARADHE,ASHOK S.KINAGI

D) TO THE EXTENT QUESTIONED & ETC. THESE I.T.As. COMING ON FOR ORDERS, THIS DAY, ALOK ARADHE J., DELIVERED THE FOLLOWING: COMMON JUDGMENT These appeals under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) have been filed by the assessee as well as the revenue. I.T.A.No.313/2018 and I.T.A.No.315/2018 have been filed

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S NIRANI SUGARS LTD.,

In the result, the impugned orders passed by

Bench: ALOK ARADHE,P.G.M.PATIL

disallowance of depreciation. The assessee thereupon approached the Income Tax Appellate Tribunal. The Tribunal, by an order dated 19.02.2015 has allowed the appeal preferred by the assessee and set aside the order of the Commission of Income Tax (Appeals). The Assessing Officer was further directed to allow depreciation as per Appendix I at the higher rates. The Tribunal, inter alia

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S NIRANI SUGARS LTD.,

In the result, the impugned orders passed by

Bench: ALOK ARADHE,P.G.M.PATIL

disallowance of depreciation. The assessee thereupon approached the Income Tax Appellate Tribunal. The Tribunal, by an order dated 19.02.2015 has allowed the appeal preferred by the assessee and set aside the order of the Commission of Income Tax (Appeals). The Assessing Officer was further directed to allow depreciation as per Appendix I at the higher rates. The Tribunal, inter alia

THE COMMISIONER OF INCOME-TAX vs. M/S IBC KNOWLEDGE PARK PVT LTD

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

d) Whether the Tribunal was correct in upholding the validity of the order under Section 153C of the Act for the assessment year 2005-06 despite there being no pending assessment as on the date of search and the documents not revealing any undisclosed income? - 9 - 4. The appeals filed by the Revenue raise the following substantial questions

THE COMMISSIONER OF INCOME-TAX vs. M/S. IBC KNOWLEDGE PARK PVT. LTD.,

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

d) Whether the Tribunal was correct in upholding the validity of the order under Section 153C of the Act for the assessment year 2005-06 despite there being no pending assessment as on the date of search and the documents not revealing any undisclosed income? - 9 - 4. The appeals filed by the Revenue raise the following substantial questions

THE COMMISSIONER OF INCOME-TAX vs. M/S. IBC KNOWLEDGE PARK PVT. LTD.,

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

d) Whether the Tribunal was correct in upholding the validity of the order under Section 153C of the Act for the assessment year 2005-06 despite there being no pending assessment as on the date of search and the documents not revealing any undisclosed income? - 9 - 4. The appeals filed by the Revenue raise the following substantial questions

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

D G M E N T 1.This appeal is filed by the appellants/revenue seeking to set aside the order passed by the Income Tax Appellate Tribunal, ‘C’ Bench, Bengaluru (for short “ITAT”) in ITA No.653 (Bang) 2015, dated 29.07.2016; to confirm the order passed by the Deputy Commissioner of Income Tax, Central Circle 1(3), Bengaluru (for short “DCIT

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S. PUMA SPORTS INDIA P., LTD.,

The appeal stands dismissed

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

disallowance made under Section 40(a)(1) of the Act for the sum of 5 Rs.7,29,13,934/- by holding that the income of the non-residents by way of commission cannot be considered as accrued or arisen or deemed to accrue or arise in India as the services of such agents were rendered or utilized outside India

MANGALORE REFINERY AND PETROCHEMICALS LTD vs. PRINCIPAL COMMISSIONER OF INCOME TAX

In the result, I pass the following:-

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

d) for costs of this Petition. “ 2. Both the petitions are by the same petitioner – assessee seeking identical reliefs. While W.P.No.10551/2022 is in relation to the assessment year 2008-09, W.P.No.10523/2022 is in relation to the assessment year 2009-10. Since common issues arise for consideration in both the matters, they are taken up together and disposed