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

Bench: K.SOMASHEKAR,UMESH M ADIGA

b) of subsection 1 of Section 153A of the Act. 7.It is further contended that Tribunal erroneously set-aside the assessment order passed for the year assessment year 2011- 12 holding that there is no satisfaction recorded by the assessing officer of the searched person (153A) in the file of the said person ignoring the intention of legislature and even

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

b) of subsection 1 of Section 153A of the Act. 9. It is further contended that Tribunal erroneously set-aside the assessment order passed for the year assessment year 2011- 12 holding that there is no satisfaction recorded by the assessing officer of the searched person (153A) in the file of the said person ignoring the intention of legislature

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 145A of the Income- tax Act which was inserted with effect from assessment year 1999-2000. The said provision states that the valuation of stock should include the amount of any tax duty, cess or fee - 94 - actually paid or incurred to bring the goods to its present location and condition. The Department has followed a consistent stand

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 145A of the Income- tax Act which was inserted with effect from assessment year 1999-2000. The said provision states that the valuation of stock should include the amount of any tax duty, cess or fee - 94 - actually paid or incurred to bring the goods to its present location and condition. The Department has followed a consistent stand

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

disallowances. 55. However, keeping in view the contention made by the learned Standing Counsel Shri Y.V. Raviraj for the appellant / Revenue and so also the learned counsel Shri Mayank Jain for the respondent / Assessee, at the cost of repetition, it is relevant to state that the counsel for the respondent / Assessee had relied the judgment of THE COMMISSIONER OF INCOME

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

The appeal stands dismissed

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

144(C)(13) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’) by making transfer pricing adjustment for Rs.4,16,65,106/- on the basis of the order passed under Section 92CA of the Act dated 24.10.2016. The assessing authority also made other additions. The assessee’s objections were not considered by the Dispute Resumption Panel and therefore

THE COMMISSIONER OF INCOME TAX vs. M/S BPL SANYO FINANCE LTD

In the result, the appeal filed by the revenue is

Bench: The Tribunal Was Arising From The Order Dated 4Th June 2004 Passed By The Commissioner Of Income Tax (Appeals) Bangalore (For Short “The

disallowed in computing the total income of such person as a result thereof, shall for the purposes of clause (c) of this sub-section, be deemed to represent the income in respect of which particulars have been concealed. 24. In this connection, at this stage, we would like to refer to the judgment of the Supreme Court in K.P.Madhusudan

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

The appeals stand dismissed

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

b), (c), (cc) and (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

THE PR COMMISSIONER OF INCOME TAX vs. M/S MPHASIS LTD

The appeal is dismissed accordingly

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

144(C)(13) by holding that the above profit was not eligible for deduction and hence, disallowed the claim of deduction under Section 10B of the Act. 4. The assessee preferred an appeal before the Income Tax Appellate Tribunal (‘the Tribunal’ for short) as its objections were rejected by the DRP (Dispute Resolution Panel) and the Tribunal has allowed

SMT. PUNEETHA @ PUNEETHA B. A. vs. SRI. D. RAVI

The appeal is dismissed accordingly

Bench: R DEVDAS

144(C)(13) by holding that the above profit was not eligible for deduction and hence, disallowed the claim of deduction under Section 10B of the Act. 4. The assessee preferred an appeal before the Income Tax Appellate Tribunal (‘the Tribunal’ for short) as its objections were rejected by the DRP (Dispute Resolution Panel) and the Tribunal has allowed

M/S FIDELITY BUSINESS SERVICES INDIA PVT LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX

Bench: S.SUJATHA,VINEET KOTHARI

B”, vide its Order dated 22/02/2017 for AY 2011-12 held partly in favour of the Appellant – Assessee that Appellant Assessee was not liable to pay tax on ‘Distribution of Dividend’ as defined under Section 2(22)(d) of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’ for short) in terms of Section

MADHU SOUHARDA PATHINA SAHAKARI NIYAMITHA vs. THE INCOME TAX OFFICER

The appeal stands dismissed

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

B” Bench, Bengaluru (for short, “the Tribunal”) in ITA No. 969/Bang/2023 dated 02.01.2024, relating to the Assessment Year 2017–18. The assessee is assessed in the status of an Association of Persons (AOP). - 3 - HC-KAR NC: 2026:KHC:1855-DB ITA No. 207 of 2024 2.1 The assessee did not file a return of income for the Assessment Year

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

The appeals are allowed; the impugned

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

144(C) of the Act of 1961 on 12.10.2012, wherein the assessing officer has 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

PR. COMMISSIONER OF INCOME TAX vs. SRI SRI ADICHUNCHUNAGIRI SHIKSHANA TRUST

In the result, all the appeals are

Bench: JAYANT PATEL,B.SREENIVASE GOWDA

144 of the Act denying exemption under Section 10(23) of the Act. The addition of income was made on account of disallowance of depreciation by the Assessing Officer. 4. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Bangalore. The CIT(A) after calling for 4 the remand report from the Assessing Officer, allowed

THE COMMISSIONER OF INCOME TAX vs. M/S KARNATAKA REDDY JANASANGHA

The appeals are dismissed

Bench: S.SUJATHA,N.K.PATIL

144 of the Act denying exemption under Section 10(23) of the Act. The addition of income was made on account of disallowance of depreciation by the Assessing Officer. 4. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Bangalore. The CIT(A) after calling for the remand report from the Assessing Officer, allowed

THE COMMISSIONER OF INCOME TAX vs. SRI ADICHUNCHUNGIRI

The appeals are dismissed

Bench: S.SUJATHA,N.K.PATIL

144 of the Act denying exemption under Section 10(23) of the Act. The addition of income was made on account of disallowance of depreciation by the Assessing Officer. 4. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Bangalore. The CIT(A) after calling for the remand report from the Assessing Officer, allowed

THE DIRECTOR OF INCOME TAX vs. M/S GOKULA EDUCATION FOUNDATION (MEDICAL)

The appeals are dismissed

Bench: S.SUJATHA,N.K.PATIL

144 of the Act denying exemption under Section 10(23) of the Act. The addition of income was made on account of disallowance of depreciation by the Assessing Officer. 4. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Bangalore. The CIT(A) after calling for the remand report from the Assessing Officer, allowed

THE DIRECTOR OF INCOME TAX EXEMPTIONS vs. AL-AMEEN CHARITABLE FUND TRUST

The appeals are dismissed

Bench: S.SUJATHA,N.K.PATIL

144 of the Act denying exemption under Section 10(23) of the Act. The addition of income was made on account of disallowance of depreciation by the Assessing Officer. 4. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Bangalore. The CIT(A) after calling for the remand report from the Assessing Officer, allowed

COMMISSIONER OF INCOME vs. SRI ADICHUNCHANAGIRI

The appeals are dismissed

Bench: S.SUJATHA,N.K.PATIL

144 of the Act denying exemption under Section 10(23) of the Act. The addition of income was made on account of disallowance of depreciation by the Assessing Officer. 4. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Bangalore. The CIT(A) after calling for the remand report from the Assessing Officer, allowed

THE DIRECTOR OF INCOME TAX vs. INTERNATIONAL INSTITUTE OF INFORMATION TECHNOLOGY

The appeals are dismissed

Bench: S.SUJATHA,N.K.PATIL

144 of the Act denying exemption under Section 10(23) of the Act. The addition of income was made on account of disallowance of depreciation by the Assessing Officer. 4. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Bangalore. The CIT(A) after calling for the remand report from the Assessing Officer, allowed