M/S SAFINA HOTELS PRIVATE LIMITED vs. THE COMMISSIONER OF INCOME TAX

Appeal is allowed

Bench: S.SUJATHA,N.K.PATIL

Section 271(1)(c) of the Act. Thus, he submits that there is no variance between the contents of the notice issued and the orders passed. 8 6. It is further contended that the assessee had wrongly claimed the capital expenditure as the revenue expenditure under the head ‘financial expenses’ in the return of income filed, Assessing Officer has disallowed

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

6 of the Act, it is, therefore, liable to tax in India on its worldwide income including the profits attributable to its Permanent Establishments in foreign countries and also the incomes which are subjected to withholding tax in foreign countries. 15. The assessee-Company claims that it is entitled to relief of such income taxes paid in the foreign jurisdiction

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

6 of the Act, it is, therefore, liable to tax in India on its worldwide income including the profits attributable to its Permanent Establishments in foreign countries and also the incomes which are subjected to withholding tax in foreign countries. 15. The assessee-Company claims that it is entitled to relief of such income taxes paid in the foreign jurisdiction

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

Disallowed (Rs.) (I) (II) (III) 2009-10 28,76,23,325 9,95,82,217 2010-11 2,29,05,056 1,46,91,363 Of these, the Assessing Officer found that to the extent given in column 3 above, the appellant was unable to substantiate the said expense claimed before the Assessing Officer. 16. In respect of assessment

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

c) of the Act is legally sustainable in the light of the fact, which surfaced in the survey under Section 133-A of Act, that claim of 100% depreciation made by the respondent-assessee was not only false but was made in respect of non-existent goods, and that penalty is liable to be levied not only for concealing

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

6 only because one of the directors of the assessee company and of GLATIPL is common, Section 93CA is not applicable. The Tribunal also held that in order to constitute a relationship of an AE, the parameters laid down in both subsections (1) and (2) should be fulfilled. As per explanation, amendment carried out in sub-section (2) of section

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

disallowed(Rs) (I) (II) (III) 2009-10 28,76,23,325 9,95,82,217 2010-11 2,29,05,056 1,46,91,363 15. Of these the assessing officer found that to the extent given in column (III) above, the appellant was unable to substantiate the said expenses claimed before the assessing officer. 16.In respect of assessment

COMMISSIONER OF INCOME vs. SHRI MUNINAGA REDDY

Bench: ARAVIND KUMAR,JAYANT PATEL

disallowance resulting in increase to the income of the assessee, raises a presumption of concealment of income. It is a rebuttable presumption, which the assessee can rebut by furnishing material evidence to establish its claim. Explanation -1 to section 271(1)(c) of the Act provides that, if a person fails to offer an 6

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

The appeals stand dismissed

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

6. We have considered the submission of learned counsel for the parties and perused the appeal papers. - 10 - HC-KAR NC: 2026:KHC:10978-DB ITA No. 142 of 2025 C/W ITA No. 143 of 2025 ITA No. 144 of 2025 7. The assessee filed its return of income claiming the benefit of exemption under Section

SHRI. MUNINAGA REDDY vs. THE ASST. COMMISSIONER OF INCOME -TAX CIRCLE 6 (1)

Appeals are allowed to the aforesaid extent

Bench: ARAVIND KUMAR,JAYANT PATEL

section 271(1)(c) of the Act, the amount so added or disallowed in computing the assessee’s total income is deemed to represent the concealed income. It is for the assessee to furnish material to establish that the assessee has not concealed income or has not furnished inaccurate particulars of income. In the absence of any such evidence

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

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

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 are covered by definition of ‘Workman’ in Explanation (iii) to section 80JJAA of the Act read with

COMMISSIONER OF INCOME TAX-III vs. M/S SYNDICATE BANK

The appeals are disposed of

Bench: ALOK ARADHE,RAVI V HOSMANI

disallowing an amount of Rs.192,53,21,426/- on reversal of interest pertaining to earlier years as deduction out of current years income and added back to interest on zero coupon bonds to the tune of RS.1,03,53,095/- along with other additions/disallowance in computation of regular income/book profit. It was held that as per section 36(1)(viia

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

The appeal stands dismissed

Bench: S.SUJATHA,J.M.KHAZI

c) amend any intimation under sub-section (1) of section 200A; (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

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

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”) and to pass such other suitable order as deems fit in this appeal. 2.Heard the learned standing counsel Shri Y.V. Raviraj for appellants/revenue and the learned counsel

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

c) Whether the Tribunal was justified in rejecting the contention of the appellant that proceedings under Section 153C ought to be initiated only for assessment years in respect of which the documents were found during the search? d) Whether the Tribunal was correct in upholding the validity of the order under Section 153C of the Act for the assessment year

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

c) Whether the Tribunal was justified in rejecting the contention of the appellant that proceedings under Section 153C ought to be initiated only for assessment years in respect of which the documents were found during the search? d) Whether the Tribunal was correct in upholding the validity of the order under Section 153C of the Act for the assessment year

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

c) Whether the Tribunal was justified in rejecting the contention of the appellant that proceedings under Section 153C ought to be initiated only for assessment years in respect of which the documents were found during the search? d) Whether the Tribunal was correct in upholding the validity of the order under Section 153C of the Act for the assessment year

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

Bench: CHIEF JUSTICE,C M JOSHI

C M JOSHI ORAL JUDGMENT (PER: HON'BLE MR. VIBHU BAKHRU, CHIEF JUSTICE) 1. For the reasons stated in the applications ― I.A.No.1/2025, the same are allowed. The delay of 46 days in filing the above captioned appeals, is condoned. 2. The Revenue have filed the present appeals under Section 260A of the Income Tax Act, 1961 [the Act], impugning