SHANKARANARAYANA CONSTRUCTIONS PRIVATE LIMITED,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE 2(4), CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU

ITA 1269/BANG/2025Status: DisposedITAT Bangalore26 November 2025AY 2016-2017Bench: SHRI LAXMI PRASAD SAHU (Accountant Member), SHRI SOUNDARARAJAN K. (Judicial Member)1 pages
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What did the Tribunal hold?

The tribunal held that the issue of telescoping excess income offered in some years against shortfalls in others should be examined by the AO. Regarding Section 14A disallowance, the tribunal remitted the issue to the AO for fresh consideration, emphasizing the need for recorded satisfaction.

What were the facts?

The assessee filed appeals against orders related to assessment years 2015-16 to 2018-19. Key issues involved the legality of a search under Section 132, subsequent assessment under Section 153A, disallowance of lease expenses, and an ad-hoc addition for unexplained expenditure.

What were the issues?

Whether a search under Section 132 was valid, justifying assessment under Section 153A, and whether excess income offered in one year can be set off against shortfalls in others (telescoping).

Which sections of the Income-tax Act were involved?

Section 132,Section 153A,Section 250,Section 14A,Section 234A,Section 234B,Section 234C

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Income Tax Appellate Tribunal, ‘B’ BENCH : BANGALORE

Before: SHRI LAXMI PRASAD SAHU & SHRI SOUNDARARAJAN K.

For Appellant: Shri Muthu Shankar, CIT-

PER BENCH These are the four appeals filed by the assessee against the separate orders passed by the Ld.CIT(A) dated 28/03/2025 in respect of the A.Ys. 2015-16, 2016-17, 2017-18 and 2018-19. 2. The issues involved in all the appeals are common except for the A.Y. in which the additional issue of disallowance made u/s. 14A was involved and therefore for the sake of convenience, all the appeals are taken up together and the appeal in ITA No. 1268/Bang/2025 is taken as the lead ITA Nos. 1268 to 1271/Bang/2025 case and the decision arrived in the sai

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