ITAT Bangalore Judgments — October 2020

M/S.BRINDAVAN BEVERAGES PVT. LTD.,BANGALORE vs DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE

ITA 2004/BANG/2016[2013-14]Status: Disposed20 Oct 2020AY 2013-14Partly Allowed

The Tribunal held that the disallowance under Section 14A cannot exceed the amount of exempt income earned by the assessee. Therefore, the disallowance was restricted to the actual exempt income for the respective assessment years.

M/S PREEADITH CONSULTANCY,SHIMOGA vs INCOME-TAX OFFICER, SHIMOGA

ITA 1915/BANG/2016[2009-10]Status: Disposed20 Oct 2020AY 2009-10Withdrawn

The Tribunal considered the submissions and decided that keeping the appeal pending would serve no purpose as the assessee had already initiated proceedings under the Vivad Se Vishwas Act. The appeal was dismissed as withdrawn.

MR.HAJIVALI MOHD EBRAHIM,BANGALORE vs INCOME TAX OFFICER WARD-6(2)(4), BANGALORE

ITA 818/BANG/2019[2015-16]Status: Disposed20 Oct 2020AY 2015-16Dismissed

The Tribunal dismissed the appeals as withdrawn, granting the assessees liberty to approach the Tribunal for recall of the order if they opt out of the Vivad Se Viswas scheme or face issues with it.

M/ RANI CHANNAMMA UNIVERSITY,BELAGAVI vs COMMISSIONER OF INCOME TAX (EXEMPTIONS), BANGALORE

ITA 3177/BANG/2018[2017-18]Status: Disposed20 Oct 2020AY 2017-18Remanded

The Tribunal found that the assessee was not provided with adequate opportunity for hearing by the CIT(E) in both proceedings. Therefore, the matters were set aside and remanded back to the CIT(E) for fresh decisions.

SHRI MITHALALA JAIN,BANGALORE vs INCOME TAX OFFICER WARD-2(2)(4), BANGALORE

ITA 877/BANG/2019[2014-15]Status: Disposed20 Oct 2020AY 2014-15Dismissed

The Tribunal dismissed the appeal as withdrawn, noting that the assessee had initiated the settlement process under the Vivad Se Vishwas Act. The assessee was granted liberty to seek recall of the order if necessary.

MANYATA PROMOTERS PRIVATE LIMITED,BENGALURU vs DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BENGALURU

ITA 594/BANG/2020[2009-10]Status: Disposed20 Oct 2020AY 2009-10Dismissed

The Tribunal allowed the assessee to withdraw the appeals. Liberty was granted to move for recall of the order if the VSVS scheme was not accepted or if the assessee wished to opt out.

SRI. VELLIANGIRI SHANMUGAM,BANGALORE vs DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 5(3)(1), BANGALORE

ITA 1771/BANG/2019[2015-16]Status: Disposed20 Oct 2020AY 2015-16Dismissed

The tribunal allowed the assessee's request to withdraw the appeal. The appeal was dismissed as withdrawn, with liberty to seek recall if necessary under the Vivad se Vishwas Scheme.

SHRI ARVIND KUMAR,BANGALORE vs INCOME TAX OFFICER WARD-2(2)(4), BANGALORE

ITA 876/BANG/2019[2014-15]Status: Disposed20 Oct 2020AY 2014-15Dismissed

The Tribunal dismissed the appeal as withdrawn, noting that the assessee had already initiated the settlement process under the Vivad Se Vishwas Act. Liberty was granted to the assessee to seek recall of the order if necessary.

M/S RANI CHANNAMMA UNIVERSITY,BELAGAVI vs COMMISSIONER OF INCOME TAX (EXEMPTIONS), BANGALORE

ITA 3176/BANG/2018[2017-18]Status: Disposed20 Oct 2020AY 2017-18Remanded

The Tribunal found that the assessee was not provided with adequate opportunity for hearing by the CIT(E) in both proceedings. Therefore, the matters were set aside and remanded back to the CIT(E) for fresh decisions.

MAHENDRA B CHOWHAN,BANGALORE vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(2), BANGALORE

ITA 1594/BANG/2019[2013-14]Status: Disposed19 Oct 2020AY 2013-14Allowed

The Tribunal held that the penalty imposed was unsustainable because the show cause notice issued under section 274 of the Act was defective, failing to specify whether the penalty was for concealment of income or furnishing inaccurate particulars. This defect was not curable under section 292B.

SRI NASIR PASHA,MYSURU vs INCOME TAX OFFICER, WARD- 2(2), MYSURU

ITA 1677/BANG/2019[2008-09]Status: Disposed19 Oct 2020AY 2008-09Withdrawn

The Tribunal noted that the assessee had filed an application under the Vivad Se Vishwas Act and would withdraw the appeal. Therefore, the appeal was dismissed as withdrawn.

MAHENDRA B CHOWHAN,BANGALORE vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(2), BANGALORE

ITA 1593/BANG/2019[2012-2013]Status: Disposed19 Oct 2020AY 2012-2013Allowed

The Tribunal held that the penalty imposed was unsustainable because the show cause notice issued under section 274 of the Act was defective, failing to specify whether the penalty was for concealment of income or furnishing inaccurate particulars. This defect was not curable under section 292B.

MAHENDRA B CHOWHAN,BANGALORE vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(2), BANGALORE

ITA 1591/BANG/2019[2010-11]Status: Disposed19 Oct 2020AY 2010-11Allowed

The Tribunal held that the penalty imposed was unsustainable because the show cause notice issued under section 274 of the Act was defective, failing to specify whether the penalty was for concealment of income or furnishing inaccurate particulars. This defect was not curable under section 292B.

MAHENDRA B CHOWHAN,BANGALORE vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(2), BANGALORE

ITA 1592/BANG/2019[2011-12]Status: Disposed19 Oct 2020AY 2011-12Allowed

The Tribunal held that the penalty imposed was unsustainable because the show cause notice issued under section 274 of the Act was defective, failing to specify whether the penalty was for concealment of income or furnishing inaccurate particulars. This defect was not curable under section 292B.

MAHENDRA B CHOWHAN,BANGALORE vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(2), BANGALORE

ITA 1590/BANG/2019[2009-10]Status: Disposed19 Oct 2020AY 2009-10Allowed

The Tribunal held that the penalty imposed was unsustainable because the show cause notice issued under section 274 of the Act was defective, failing to specify whether the penalty was for concealment of income or furnishing inaccurate particulars. This defect was not curable under section 292B.

YOUNIS ZIA vs DCIT,

ITA 131/BANG/2013[2008-09]Status: Disposed19 Oct 2020AY 2008-09Dismissed

The Tribunal dismissed the appeals as withdrawn, granting the assessee liberty to seek recall of the order under Section 254(2) of the IT Act if they opt out of the Vivad Se Viswas scheme or encounter issues with it.

YOUNIS ZIA vs DCIT,

ITA 132/BANG/2013[2009-10]Status: Disposed19 Oct 2020AY 2009-10Dismissed

The Tribunal dismissed the appeals as withdrawn, granting the assessee liberty to seek recall of the order if they opt out of the Vivad Se Viswas scheme or face issues under the Act. This was based on the Tribunal's consistent view that keeping such appeals pending serves no purpose.

ASSISTANT COMMISSIONER OF INCOME TAX,BANGALORE vs M/S. KARNATAKA INDUSTRIAL AREA DEVELOPMENT BOARD, BANGALORE

ITA 1333/BANG/2016[2011-12]Status: Disposed19 Oct 2020AY 2011-12Dismissed

The Tribunal held that the first issue regarding the proviso to Section 2(15) was squarely covered in favor of the assessee by the Karnataka High Court's judgment in the assessee's own case. The second issue regarding depreciation was also covered by a Tribunal order in the assessee's own case, which followed a Supreme Court judgment.

JDA SOFTWARE INDIA PRIVATE LIMITED,BANGALORE vs DCIT, BANGALORE

ITA 352/BANG/2016[2011-12]Status: Disposed19 Oct 2020AY 2011-12Partly Allowed

The Tribunal held that several companies selected as comparables by the TPO and DRP were not appropriate for determining the arm's length price of software development services. The Tribunal also directed the Assessing Officer to examine the assessee's claim of non-receipt of refund.

SHRI.YUNUS ZIA,BANGALORE vs DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE

ITA 470/BANG/2018[2010-11]Status: Disposed19 Oct 2020AY 2010-11Dismissed

The Tribunal dismissed the appeals as withdrawn, granting the assessee liberty to seek recall of the order if they opt out of the Vivad Se Viswas scheme or face issues under it. This was based on the Tribunal's consistent view that keeping such appeals pending serves no purpose.

M/S. ISTAR SKILL DEVELOPMENT PVT LTD,BENGALURU vs INCOME TAX OFFICER, WARD-3(2)(1), BENGALURU

ITA 762/BANG/2018[2014-15]Status: Disposed19 Oct 2020AY 2014-15Remanded

The Tribunal admitted an additional ground raised by the assessee concerning a CBDT circular exempting startups from Section 56(2)(viib). The Tribunal held that this issue required verification and remanded the matter to the CIT(A) to examine the applicability of the circular and the fulfillment of prescribed conditions.

MAHENDRA B CHOWHAN,BANGALORE vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(2), BANGALORE

ITA 1595/BANG/2019[2014-15]Status: Disposed19 Oct 2020AY 2014-15Allowed

The Tribunal held that the penalty imposed was unsustainable because the show cause notice issued under section 274 of the Act was defective, failing to specify whether the penalty was for concealment of income or furnishing inaccurate particulars. This defect was not curable under section 292B.

MAHENDRA B CHOWHAN,BANGALORE vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(2), BANGALORE

ITA 1596/BANG/2019[2015-16]Status: Disposed19 Oct 2020AY 2015-16Allowed

The Tribunal held that the penalty imposed was unsustainable because the show cause notice issued under section 274 of the Act was defective as it did not specify the grounds for penalty (concealment of income or furnishing inaccurate particulars). This defect was not curable under section 292B.

M/S. EYGBS (INDIA) LLP (EARLIER KNOWN AS EYGBS (INDIA) PRIVATE LIMITED AND SUCCESSOR TO EYME TECHNOLOGIES PRIVATE LIMITED),BENGALURU vs ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE- 1(1), THIRUVANATHAPURAM

ITA 2300/BANG/2019[2009-10]Status: Disposed19 Oct 2020AY 2009-10Remanded

The Tribunal held that the deduction u/s 10A is allowable in principle for voluntary TP adjustments, as supported by prior tribunal rulings. However, the factual aspect of whether prior period expenses related to this income needed clarification.

SHRI. NAVEEN KUMAR GUPTA (HUF),MYSORE vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), MYSORE

ITA 2377/BANG/2019[2015-16]Status: Disposed16 Oct 2020AY 2015-16Dismissed

The tribunal dismissed the assessee's appeal as withdrawn. Liberty was granted to the assessee to approach the tribunal for recall of the order if they finally opt out of the Vivad Se Vishwas Scheme.

PRAGATHI CO-OPERATIVE BANK LIMITED,BANGALORE vs DIRECTOR OF INCOME TAX (INTELLIGENCE AND CRIMINAL INVESTIGATION), BANGALORE

ITA 1857/BANG/2019[2010-11]Status: Disposed16 Oct 2020AY 2010-11Allowed

The Tribunal held that the assessee had a reasonable cause for non-compliance with Rule 114E due to the ambiguity in the rule prior to its amendment, which specifically included cooperative banks. Therefore, the penalty under Section 271FA was not justified.

PRAGATHI CO-OPERATIVE BANK LIMITED,BANGALORE vs DIRECTOR OF INCOME TAX (INTELLIGENCE AND CRIMINAL INVESTIGATION), BANGALORE

ITA 1854/BANG/2019[2007-08]Status: Disposed16 Oct 2020AY 2007-08Allowed

The Tribunal held that the assessee had a reasonable cause for non-compliance with Rule 114E due to the ambiguity in the rule prior to its amendment, which specifically included cooperative banks. Therefore, the penalty under Section 271FA was not justified.

PRAGATHI CO-OPERATIVE BANK LIMITED,BANGALORE vs DIRECTOR OF INCOME TAX (INTELLIGENCE AND CRIMINAL INVESTIGATION), BANGALORE

ITA 1858/BANG/2019[2011-12]Status: Disposed16 Oct 2020AY 2011-12Allowed

The Tribunal held that the assessee had a reasonable cause for non-compliance with Rule 114E due to the ambiguity in the rule prior to its amendment, which specifically included cooperative banks. Therefore, the penalty under Section 271FA was not justified.

PRAGATHI CO-OPERATIVE BANK LIMITED,BANGALORE vs DIRECTOR OF INCOME TAX (INTELLIGENCE AND CRIMINAL INVESTIGATION), BANGALORE

ITA 1855/BANG/2019[2008-09]Status: Disposed16 Oct 2020AY 2008-09Allowed

The Tribunal held that the assessee had a reasonable cause for non-compliance with Rule 114E due to the ambiguity in the rule prior to its amendment, which specifically included cooperative banks. Therefore, the penalty under Section 271FA was not justified.

PRAGATHI CO-OPERATIVE BANK LIMITED,BANGALORE vs DIRECTOR OF INCOME TAX (INTELLIGENCE AND CRIMINAL INVESTIGATION), BANGALORE

ITA 1859/BANG/2019[2012-13]Status: Disposed16 Oct 2020AY 2012-13Allowed

The Tribunal held that the assessee had a reasonable cause for non-compliance with Rule 114E due to the ambiguity in the rule prior to its amendment, which specifically included cooperative banks. Therefore, the penalty under Section 271FA was not justified.

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1, KALABURAGI vs M/S KRISHNA GRAMEENA BANK, GULBARGA

ITA 521/BANG/2018[2013-14]Status: Disposed16 Oct 2020AY 2013-14Partly Allowed

The Tribunal dismissed the Revenue's appeals, finding no reason to interfere with the CIT(A)'s order as the relied-upon tribunal orders were not stayed or reversed. For the assessee's appeals, the disallowance of provision for privileged leave encashment was upheld based on a Supreme Court judgment, while the issue of disallowance of provision for bad and doubtful debts was restored to the AO for fresh adjudication.

M/S KRISHNA GRAMEENA BANK,GULBARGA vs ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1, GULBARGA

ITA 496/BANG/2018[2011-12]Status: Disposed16 Oct 2020AY 2011-12Partly Allowed

The Tribunal dismissed the Revenue's appeals, finding no reason to interfere with the CIT(A)'s order as the relied-upon tribunal orders were not stayed or reversed. For the assessee's appeals, the disallowance of provision for privileged leave encashment was upheld based on a Supreme Court judgment, while the issue of disallowance of provision for bad and doubtful debts was restored to the AO for fresh adjudication.

M/S KRISHNA GRAMEENA BANK,GULBARGA vs THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1, KALABURAGI

ITA 1102/BANG/2018[2012-13]Status: Disposed16 Oct 2020AY 2012-13Partly Allowed

The Tribunal dismissed the Revenue's appeals, finding no reason to interfere with the CIT(A)'s order as the relied-upon tribunal orders were not stayed or reversed. For the assessee's appeals, the disallowance of provision for privileged leave encashment was upheld based on a Supreme Court judgment, while the issue of disallowance of provision for bad and doubtful debts was restored to the AO for fresh adjudication.

PRAGATHI CO-OPERATIVE BANK LIMITED,BANGALORE vs DIRECTOR OF INCOME TAX (INTELLIGENCE AND CRIMINAL INVESTIGATION), BANGALORE

ITA 1856/BANG/2019[2009-10]Status: Disposed16 Oct 2020AY 2009-10Allowed

The Tribunal held that the assessee had a reasonable cause for non-compliance with Rule 114E due to the ambiguity in the rule prior to its amendment, which specifically included cooperative banks. Therefore, the penalty under Section 271FA was not justified.

M/S.NAVODAYA GRAMA VIKAS CHARITABLE TRUST,MANGALORE vs THE ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS) CIRCLE-1, MANGALORE

ITA 552/BANG/2018[2009-10]Status: Disposed16 Oct 2020AY 2009-10Allowed

The Tribunal held that advancing loans to SHGs is an application of income for charitable purposes, citing a CBDT circular and the trust's objects. The Tribunal found that the Assessing Officer's reasons for reopening the assessment lacked a live link and objective basis.

M/S. ANNAPURNESHWARI INVESTMENTS,BANGALORE vs THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2(2), BANGALORE

ITA 212/BANG/2020[2005-06]Status: Disposed16 Oct 2020AY 2005-06Dismissed

The Tribunal rejected the assessee's additional grounds regarding the applicability of Section 153C versus Section 148, finding no relevance in prior ITAT orders. The Tribunal also upheld the CIT(A)'s decision to confirm the additions made by the AO, noting the assessee's failure to provide supporting evidence.

PRAGATHI CO-OPERATIVE BANK LIMITED,BANGALORE vs DIRECTOR OF INCOME TAX (INTELLIGENCE AND CRIMINAL INVESTIGATION), BENGALURU

ITA 1853/BANG/2019[2006-07]Status: Disposed16 Oct 2020AY 2006-07Allowed

The Tribunal held that the assessee had a reasonable cause for non-compliance with Rule 114E due to the ambiguity in the rule prior to its amendment, which specifically included cooperative banks. Therefore, the penalty under Section 271FA was not justified.

PERMASTEELISA (INDIA) PRIVATE LIMITED,BANGALORE vs DCIT, BANGALORE

ITA 1071/BANG/2016[2009-10]Status: Disposed16 Oct 2020AY 2009-10Dismissed

The Tribunal dismissed the appeals as withdrawn, granting the assessee liberty to approach for recall of the order if they opt out of the Vivad Se Viswas scheme or face issues with it.

MRS. SHAMSHAD BEGUM,PUTTUR vs THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, MANGALURU

ITA 60/BANG/2020[2015-16]Status: Disposed16 Oct 2020AY 2015-16Allowed

The Tribunal held that when the CIT(A) determined that the assessment fell outside the purview of Section 153A, the assessment order should have been declared bad in law. Consequently, other grounds regarding the merits of additions became academic.

MRS. SHAMSHAD BEGUM,PUTTUR vs THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, BANGALORE

ITA 55/BANG/2020[2010-11]Status: Disposed16 Oct 2020AY 2010-11Allowed

The Tribunal held that when the CIT(A) determined that the assessment fell outside the purview of Section 153A, the assessment order should have been declared bad in law. Consequently, other grounds regarding the merits of additions became academic.

MRS. SHAMSHAD BEGUM,PUTTUR vs THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, MANGALURU

ITA 58/BANG/2020[2013-14]Status: Disposed16 Oct 2020AY 2013-14Allowed

The Tribunal held that when the CIT(A) determined that the assessment fell outside the purview of Section 153A, the assessment order should have been declared bad in law. Consequently, other grounds regarding the merits of additions became academic.

MRS. SHAMSHAD BEGUM,PUTTUR vs THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, MANGALURU

ITA 59/BANG/2020[2014-15]Status: Disposed16 Oct 2020AY 2014-15Allowed

The Tribunal held that when the CIT(A) determined that the assessment fell outside the purview of Section 153A, the assessment order should have been declared bad in law. Consequently, other grounds regarding the merits of additions became academic.

MRS. SHAMSHAD BEGUM,PUTTUR vs THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, BANGALORE

ITA 56/BANG/2020[2011-12]Status: Disposed16 Oct 2020AY 2011-12Allowed

The Tribunal held that when the CIT(A) determined that the assessment fell outside the purview of Section 153A, the assessment order should have been declared bad in law. Consequently, other grounds regarding the merits of additions became academic.

MRS. SHAMSHAD BEGUM,PUTTUR vs THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1, MANGALURU

ITA 57/BANG/2020[2012-13]Status: Disposed16 Oct 2020AY 2012-13Allowed

The Tribunal held that when the CIT(A) determined that the assessment fell outside the purview of Section 153A, the assessment order should have been declared bad in law. Consequently, other grounds regarding the merits of additions became academic.

NALLURPALLI UNNIKRISHNAN SRINIVAS,BANGALORE vs THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(3)(1), BANGALORE

ITA 1343/BANG/2017[2012-13]Status: Disposed16 Oct 2020AY 2012-13Partly Allowed

The tribunal upheld the AO's rejection of the assessee's books of accounts and the estimation of business income. However, following the Karnataka High Court's judgment in CIT vs. Bahubali Neminath Muttin, the tribunal deleted the addition of Rs. 107.27 lakhs for unexplained cash deposits, finding it to be explained by cash sales and withdrawals from disclosed bank accounts.

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1, KALABURAGI vs M/S KRISHNA GRAMEENA BANK, GULBARGA

ITA 522/BANG/2018[2011-12]Status: Disposed16 Oct 2020AY 2011-12Partly Allowed

The Tribunal dismissed the Revenue's appeals, finding no reason to interfere with the CIT(A)'s order as the relied-upon tribunal orders were not stayed or reversed. For the assessee's appeals, the disallowance of provision for privileged leave encashment was upheld based on a Supreme Court judgment, while the issue of disallowance of provision for bad and doubtful debts was restored to the AO for fresh adjudication.

M/S NAVODAYA GRAMA VIKAS CHARITABLE TRUST,MANGALORE vs THE ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS) CIRCLE-1, MANGALORE

ITA 553/BANG/2018[2014-15]Status: Disposed16 Oct 2020AY 2014-15Allowed

The Tribunal held that advancing loans to SHGs is an application of income for charitable purposes, citing a CBDT circular and the trust's objects. The Tribunal found that the Assessing Officer's reasons for reopening the assessment lacked a live link and objective basis.

SHRI. MALLIKARJUN H. METI,BAGALKOT vs THE INCOME TAX OFFICER, WARD- 1, BAGALKOT

ITA 1562/BANG/2019[2009-10]Status: Disposed16 Oct 2020AY 2009-10Dismissed

The Tribunal held that the penalty notice was not bad in law as it clearly stated the assessee had concealed income and furnished inaccurate particulars. Therefore, the principles of natural justice were followed, and the cited High Court judgment was not applicable.

PRAGATHI CO-OPERATIVE BANK LIMITED,BANGALORE vs DIRECTOR OF INCOME TAX (INTELLIGENCE AND CRIMINAL INVESTIGATION), BANGALORE

ITA 1860/BANG/2019[2013-14]Status: Disposed16 Oct 2020AY 2013-14Allowed

The Tribunal held that the assessee had a reasonable cause for non-compliance with Rule 114E due to the ambiguity in the rule prior to its amendment, which specifically included cooperative banks. Therefore, the penalty under Section 271FA was not justified.

M/S. UDAYANT MALHOUTRA & COMPANY PRIVATE LIMITED,BEGALURU vs THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 7(1)(1), BENGALURU

ITA 2527/BANG/2019[2015-16]Status: Disposed16 Oct 2020AY 2015-16Remanded

The Tribunal found that the valuation of shares held by the assessee in a listed company (Dynamite Technologies Ltd.) was a crucial factor in determining the Net Asset Value (NAV). Since the assessee claimed the market value of these shares was higher than what was considered by the lower authorities, the issue was remanded to the AO for verification.