Chief CIT v. Pampapathi

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

INCOME TAX OFFICER, W-1, VIJAYANAGAR vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1163 to 1165/Bang/2023 Assessment Years: 2013-14 to 2015-16 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.1166/Bang/2023 Assessment Year: 2017-18 M/s. Ramachandra Setty & Sons ITO SRS Building Ward-1 BM Road Vs. Hassan Hassan 573 201 PAN NO : AAEFS4881R APPELLANT RESPONDENT ITA Nos.…

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

…rse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [20081 175 Taxman 318/ [20091 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed Page 34 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self-incriminating statement which the Revenue sought to rely upo…

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

…rse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [20081 175 Taxman 318/ [20091 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed Page 34 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self-incriminating statement which the Revenue sought to rely upo…

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

…rse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [20081 175 Taxman 318/ [20091 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed Page 34 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self-incriminating statement which the Revenue sought to rely upo…

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

…rse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [20081 175 Taxman 318/ [20091 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed Page 34 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self-incriminating statement which the Revenue sought to rely upo…

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…urse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [2008] 175 Taxman 318/[2009] 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self incriminating statement which the Revenue sought to rely upon as being a statement made under Section 132(4) of the Act. The Revenue's contention was…

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…urse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [2008] 175 Taxman 318/[2009] 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self incriminating statement which the Revenue sought to rely upon as being a statement made under Section 132(4) of the Act. The Revenue's contention was…

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…urse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [2008] 175 Taxman 318/[2009] 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self incriminating statement which the Revenue sought to rely upon as being a statement made under Section 132(4) of the Act. The Revenue's contention was…

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…urse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [2008] 175 Taxman 318/[2009] 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self incriminating statement which the Revenue sought to rely upon as being a statement made under Section 132(4) of the Act. The Revenue's contention was…

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…urse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [2008] 175 Taxman 318/[2009] 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self incriminating statement which the Revenue sought to rely upon as being a statement made under Section 132(4) of the Act. The Revenue's contention was…

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…urse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [2008] 175 Taxman 318/[2009] 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self incriminating statement which the Revenue sought to rely upon as being a statement made under Section 132(4) of the Act. The Revenue's contention was…

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…urse of search and any statement made during such examination by the such person (the person being examined on oath) would have evidentiary value under Section 132(4) of the Act. The Karnataka High Court in Chief CIT v. Pampapathi [2008] 175 Taxman 318/[2009] 310 ITR 64 in the context of facts before it viz. the search on the Assessee therein was completed on 13th December, 1994. On 25th January, 1995, a letter was written by the Assessee therein making certain self incriminating statement which the Revenue sought to rely upon as being a statement made under Section 132(4) of the Act. The Revenue's contention was…