CIT v. Calcutta Knitwears

362 ITR 673Supreme Court of India2014#122 most cited

What is CIT v. Calcutta Knitwears authority for?

The recording of a satisfaction note by the Assessing Officer is a jurisdictional prerequisite for assessments under Section 153C, and the six-year limitation period for such assessments is reckoned from the date this satisfaction is recorded.

528

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Calcutta Knitwears · section 153C · satisfaction note · jurisdictional prerequisite · limitation period · seized material · assessment year · block period · search assessment · section 158BD

Also reported as

43 Taxmann.com 446223 Taxmann 115

Sections most often in play

Section 153CSection 143(3)Section 132Section 153ASection 153DSection 144Section 115BBESection 292C
Read the full judgment

Issues it is cited on

section 158bdincome tax settlement commissionsection 158bcsection 144asection 144basatisfaction notesection 158bblock periodsection 158section 153c(1)documents seizedsection 292c

Judgments citing CIT v. Calcutta Knitwears

Shree Basaveshwar Sugars Limited, Vijayapura vs. ACIT, Centrl Circle, Trichirapalli

In the result, the appeals filed by the assessee in ITA

ITA 1010/CHNY/2022[2017-18]Status: DisposedITAT Chennai18 Jan 2023AY 2017-18
For Appellant: Shri G. Baskar, Shri I. Dinesh &For Respondent: Shri R. Mohan Reddy, CIT
Section 132Section 132(4)Section 142(1)Section 144Section 153C

…ommissioner (Appeals) may kindly call for the records of the AO. In the absence of any satisfaction note the assessment is liable to be quashed as ab initio void. We place reliance on the decision of the Supreme Court in the case of CIT vs. Calcutta Knitwears 362 ITR 673 and in the light of the CBDT Circular No.24/2015 dated 31-12-2015. If there is one, the AO may be directed to furnish a copy of the satisfaction note along with enclosures if any to complete our submissions. 4.2 The ld.counsel stated that exactly on identical facts, Hon’ble High Court of Madras in the case of B.Kubendran vs. DCIT [2021] 126 taxma…

Shree Basaveshwar Sugars Limited, Vijayapura vs. ACIT, Centrl Circle, Trichirapalli

In the result, the appeals filed by the assessee in ITA

ITA 1009/CHNY/2022[2016-17]Status: DisposedITAT Chennai18 Jan 2023AY 2016-17
For Appellant: Shri G. Baskar, Shri I. Dinesh &For Respondent: Shri R. Mohan Reddy, CIT
Section 132Section 132(4)Section 142(1)Section 144Section 153C

…ommissioner (Appeals) may kindly call for the records of the AO. In the absence of any satisfaction note the assessment is liable to be quashed as ab initio void. We place reliance on the decision of the Supreme Court in the case of CIT vs. Calcutta Knitwears 362 ITR 673 and in the light of the CBDT Circular No.24/2015 dated 31-12-2015. If there is one, the AO may be directed to furnish a copy of the satisfaction note along with enclosures if any to complete our submissions. 4.2 The ld.counsel stated that exactly on identical facts, Hon’ble High Court of Madras in the case of B.Kubendran vs. DCIT [2021] 126 taxma…

Shree Basaveshwar Sugars Limited, Vijayapura vs. ACIT, Centrl Circle, Trichirapalli

In the result, the appeals filed by the assessee in ITA

ITA 1008/CHNY/2022[2015-16]Status: DisposedITAT Chennai18 Jan 2023AY 2015-16
For Appellant: Shri G. Baskar, Shri I. Dinesh &For Respondent: Shri R. Mohan Reddy, CIT
Section 132Section 132(4)Section 142(1)Section 144Section 153C

…ommissioner (Appeals) may kindly call for the records of the AO. In the absence of any satisfaction note the assessment is liable to be quashed as ab initio void. We place reliance on the decision of the Supreme Court in the case of CIT vs. Calcutta Knitwears 362 ITR 673 and in the light of the CBDT Circular No.24/2015 dated 31-12-2015. If there is one, the AO may be directed to furnish a copy of the satisfaction note along with enclosures if any to complete our submissions. 4.2 The ld.counsel stated that exactly on identical facts, Hon’ble High Court of Madras in the case of B.Kubendran vs. DCIT [2021] 126 taxma…

Shree Basaveshwar Sugars Limited, Vijayapura vs. ACIT, Centrl Circle, Trichirapalli

In the result, the appeals filed by the assessee in ITA

ITA 1007/CHNY/2022[2014-15]Status: DisposedITAT Chennai18 Jan 2023AY 2014-15
For Appellant: Shri G. Baskar, Shri I. Dinesh &For Respondent: Shri R. Mohan Reddy, CIT
Section 132Section 132(4)Section 142(1)Section 144Section 153C

…ommissioner (Appeals) may kindly call for the records of the AO. In the absence of any satisfaction note the assessment is liable to be quashed as ab initio void. We place reliance on the decision of the Supreme Court in the case of CIT vs. Calcutta Knitwears 362 ITR 673 and in the light of the CBDT Circular No.24/2015 dated 31-12-2015. If there is one, the AO may be directed to furnish a copy of the satisfaction note along with enclosures if any to complete our submissions. 4.2 The ld.counsel stated that exactly on identical facts, Hon’ble High Court of Madras in the case of B.Kubendran vs. DCIT [2021] 126 taxma…

Shree Basaveshwar Sugars Limited, Vijayapura vs. ACIT, Centrl Circle, Trichirapalli

In the result, the appeals filed by the assessee in ITA

ITA 1006/CHNY/2022[2012-13]Status: DisposedITAT Chennai18 Jan 2023AY 2012-13
For Appellant: Shri G. Baskar, Shri I. Dinesh &For Respondent: Shri R. Mohan Reddy, CIT
Section 132Section 132(4)Section 142(1)Section 144Section 153C

…ommissioner (Appeals) may kindly call for the records of the AO. In the absence of any satisfaction note the assessment is liable to be quashed as ab initio void. We place reliance on the decision of the Supreme Court in the case of CIT vs. Calcutta Knitwears 362 ITR 673 and in the light of the CBDT Circular No.24/2015 dated 31-12-2015. If there is one, the AO may be directed to furnish a copy of the satisfaction note along with enclosures if any to complete our submissions. 4.2 The ld.counsel stated that exactly on identical facts, Hon’ble High Court of Madras in the case of B.Kubendran vs. DCIT [2021] 126 taxma…

Shree Basaveshwar Sugars Limited, Vijayapura vs. ACIT, Centrl Circle, Trichirapalli

In the result, the appeals filed by the assessee in ITA

ITA 1005/CHNY/2022[2012-13]Status: DisposedITAT Chennai18 Jan 2023AY 2012-13
For Appellant: Shri G. Baskar, Shri I. Dinesh &For Respondent: Shri R. Mohan Reddy, CIT
Section 132Section 132(4)Section 142(1)Section 144Section 153C

…ommissioner (Appeals) may kindly call for the records of the AO. In the absence of any satisfaction note the assessment is liable to be quashed as ab initio void. We place reliance on the decision of the Supreme Court in the case of CIT vs. Calcutta Knitwears 362 ITR 673 and in the light of the CBDT Circular No.24/2015 dated 31-12-2015. If there is one, the AO may be directed to furnish a copy of the satisfaction note along with enclosures if any to complete our submissions. 4.2 The ld.counsel stated that exactly on identical facts, Hon’ble High Court of Madras in the case of B.Kubendran vs. DCIT [2021] 126 taxma…

DCIT CC, -7(2), Mumbai vs. M/S. Glamour Health Care Pvt. Ltd, Mumbai

In the result, appeal filed by the Revenueis dismissed

ITA 2252/MUM/2021[2014-15]Status: DisposedITAT Mumbai19 Dec 2022AY 2014-15

Bench: Shri Kuldip Singh & Shri Gagan Goyaldy.Cit, Cc-7(2), Room No. 655, Aayakar Bhavan, M.K. Road, Mumbai-400020. ...... Appellant Vs. M/S Glamour Health Care Pvt. Ltd. 4 Kiran Villa, 34, Ram Mandir Road, Danda, Khar (West), Mumbai-400052. Pan: Aaacn2617F ..... Respondent Appellant/Revenue By : Sh. Rakesh Garg, Cit-Dr Respondent/Assessee By : Sh. Rajiv Khandelwal, Ar Date Of Hearing : 22/09/2022 Date Of Pronouncement : 19/12/2022 Order Per Gagan Goyal, A.M: This Appeal By Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-49, Mumbai [For Short ‘Ld. Cit(A)’] Passed Under Section 250 Of The Income Tax Act, 1961 [For Short ‘The Act’] Vide Order Dated 24.08.2021 For Assessment Year (Ay) 2014-15. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Sh. Rajiv Khandelwal, ARFor Respondent: Sh. Rakesh Garg, CIT-DR
Section 132Section 132(4)Section 143(2)Section 143(3)Section 153CSection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER Dy.CIT, CC-7(2), Room No. 655, Aayakar Bhavan, M.K. Road, Mumbai-400020. ...... Appellant Vs. M/s Glamour Health Care Pvt. Ltd. 4 Kiran Villa, 34, Ram Mandir Road, Danda, Khar (West), Mumbai-400052. PAN: AAACN2617F ..... Respondent Appellant/Revenue by : Sh. Rakesh Garg, CIT-DR Respondent/Assessee by : Sh. Rajiv Khandelwal, AR Date of hearing : 22/09/2022 Date of pronouncement : 19/12/2022 ORDER PER GAGAN GOYAL, A.M: This appeal by Revenue is directed against the orde…

ACIT, New Delhi vs. M/S. Nagar Dairy Pvt. Ltd., New Delhi

In the result, C.O. Nos. 26, 27 & 28/Del/2016 filed by the assessee are allowed, accordingly the Assessment Orders dated 28

ITA 5473/DEL/2015[2009-10]Status: DisposedITAT Delhi23 Nov 2022AY 2009-10

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 153CSection 271(1)(c)Section 40A(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘A’ NEW DELHI BEFORE DR. B. R. R. KUMAR, ACCOUNTANT MEMBER AND SH. YOGESH KUMAR U.S., JUDICIAL MEMBER I.T.A. No. 5471/DEL/2015 (A.Y 2007-08) ACIT Vs Nagar Dairy Pvt. Ltd. Central Circle-15, Room No. D-3/10, Paschim Marg 353, E-2, ARA Centre, Vasant Vihar, Jhandewalan Extension, New Delhi New Delhi AABCN7304C (APPELLANT) (RESPONDENT) I.T.A. No. 5472/DEL/2015 (A.Y 2008-09) ACIT Vs Nagar Dairy Pvt. Ltd. Central Circle-15, Room No. D-3/10, Paschim Marg 353, E-2, ARA Centre, Vasant Vihar, Jhandewalan Extension, New Delhi New Delhi AABCN7304C (APPELLANT) (RESPO…

ACIT, New Delhi vs. M/S. Nagar Dairy Pvt. Ltd., New Delhi

In the result, C.O. Nos. 26, 27 & 28/Del/2016 filed by the assessee are allowed, accordingly the Assessment Orders dated 28

ITA 5472/DEL/2015[2008-09]Status: DisposedITAT Delhi23 Nov 2022AY 2008-09

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 153CSection 271(1)(c)Section 40A(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘A’ NEW DELHI BEFORE DR. B. R. R. KUMAR, ACCOUNTANT MEMBER AND SH. YOGESH KUMAR U.S., JUDICIAL MEMBER I.T.A. No. 5471/DEL/2015 (A.Y 2007-08) ACIT Vs Nagar Dairy Pvt. Ltd. Central Circle-15, Room No. D-3/10, Paschim Marg 353, E-2, ARA Centre, Vasant Vihar, Jhandewalan Extension, New Delhi New Delhi AABCN7304C (APPELLANT) (RESPONDENT) I.T.A. No. 5472/DEL/2015 (A.Y 2008-09) ACIT Vs Nagar Dairy Pvt. Ltd. Central Circle-15, Room No. D-3/10, Paschim Marg 353, E-2, ARA Centre, Vasant Vihar, Jhandewalan Extension, New Delhi New Delhi AABCN7304C (APPELLANT) (RESPO…

ACIT, New Delhi vs. M/S. Nagar Dairy Pvt. Ltd., New Delhi

In the result, C.O. Nos. 26, 27 & 28/Del/2016 filed by the assessee are allowed, accordingly the Assessment Orders dated 28

ITA 5471/DEL/2015[2007-08]Status: DisposedITAT Delhi23 Nov 2022AY 2007-08

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 153CSection 271(1)(c)Section 40A(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘A’ NEW DELHI BEFORE DR. B. R. R. KUMAR, ACCOUNTANT MEMBER AND SH. YOGESH KUMAR U.S., JUDICIAL MEMBER I.T.A. No. 5471/DEL/2015 (A.Y 2007-08) ACIT Vs Nagar Dairy Pvt. Ltd. Central Circle-15, Room No. D-3/10, Paschim Marg 353, E-2, ARA Centre, Vasant Vihar, Jhandewalan Extension, New Delhi New Delhi AABCN7304C (APPELLANT) (RESPONDENT) I.T.A. No. 5472/DEL/2015 (A.Y 2008-09) ACIT Vs Nagar Dairy Pvt. Ltd. Central Circle-15, Room No. D-3/10, Paschim Marg 353, E-2, ARA Centre, Vasant Vihar, Jhandewalan Extension, New Delhi New Delhi AABCN7304C (APPELLANT) (RESPO…

Arun Agarwal, Jaipur vs. ACIT, C.C. 3, Jaipur

In the result, the above appeals of the assessee are allowed

ITA 344/JPR/2022[2009-10]Status: DisposedITAT Jaipur22 Nov 2022AY 2009-10
For Appellant: Shri Mukesh Khandelwal, CAFor Respondent: Shri Shailendra Sharma, CIT-DR
Section 153ASection 153CSection 69C

…ing of ARUN AGARWAL VS ACIT, CC-3, JAIPUR satisfaction is illegal and proceedings undertaken based on such illegal notice requires to be quashed. During the course of hearing, the ld. AR relied on following case laws. 1. CIT vs Calcutta Knitwears, Ludhiana, 362 ITR 673 (SC) 2.Super Malls Pvt. Ltd. vs PCIT, 423 ITR 281 (SC) 3. Manish Maheshwari vs ACIT, 289 ITR 341 (SC) 4.ACIT vs Rangoli Buildcon (P) Ltd. (ITA 5015/Del/2014) 5. K.M. Sharma vs ITO , 254 ITR 772 (SC) He further submitted that in all the above four cases, the Hon’ble Courts have given verdict about mandatory condition of recording satisfaction pri…

M/S. Silicon Estates, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 23/BANG/2021[2011-12]Status: DisposedITAT Bangalore14 Nov 2022AY 2011-12

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR
Section 132Section 153CSection 80I

…on recorded by the Assessing Officer (in case of the assessee) before issuing notice under section 153C is enclosed from pages 205 to 210 of the paper book filed by the assessee. 9.3 The Hon’ble Apex Court in the case of Calcutta Knitwears reported in (2014) 362 ITR 673 (SC) had laid down that for the purpose of section 153BD of the I.T.Act, recording of a satisfaction note is a prerequisite and the satisfaction note must be prepared by the Assessing Officer before he transmits the record to the other A.O. who has jurisdiction over such other person u/s 155BD of the I.T.Act. The Hon’ble Apex Court held that sati…

M/S. Silicon Estates, Bengaluru vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 22/BANG/2021[2010-11]Status: DisposedITAT Bangalore14 Nov 2022AY 2010-11

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR
Section 132Section 153CSection 80I

…on recorded by the Assessing Officer (in case of the assessee) before issuing notice under section 153C is enclosed from pages 205 to 210 of the paper book filed by the assessee. 9.3 The Hon’ble Apex Court in the case of Calcutta Knitwears reported in (2014) 362 ITR 673 (SC) had laid down that for the purpose of section 153BD of the I.T.Act, recording of a satisfaction note is a prerequisite and the satisfaction note must be prepared by the Assessing Officer before he transmits the record to the other A.O. who has jurisdiction over such other person u/s 155BD of the I.T.Act. The Hon’ble Apex Court held that sati…

M/S. Silicon Estates, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 21/BANG/2021[2009-10]Status: DisposedITAT Bangalore14 Nov 2022AY 2009-10

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR
Section 132Section 153CSection 80I

…on recorded by the Assessing Officer (in case of the assessee) before issuing notice under section 153C is enclosed from pages 205 to 210 of the paper book filed by the assessee. 9.3 The Hon’ble Apex Court in the case of Calcutta Knitwears reported in (2014) 362 ITR 673 (SC) had laid down that for the purpose of section 153BD of the I.T.Act, recording of a satisfaction note is a prerequisite and the satisfaction note must be prepared by the Assessing Officer before he transmits the record to the other A.O. who has jurisdiction over such other person u/s 155BD of the I.T.Act. The Hon’ble Apex Court held that sati…

M/S. Silicon Estates, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 20/BANG/2021[2008-09]Status: DisposedITAT Bangalore14 Nov 2022AY 2008-09

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR
Section 132Section 153CSection 80I

…on recorded by the Assessing Officer (in case of the assessee) before issuing notice under section 153C is enclosed from pages 205 to 210 of the paper book filed by the assessee. 9.3 The Hon’ble Apex Court in the case of Calcutta Knitwears reported in (2014) 362 ITR 673 (SC) had laid down that for the purpose of section 153BD of the I.T.Act, recording of a satisfaction note is a prerequisite and the satisfaction note must be prepared by the Assessing Officer before he transmits the record to the other A.O. who has jurisdiction over such other person u/s 155BD of the I.T.Act. The Hon’ble Apex Court held that sati…

M/S. Silicon Estates, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 19/BANG/2021[2007-08]Status: DisposedITAT Bangalore14 Nov 2022AY 2007-08

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR
Section 132Section 153CSection 80I

…on recorded by the Assessing Officer (in case of the assessee) before issuing notice under section 153C is enclosed from pages 205 to 210 of the paper book filed by the assessee. 9.3 The Hon’ble Apex Court in the case of Calcutta Knitwears reported in (2014) 362 ITR 673 (SC) had laid down that for the purpose of section 153BD of the I.T.Act, recording of a satisfaction note is a prerequisite and the satisfaction note must be prepared by the Assessing Officer before he transmits the record to the other A.O. who has jurisdiction over such other person u/s 155BD of the I.T.Act. The Hon’ble Apex Court held that sati…

M/S. Silicon Estates, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 18/BANG/2021[2006-07]Status: DisposedITAT Bangalore14 Nov 2022AY 2006-07

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT –DR
Section 132Section 153CSection 80I

…on recorded by the Assessing Officer (in case of the assessee) before issuing notice under section 153C is enclosed from pages 205 to 210 of the paper book filed by the assessee. 9.3 The Hon’ble Apex Court in the case of Calcutta Knitwears reported in (2014) 362 ITR 673 (SC) had laid down that for the purpose of section 153BD of the I.T.Act, recording of a satisfaction note is a prerequisite and the satisfaction note must be prepared by the Assessing Officer before he transmits the record to the other A.O. who has jurisdiction over such other person u/s 155BD of the I.T.Act. The Hon’ble Apex Court held that sati…

Lekshmi Traders vs. The Commissioner of Income Tax

ITA/2/2018HC Kerala02 Nov 2022

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

For Appellant: LEKSHMI TRADERSFor Respondent: THE COMMISSIONER OF INCOME TAX
Section 132Section 158B

…xure J Order, without considering the ratio of the decisions of the Hon'ble Supreme Court Manish Maheswari's Case, reported in (2007) 289 ITR 341 (SC), A.R Enterprises' Case, reported in (2013) 350 ITR 489 (SC), Calcutta Knitwears Case, reported in (2014) 362 ITR 673 (SC)? ii. Whether on the facts and circumstances of the case, the Appellate Tribunal was justified in holding that recording of satisfaction by the assessing officer is not contemplated u/s. 158BD, which forms the basis for passing Annexure J order? iii. Whether on the facts and circumstances of the case, the Appellate tribunal was justif…

Amrshi M. Nishar, Mumbai vs. DCIT OSD-II Cen RG 7, Mumbai

In the result, both the appeals are allowed

ITA 3263/MUM/2013[2008-09]Status: DisposedITAT Mumbai19 Sept 2022AY 2008-09
For Appellant: Shri Girish DaveFor Respondent: Shri Achal Sharma
Section 1Section 132(1)Section 133Section 133ASection 153CSection 69

…e submitted that the term „satisfaction‟ has not been defined in the Act. There is no specific manner regarding the recording of satisfaction or the time when it is to be recorded. The Hon'ble Supreme Court, in the case of CIT-III vs. Calcutta Knitwear [2014] 362 ITR 673 (SC), has treated Sections such as 158BC, 158BD, 153C, etc. as machinery provisions which are required to be interpreted literally so as to achieve the objectives for which they were brought into the statute. There is nothing in the Act that the satisfaction should be recorded in a particular manner. It would, therefore, be substantial compliance…

Sri. Karthik Krishna vs. Deputy Commissioner of Income Tax

ITA/95/2016HC Karnataka12 Sept 2022

Bench: P.S.DINESH KUMAR,UMESH M ADIGA

Section 153CSection 260Section 260A

…- 1 - IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 12TH DAY OF SEPTEMBER, 2022 PRESENT THE HON’BLE MR.JUSTICE P.S.DINESH KUMAR AND THE HON’BLE MR.JUSTICE UMESH M. ADIGA I.T.A No.447/2014 C/W I.T.A No.450/2014, I.T.A. No.95/2016 AND I.T.A. No.98/2016 IN I.T.A.No.447/2014: BETWEEN: SRI. KARTHIK KRISHNA PRESENTLY RESIDING AT 170/A, TARAKA, 10TH MAIN R.M.V. EXTENSION SADASHIVNAGAR BANGALORE-560 080. ... APPELLANT [BY SHRI. S.PARTHASARATHI, ADVOCATE FOR SHRI. BALRAM R. RAO, ADVOCATE ]…