CIT v. Sahara India

KOCH BUSINESS SOLUTIONS INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(3)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

…g/2024 & SA No.35/Bang/2025 Koch Business Solutions India Pvt. Ltd., Bengaluru Page 7 of 50 3.1 We have heard both the parties on admission of additional ground. The Lucknow bench of the Hon’ble Allahabad High Court in the case of CIT Vs. Sahara India (2012) 347 ITR 331 held that a legal issue can be raised at any stage but there shall be good reason for admitting the additional ground. In our Opinion all the facts are already on record and there is no necessity of investigation of any fresh facts for the purpose of the adjudication of above ground. IT(TP)A No.1844/Bang/2024 & SA No.35/Bang/2025 Koch Business S…

TUNGABHADRA PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA,SINDHANUR vs. INCOME TAX OFFICER, WARD -1, RAICHUR

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

…g/2024 & SA No.35/Bang/2025 Koch Business Solutions India Pvt. Ltd., Bengaluru Page 7 of 50 3.1 We have heard both the parties on admission of additional ground. The Lucknow bench of the Hon’ble Allahabad High Court in the case of CIT Vs. Sahara India (2012) 347 ITR 331 held that a legal issue can be raised at any stage but there shall be good reason for admitting the additional ground. In our Opinion all the facts are already on record and there is no necessity of investigation of any fresh facts for the purpose of the adjudication of above ground. IT(TP)A No.1844/Bang/2024 & SA No.35/Bang/2025 Koch Business S…

MRS. SUREKHA LEGAL REPRESENTATIVE OF LATE SHRI. DEVARAJ,BENGALURU vs. INCOME TAX OFFICER, WARD-7(2)(5), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19 Mrs. Surekha (Legal Representative Of Late Shri Devaraj, Since Dead) No.112, 1St Main, Ramarao Layout Vs. Ito Bsk 3Rd Phase, 3Rd Stage Ward 7(2)(5) Bengaluru 560 085 Bengaluru Pan No :Asvps2939R Appellant Respondent Appellant By : Sri Balachandran, A.R. Respondent By : Sri N. Balusamy, D.R. Date Of Hearing : 17.02.2026 Date Of Pronouncement : 06.03.2026

…4 of 19 Mrs. Surekha (Legal Rep. of Late Shri Devaraj, since dead), Bengaluru Page 5 of 19 3.1 We have heard both the parties on admission of additional grounds. The Lucknow bench of the Hon’ble Allahabad High Court in the case of CIT Vs. Sahara India (2012) 347 ITR 331 held that a legal issue can be raised at any stage but there shall be good reason for admitting the additional ground.In our Opinion all the facts are already on record and there is no necessity of investigation of any fresh facts for the purpose of the adjudication of above grounds. Further we are also of the opinion that the additional grounds…

SAIKAT CHINMAY BHATTACHARYA,MUMBAI vs. DY. CIT, INTERNATIONAL TAXATION, CIRCLE 1(1), BANGALORE

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.582/Bang/2025

…efore or at the time of hearing of the appeal, as he may be advised from time to time. 3.1 We have heard the rival submissions on admission of additional grounds. The Lucknow bench of the Hon'ble Allahabad High Court in the case of CIT Vs. Sahara India (2012) 347 ITR 331 held that a legal issue can be raised at any stage but there shall be good reason for admitting the additional ground. In our considered opinion all the facts are already on record and there is no necessity of investigation of any fresh facts for the purpose of the adjudication of above ground. Further we are also of the opinion that the addition…

NEETA BHAMBHANI,BENGALURU vs. DCIT, (IT), CIRCLE-1(1), BENGALURU

In the result, I pass the following:-

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

…y be allowed and appropriate relief be granted in the interest of justice and equity. 3.1 We have heard the rival submissions on admission of additional grounds. The Lucknow bench of the Hon’ble Allahabad High Court in the case of CIT Vs. Sahara India (2012) 347 ITR 331 held that a legal issue can be raised at any stage but there shall be good reason for admitting the additional ground. In our considered Opinion all the facts are already on record and there is no necessity of investigation of any fresh facts for the purpose of the adjudication of above grounds. Further we are also of the opinion that the additio…

RAHUL MEKA ,BENGALURU vs. INCOME TAX OFFICER, WARD INTERNATIONAL TAXATION-1(2) , BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

…may be allowed and appropriate relief may be granted in the interest of justice and equity. 4. We have heard both the parties on admission of additional grounds. The Lucknow bench of the Hon’ble Allahabad High Court in the case of CIT Vs. Sahara India (2012) 347 ITR 331 held that a legal issue can be raised at any stage but there shall be good reason for admitting the additional ground.In our Opinion all the facts are already on record and there is no necessity of investigation of any fresh facts for the purpose of the adjudication of above grounds. Further we are also of the opinion that the additional grounds…

M/S. EDUCATIONAL CONCEPTS INNOVATORS INTERNATIONAL ,BENGALURU vs. INCOME TAX OFFICER, WARD-1(2)(1), BENGALURU

Accordingly all these additional grounds are dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

…on of law which did not arise before the lower authorities but arise before it from facts as found by lower authorities and having a bearing on tax liability of the assessee. Further, the Hon'ble Allahabad High Court in the case of CIT Vs. Sahara India (2012) 347 ITR 331 held that a question of law which can be decided with reference to material on record can be admitted even though not raised before. Accordingly, we inclined to admit the additional grounds for the purpose of adjudication as there is no investigation of any fresh facts otherwise on record and the grounds raised are purely legal in nature. 5. Now…

SHRI. ANANTULA VIJAY MOHAN ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

…ITA No.2059 & 2060/Bang/2024 & SP 67/Bang/2024 Anantula Vijay Mohan, Hyderabad IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH: BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.2059 & 2060/Bang/2024 Assessment Years: 2016-17 & 2017-18 Anantula Vijay Mohan 9, Banjara Avenue Road No.1, Banjara Hills Hyderabad 500 034 PAN NO: AELPM6515K APPELLANT Vs. Vs. DCIT Circle-6(1)(1) Bangalore RESPONDENT SP No.67/Bang/2024 (Arising out of ITA No.2060/Bang/2024) Assessment Year: 2017-18 Anantula Vijay Mohan 9, Banjara Avenue Road No.1, Banjara Hills Hyderabad 500 034 PA…

ANANTULA VIJAY MOHAN ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

…ITA No.2059 & 2060/Bang/2024 & SP 67/Bang/2024 Anantula Vijay Mohan, Hyderabad IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH: BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.2059 & 2060/Bang/2024 Assessment Years : 2016-17 & 2017-18 Anantula Vijay Mohan 9, Banjara Avenue Road No.1, Banjara Hills Hyderabad 500 034 PAN NO:AELPM6515K APPELLANT Vs. DCIT Circle-6(1)(1) Bangalore RESPONDENT SP No.67/Bang/2024 (Arising out of ITA No.2060/Bang/2024) Assessment Year: 2017-18 Anantula Vijay Mohan 9, Banjara Avenue Road No.1, Banjara Hills Hyderabad 500 034 PAN NO…