Karanvir Singh Gossal v. CIT

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

…all the benefits and exemptions available as per the statute, on the facts and circumstances of the case. 5. Without prejudice, to the right to seek waiver as per the parity of reasoning of the decision of the Hon’ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies himself liable to be changed to interest under section 234A, 234B & 234C of the Income Tax Act on the facts and circumstances of the case. The Appellant contends that the levy of interest under section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learne…

NANDINI CREDIT CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. INCOME TAX OFFICER, WARD-4(2)(3), BANGALORE

Appeal of the Assessee is allowed

Bench: Shri Prashant Maharishi, Vice –Assessment Year : 2020-21

…of natural justice and thus the additions confirmed needs to be deleted on the facts of the case. 8. Interest: Without prejudice to the right to seek waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies herself liable to be charged to interest under section 234 B of the Income Tax Act on the facts and circumstances of the case. Further the levy of interestunder section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible from t…

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

In the result, this portion of appeal is partly allowed for statistical purposes

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

…nst the canons of taxation and against the canons of taxation, on the facts and circumstances of the case. 11. Without prejudice to the right to seek waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learne…

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

In the result, this portion of appeal is partly allowed for statistical purposes

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

…nst the canons of taxation and against the canons of taxation, on the facts and circumstances of the case. 11. Without prejudice to the right to seek waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learne…

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

In the result, this portion of appeal is partly allowed for statistical purposes

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

…nst the canons of taxation and against the canons of taxation, on the facts and circumstances of the case. 11. Without prejudice to the right to seek waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learne…

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

In the result, this portion of appeal is partly allowed for statistical purposes

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

…nst the canons of taxation and against the canons of taxation, on the facts and circumstances of the case. 11. Without prejudice to the right to seek waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234A, 234B & 234C of the Income Tax Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learne…

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

…pted and assessed correct and proper income of the appellant, on the facts and circumstances of the case. 8. Without prejudice, to the right to seek waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies itself liable to be charged to interest under section 234 A, 234 B and 234 C of the Income Tax Act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234 A, 234 B and 234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by t…

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

…of a permanent character and hence is a revenue expenditure, on the facts and circumstances of the case. 10. Without prejudice, to the right to seek waiver as per the parity of reasoning of the decision of the Hon’ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies himself liable to be charged to interest under section 234 B, 244 A & 234 D of the Income Tax Act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation ITA Nos.619 to 622/Bang/2025…

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

…of a permanent character and hence is a revenue expenditure, on the facts and circumstances of the case. 10. Without prejudice, to the right to seek waiver as per the parity of reasoning of the decision of the Hon’ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies himself liable to be charged to interest under section 234 B, 244 A & 234 D of the Income Tax Act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation ITA Nos.619 to 622/Bang/2025…

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

…of a permanent character and hence is a revenue expenditure, on the facts and circumstances of the case. 10. Without prejudice, to the right to seek waiver as per the parity of reasoning of the decision of the Hon’ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies himself liable to be charged to interest under section 234 B, 244 A & 234 D of the Income Tax Act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation ITA Nos.619 to 622/Bang/2025…

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

…of a permanent character and hence is a revenue expenditure, on the facts and circumstances of the case. 10. Without prejudice, to the right to seek waiver as per the parity of reasoning of the decision of the Hon’ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies himself liable to be charged to interest under section 234 B, 244 A & 234 D of the Income Tax Act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation ITA Nos.619 to 622/Bang/2025…

RANGAPPA BYRAPPA,BANGALORE vs. INCOME TAX OFFICER WARD-3(3)(1), BANGALORE

In the result the appeal of the assessee is allowed for statistical purposes

Bench: Shri Prashant Maharishiassessment Year : 2017-18

…f natural justice and thus the additions confirmed needs to be deleted on the facts of the case. 14. Interest: Without prejudice to the right to seek waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanvir Singh 349 ITR 692, the Appellant denies herself liable to be charged to interest under section 234 B of the Income Tax Act on the facts and circumstances of the case. Further the levy of interest under section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation Page 4 of 8 adopted on which interest is levied are all not disc…

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

…nt which is against the principles of natural justice and consequently the addition requires to be deleted. xi. Without prejudice, to write to seek waiver as per the parity of reasoning of the decision of the honourable Supreme Court in case of coronary Singh 349 ITR 692, the appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the income tax act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B and 234C of the act is also bad in law as the period, rate, quantum, and method of calculation adopted by the l…

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3) , BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

…nt which is against the principles of natural justice and consequently the addition requires to be deleted. xi. Without prejudice, to write to seek waiver as per the parity of reasoning of the decision of the honourable Supreme Court in case of coronary Singh 349 ITR 692, the appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the income tax act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B and 234C of the act is also bad in law as the period, rate, quantum, and method of calculation adopted by the l…

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3) , BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

…nt which is against the principles of natural justice and consequently the addition requires to be deleted. xi. Without prejudice, to write to seek waiver as per the parity of reasoning of the decision of the honourable Supreme Court in case of coronary Singh 349 ITR 692, the appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the income tax act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B and 234C of the act is also bad in law as the period, rate, quantum, and method of calculation adopted by the l…

DCIT, CENTRAL CIRCLE-1(3), BENGALURU vs. LATE SHRI MAHABIR PRASAD (LEGAL HEIR MS. PARUL KANSARIA), BENGALURU

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

…ch is against the\nprinciples of natural justice and consequently the addition\nrequires to be deleted.\nxi.\nWithout prejudice, to write to seek waiver as per the parity\nof reasoning of the decision of the honourable Supreme\nCourt in case of coronary Singh 349 ITR 692, the appellant\ndenies himself liable to be charged to interest under\nsection 234A, 234B and 234C of the income tax act on the\nfacts and circumstances of the case. The appellant\ncontends that the levy of interest under section 234A,\n234B and 234C of the act is also bad in law as the period,\nrate, quantum, and method of calculation adopted by…

DCIT, CENTRAL CIRCLE-1(3), BAENGALURU vs. LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

…nt which is against the principles of natural justice and consequently the addition requires to be deleted. xi. Without prejudice, to write to seek waiver as per the parity of reasoning of the decision of the honourable Supreme Court in case of coronary Singh 349 ITR 692, the appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the income tax act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B and 234C of the act is also bad in law as the period, rate, quantum, and method of calculation adopted by the l…

B M VENKATARAMAN GOWDA L/H OF LATE B M CHANDREGOWDA,KOLAR vs. DCIT, CENTRAL CIRCLE-1, BANGALORE

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

…t on 18.09.2020, on the facts and circumstances of the case. The rule of consistency needs to be followed. 9. Without prejudice to the right to seen waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanavir Singh 349 ITR 692, the Appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned assess…

B M VENKATARAMAN GOWDA L/H OF LATE B M CHANDREGOWDA,KOLAR vs. DCIT, CENTRAL CIRCLE-1, BANGALORE

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

…t on 18.09.2020, on the facts and circumstances of the case. The rule of consistency needs to be followed. 9. Without prejudice to the right to seen waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanavir Singh 349 ITR 692, the Appellant denies himself liable to be charged to interest under section 234A, 234B and 234C of the Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned assess…

B M VENKATARAMAN GOWDA L/H OF LATE B M CHANDREGOWDA,KOLAR vs. DCIT, CENTRAL CIRCLE-1, , BANGALORE

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

…t on 18.09.2020, on the facts and circumstances of the case. The rule of consistency needs to be followed. 9. Without prejudice to the right to seen waiver as per the parity of reasoning of the decision of the Hon'ble Apex Court in the case of Karanavir Singh 349 ITR 692, the Appellant denies himself liable to be charged to interest under Section 234A, 234B and 234C of the Act, on the facts and circumstances of the case. The appellant contends that the levy of interest under Section 234A, 234B & 234C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned assess…