Karanvir Singh Gossal v. CIT

349 ITR 692Supreme Court of India2012#619 most cited

What is Karanvir Singh Gossal v. CIT authority for?

The Supreme Court's decision establishes principles or grounds for seeking a waiver of mandatory interest levied under Sections 234A, 234B, and 234C of the Income Tax Act, 1961.

158

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2026.

Also referred to as

Karanvir Singh Gossal · interest waiver · section 234A · section 234B · section 234C · waiver of interest · mandatory interest · Income Tax Act · Supreme Court

Sections most often in play

Section 234BSection 234ASection 234CSection 143(3)Section 250Section 144Section 143(2)Section 153A

Issues it is cited on

interest under section 234amistake apparent on recordsection 234section 23section 234asection 154interest u/s 234achildsection 153dsatisfaction notesection 15section 153c

Judgments citing Karanvir Singh Gossal v. CIT

National Education Foundation, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

In the result, the appeals filed by the assessee are partly allowed

ITA 733/BANG/2021[2017-18]Status: DisposedITAT Bangalore08 Feb 2022AY 2017-18

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri.V.Chandrashekhar, AdvocateFor Respondent: Dr.Manjunath Karkihalli, CIT-DR
Section 153CSection 154Section 234Section 234ASection 250

…ces of the case. 8. Without prejudice the learned Commissioner of Income- tax [Appeals] failed to appreciate that the appellant has 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 & 234 C of the Income Tax Act on the facts and circumstances of the case. 9. The learned Commissioner of Income-tax [Appeals] failed to appreciate that the levy of interest under section 234 A, 234 B & 234 C of the Act are also bad in law as the period, 4 IT…

National Education Foundation, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

In the result, the appeals filed by the assessee are partly allowed

ITA 732/BANG/2021[2016-17]Status: DisposedITAT Bangalore08 Feb 2022AY 2016-17

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri.V.Chandrashekhar, AdvocateFor Respondent: Dr.Manjunath Karkihalli, CIT-DR
Section 153CSection 154Section 234Section 234ASection 250

…ces of the case. 8. Without prejudice the learned Commissioner of Income- tax [Appeals] failed to appreciate that the appellant has 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 & 234 C of the Income Tax Act on the facts and circumstances of the case. 9. The learned Commissioner of Income-tax [Appeals] failed to appreciate that the levy of interest under section 234 A, 234 B & 234 C of the Act are also bad in law as the period, 4 IT…

National Education Foundation, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

In the result, the appeals filed by the assessee are partly allowed

ITA 731/BANG/2021[2015-16]Status: DisposedITAT Bangalore08 Feb 2022AY 2015-16

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri.V.Chandrashekhar, AdvocateFor Respondent: Dr.Manjunath Karkihalli, CIT-DR
Section 153CSection 154Section 234Section 234ASection 250

…ces of the case. 8. Without prejudice the learned Commissioner of Income- tax [Appeals] failed to appreciate that the appellant has 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 & 234 C of the Income Tax Act on the facts and circumstances of the case. 9. The learned Commissioner of Income-tax [Appeals] failed to appreciate that the levy of interest under section 234 A, 234 B & 234 C of the Act are also bad in law as the period, 4 IT…

National Education Foundation, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

In the result, the appeals filed by the assessee are partly allowed

ITA 730/BANG/2021[2014-15]Status: DisposedITAT Bangalore08 Feb 2022AY 2014-15

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri.V.Chandrashekhar, AdvocateFor Respondent: Dr.Manjunath Karkihalli, CIT-DR
Section 153CSection 154Section 234Section 234ASection 250

…ces of the case. 8. Without prejudice the learned Commissioner of Income- tax [Appeals] failed to appreciate that the appellant has 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 & 234 C of the Income Tax Act on the facts and circumstances of the case. 9. The learned Commissioner of Income-tax [Appeals] failed to appreciate that the levy of interest under section 234 A, 234 B & 234 C of the Act are also bad in law as the period, 4 IT…

National Education Foundation, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

In the result, the appeals filed by the assessee are partly allowed

ITA 729/BANG/2021[2013-14]Status: DisposedITAT Bangalore08 Feb 2022AY 2013-14

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri.V.Chandrashekhar, AdvocateFor Respondent: Dr.Manjunath Karkihalli, CIT-DR
Section 153CSection 154Section 234Section 234ASection 250

…ces of the case. 8. Without prejudice the learned Commissioner of Income- tax [Appeals] failed to appreciate that the appellant has 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 & 234 C of the Income Tax Act on the facts and circumstances of the case. 9. The learned Commissioner of Income-tax [Appeals] failed to appreciate that the levy of interest under section 234 A, 234 B & 234 C of the Act are also bad in law as the period, 4 IT…

National Education Foundation, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

In the result, the appeals filed by the assessee are partly allowed

ITA 728/BANG/2021[2012-13]Status: DisposedITAT Bangalore08 Feb 2022AY 2012-13

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri.V.Chandrashekhar, AdvocateFor Respondent: Dr.Manjunath Karkihalli, CIT-DR
Section 153CSection 154Section 234Section 234ASection 250

…ces of the case. 8. Without prejudice the learned Commissioner of Income- tax [Appeals] failed to appreciate that the appellant has 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 & 234 C of the Income Tax Act on the facts and circumstances of the case. 9. The learned Commissioner of Income-tax [Appeals] failed to appreciate that the levy of interest under section 234 A, 234 B & 234 C of the Act are also bad in law as the period, 4 IT…

M/S. Sri Kumarswamy Minerals Exports Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-6(1)(2), Bangalore

In the result, the appeal filed by the assessee stands allowed for statistical purposes

ITA 686/BANG/2021[2014-15]Status: DisposedITAT Bangalore02 Feb 2022AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2014-15 M/S. Sri Kumaraswamy The Deputy Minerals Exports Pvt. Ltd., Commissioner Of No. 58, Cunningham Road Income Tax, Cross, Circle – 6[1][2], Bangalore – 560 052. Bangalore. Vs. Pan: Aaqcs4798A Appellant Respondent : Shri V. Chandrashekar, Assessee By Advocate : Shri Sankarganesh K, Jcit Revenue By (Dr) Date Of Hearing : 02-02-2022 Date Of Pronouncement : 02-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Ex-Parte Order Dated 12.10.2021 Passed By The Ld.Cit(A)-11, Bangalore Relating To Assessment Year 2014-15 On Following Grounds Of Appeal: “1. The Order Of The Learned Commissioner Of Income-Tax [Appeals]-12, Bengaluru, Passed Under Section 250 Of The Act Dated 12/10/2021, In So Far As It Is Against The Appellant Is Opposed To Law, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Appellant'S Case. 2. The Appellant Denies Itself Liable To Be Taxed On A Total Income Of Rs. 103,97,62,214/- As Determined By The Learned Assessing Officer & Confirmed By The Learned

For Respondent: Shri V. Chandrashekar
Section 143Section 154Section 234Section 250

…appeal preferred by the appellant, which is in grave violation, on the facts and circumstances of the case. 9. 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 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 adopted on which interest is levied are all not discernible and ar…

M/S Kumaraswamy Mineral Export Pvt. Ltd., Bengaluru vs. Joint Commissioner of Income Tax Bellary Range, Bellary

In the result, the appeal of the assessee stands allowed

ITA 1654/BANG/2018[2011-12]Status: DisposedITAT Bangalore04 Jan 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2011-12 M/S. Kumaraswamy Mineral Exports Pvt. Ltd., [For & On Behalf Of The Joint Erstwhile Partnership Commissioner Of Firm M/S. Kumaraswamy Income Tax, Mineral Exports], Bellary Range, No. 58, Cunningham Vs. Bellary. Road Cross, Bangalore – 560 052. Pan: Aabfk8539K Appellant Respondent : Shri S.V. Ravishankar, Assessee By Advocate : Shri Sumer Singh Meena, Revenue By Cit Dr(Osd) Date Of Hearing : 21-12-2021 Date Of Pronouncement : 04-01-2022 Order Per Beena Pillaipresent Appeal Has Been Filed By Assessee Against The Order Dated 22/03/2018 Passed By Ld.Cit(A), Gulbarga For Assessment Year 2011-12 On Following Grounds Of Appeal: “1. The Order Passed By The Learned Commissioner Of Income-Tax [Appeals]-4, Bengaluru Dated 22/03/2018 & The Order Of Assessment Passed By The Learned Assessing Officer Under Section 143 [3] Of The Act Dated 28/03/2014, In So Far As It Is Against The Appellant, Is Opposed To The Law, Weight Of Evidence, Probabilities, Facts & Circumstances In The Appellant'S Case.

For Respondent: Shri S.V. Ravishankar
Section 143Section 14ASection 234Section 37

…ure is allowable as per the provisions of section 37 of the Act 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 Trust denies itself liable to be charged to interest under section 234 B Et 234 C of the Income Tax Act under the facts and circumstances of the case. Further the levy of interest under section 234 B a 234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are…

Smt. Arwa Hararwala, Bangalore vs. Income Tax Officer, Ward- 7(2)(2), Bangalore

In the result, the appeal filed by the assessee stands allowed on the legal issue raised

ITA 1/BANG/2020[2014-15]Status: DisposedITAT Bangalore20 Dec 2021AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2014-15

For Respondent: Shri Ravishankar S.V
Section 143(2)Section 143(3)

…course of remand proceedings, on the facts and circumstances of the case. 8. Grounds on levy of interest : a) 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 A and B of the Income Tax Act under the facts and circumstances of the case. b) The levy of Rs 76,26,201 under section 234 B is contrary to law and is only on account of unsustainable Page 5 of 13 addition made and requires to be deleted on the facts of the case. c)…

M/S. Fashion Matrix Clothing, Bengaluru vs. Income Tax Officer, Ward- 6(2)(1), Bangalore

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

ITA 550/BANG/2021[2018-19]Status: DisposedITAT Bangalore14 Dec 2021AY 2018-19

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2018-19

For Respondent: Shri Mahesh Kumar L
Section 143Section 143(1)Section 143(1)(a)Section 2(24)(x)Section 250Section 36Section 36(1)(va)Section 43B

…natural justice and thus the additions confirmed needs to be deleted on the facts of the case. 17. Interest: Without prejudice to the right to seek waiver as per the parity of reasoning of the decision of the Flon'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 adopted on which interest is levied arc all not discernible from…

M/S. Sumathi Nursing & Maternity Home, Bengaluru vs. Assistant Director of Income Tax, Centralized Processing Center, Bangalore

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

ITA 434/BANG/2021[2019-20]Status: DisposedITAT Bangalore10 Nov 2021AY 2019-20

Bench: Shri George George K

For Appellant: Sri.Pranav KrishnaFor Respondent: Sri.Ganesh R.Ghale, Standing Counsel
Section 139Section 139(1)Section 143Section 143(1)Section 234Section 234ASection 250Section 36Section 43B

…made by mere processing of the return u/s. 143[1] of the Act under the facts and circumstances of the case. 7. 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 B of the Income Tax Act under the facts and circumstances of the case. 8. 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 learned ass…

Janardhan Julakanti, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated hereinabove

ITA 1776/HYD/2019[2016-17]Status: DisposedITAT Hyderabad20 Sept 2021AY 2016-17

Bench: Shri A. Mohan Alankamony & Shri S.S. Godaraa.Y. 2016-17 Sri Janardhan Julakanti, Vs. Income Tax Officer, Hyderabad-500 056. Ward-15(1), Pan: Adnpj 2544 A Hyderabad. (Appellant) (Respondent) Assessee By: Santi Pawan For Pavan Kumar Chakrapani Revenue By: Sri P. Suresh, Dr Date Of Hearing: 16/09/2021 Date Of Pronouncement: 20/09/2021 Order Per A. Mohan Alankamony, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Cit(A)-7, Hyderabad In Appeal No. 0178/Cit(A)-7/2018-19, Dated 23/10/2019 Passed U/S. 144 R.W.S 250(6) Of The Act For The A.Y. 2016-17. 2. The Assessee Has Raised Sixteen Grounds In His Appeal & They Are Extracted Herein Below For Reference:-

For Appellant: Santi Pawan for Pavan KumarFor Respondent: Sri P. Suresh, DR
Section 144Section 2(47)Section 234ASection 234B

…,288 under section 234B of the Act, a sum of Rs. 4,35,072/- under the facts and circumstances of the case. 14. 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 and 234B of the Act under the circumstances of the case. 15. The appellant craves leave toa dd, alter delete or substantiate any of the grounds urged above. 16. In view of the above and other grounds that may be urged at the time of the hearing of the appeal, the app…

Sri.Venkataramanappa, Bangalore vs. The Income Tax Officer Ward-3(2)(3), Bangalore

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 304/BANG/2018[2009-10]Status: DisposedITAT Bangalore17 Sept 2021AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2009-10

For Appellant: Shri Ravi Shankar, AdvocateFor Respondent: Smt. H. Kabila, Addl.CIT(DR)(ITAT), Bengaluru
Section 148Section 151

…ns for the assessment year 2009-10 which is impermissible in law on the facts and circumstance of the case. 9. 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 Page 5 of 17 itself liable to be charged to interest under section 234 A & 234 B of the Income Tax Act under the facts and circumstances of the case. Further the levy of interest under section 234 A & 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levi…

Deputy Commissioner of Income Tax, Circle- 2(1)(1), Bangalore vs. M/S. Canadian International School Private Limited, Bangalore

In the result appeal filed by revenue stands dismissed

ITA 2535/BANG/2019[2016-17]Status: DisposedITAT Bangalore16 Jul 2021AY 2016-17

Bench: Shri. B.R Baskaran & Smt. Beena Pillaiita 2535/Bang/2019 Assessment Year : 2016-17

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Kannan Narayanan, JCIT(DR)
Section 143Section 68

…o charging of interest u/s.234B of the Act. As regards the ground on charging of interest u/s. 234B of the Income Tax Act 1961 is concerned, the Honble Supreme Court in cases of Anjum M.H. Ghaswala Vs CIT, 252 ITR1 and Karanvir Singh Gossal Vs CIT reported in 349 ITR 692 has held that since charging of interest under these sections is mandatory in nature and therefore by the ratio of the above cited decisions interests is an integral part of tax. Therefore, no adjudication is needed.” 3.1 Aggrieved by the order of the Ld.CIT(A) revenue is in appeal before us now. 4. The Ld.Sr.DR submitted that, the work was given…

DCIT vs. M/S Coastal Costruction

In the result, the revenue’s appeal is dismissed, while the CO by the assessee is partly allowed for statistical purposes

ITA 1005/BANG/2013[2006-07]Status: DisposedITAT Bangalore16 Mar 2021AY 2006-07

Bench: Shri Chandra Poojari & Shri George George Kdy. Commissioner Of Income Tax, Central Circle 2(3), Bangalore. …. Appellant.

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Muzaffar Hussain, CIT(D.R.)
Section 132Section 143Section 153ASection 153CSection 2Section 2(22)(e)Section 234

…ovisions of section 2[22][e] of the Act of Rs. 4,14,57,934/- under the facts and circumstances of the case. 6. 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 Respondent / Cross Objector denies itself liable to be charged to interest under section 234 A Ft 234 B of the Income Tax Act under the facts and circumstances of the case. Further the levy of interest under section 234 A & 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation adopted Page 4 of 12 on whi…

Smt. M.H. Mamatha, L/R of Late Sri. M.N. Harinath, Bangalore vs. Income Tax Officer, Ward- 3(2)(2), Bangalore

In the result, assessee’s appeal is allowed

ITA 16/BANG/2020[2008-09]Status: DisposedITAT Bangalore28 Aug 2020AY 2008-09

Bench: Shri A. K. Garodia & Smt. Beena Pillaiassessment Year : 2008-09 Smt. M. H. Mamatha Legal Heir Of Income Tax Officer, Late Shri. M. N. Harinath, Ward – 3[2][2], No.947, 37Th Cross, Poornaprajna Vs. Bengaluru. Layout, Uttarhalli, Bsk 5Th Stage, Bengaluru – 560 061. Pan : Aeipm 2644 G Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Priyadarshi Mishra, Jcit (Dr) Date Of Hearing : 26.08.2020 Date Of Pronouncement : .08.2020

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Priyadarshi Mishra, JCIT (DR)
Section 143Section 143(2)Section 147Section 148Section 2Section 234Section 250Section 50C

…gible to tax as per the provisions of section 2[14] of the Act, 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 Page 3 of 7 liable to be charged to interest under section 234 A and 234 C of the Income Tax Act on the facts and circumstances of the case. Further the levy of interest under section 234 A Et 234 C of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied…

M/S Vasoo Builders Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 1741/BANG/2018[2010-11]Status: DisposedITAT Bangalore25 Aug 2020AY 2010-11

Bench: Shri A. K. Garodia & Smt. Beena Pillai

For Appellant: Shri. Pranav Krishna, Shri. S. Ravishankar, AdvocatesFor Respondent: Smt. R. Premi, JCIT (DR)(ITAT), Bengaluru
Section 143Section 234Section 68

…in TDS credit amounting to Rs.6,15,985/- as unaccounted income, on the facts and circumstances of the case. 9. 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 B of the Income Tax Act under 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 adopted on which interest is levied are all not discernible and…

M/S Vasoo Builders Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 1742/BANG/2018[2011-12]Status: DisposedITAT Bangalore25 Aug 2020AY 2011-12

Bench: Shri A. K. Garodia & Smt. Beena Pillai

For Appellant: Shri. Pranav Krishna, Shri. S. Ravishankar, AdvocatesFor Respondent: Smt. R. Premi, JCIT (DR)(ITAT), Bengaluru
Section 143Section 234Section 68

…in TDS credit amounting to Rs.6,15,985/- as unaccounted income, on the facts and circumstances of the case. 9. 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 B of the Income Tax Act under 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 adopted on which interest is levied are all not discernible and…

M/S. Sri Guru Sai Constructions, Bangalore vs. Assistant Commissioner of Income Tax, Circle-6(3)(1), Bangalore

In the result, the appeal filed by the assessee is

ITA 3146/BANG/2018[2014-15]Status: DisposedITAT Bangalore21 Aug 2020AY 2014-15

Bench: Shri N.V. Vasudevan & Shri G. Manjunathaita Nos.3146/Bang/2018 Assessment Year: 2014-15

For Appellant: Shri V. Narendra Sharma, A.RFor Respondent: Shri Priyadarshi Mishra, D.R
Section 234

…ITA Nos.3146/Bang/2018 M/s. Sri Guru Sai Constructions, Bengaluru IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI G. MANJUNATHA, ACCOUNTANT MEMBER ITA Nos.3146/Bang/2018 Assessment Year: 2014-15 M/s. Sri Guru Sai Constructions No.21, Sri Sai Krupa 3rd Main Road M S R Nagar Vs. ACIT Circle 6(3)(1) Bengaluru-560 054. Bengaluru PAN NO : ABJFS 3888G APPELLANT RESPONDENT Appellant by : Shri V. Narendra Sharma, A.R. Respondent by : Shri Priyadarshi Mishra, D.R. Date of Hearing : 17.08.2020 Date of Pronouncement : 21.08.2020 O R D E R PER G. Manju…

Sri H S Ningaiah, Bangalore vs. Deputy Commissioner of Income Tax Central Circle-1(4), Bangalore

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

ITA 2365/BANG/2018[2010-11]Status: DisposedITAT Bangalore26 Jun 2020AY 2010-11

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadaleassessment Year : 2010-11 Shri. H. S. Ningaiah, Vs. The Deputy Commissioner Of No.143, 4Th Block, Rmhbcs Layout, Income-Tax, Nandhini Layout, Central Circle – 1(4), Bengaluru – 560 096. Bengaluru. Pan : Abrpn 0220 D Appellant Respondent Assessee By : Shri. Pranav Krishna, Advocate Revenue By : Shri. K. V. Aravind, Standing Counsel Date Of Hearing : 23.06.2020 Date Of Pronouncement : 26.06.2020 O R D E R Per A. K. Garodia, Am: This Appeal Is Filed By The Assessee & The Same Is Directed Against The Order Of Learned Cit(A)- 11 Bengaluru, Dated 16.07.2018 For Assessment Year 2010-11. 2. The Grounds Raised By The Assessee Are As Under:

For Appellant: Shri. Pranav Krishna, AdvocateFor Respondent: Shri. K. V. Aravind, Standing Counsel
Section 1Section 153CSection 234Section 234BSection 250

…hearing is in grave violation of principles of natural justice 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 234 B of the Income Tax Act under the facts and circumstances of the case. 12.The calculation of interest by the. learned assessing officer under section 234 B of the Act is not correct. 'As' this is an assessment made under Section 153C of the Act for the impugned assess…