“Commissioner (Appeals)”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(16A) / Section 1174,761 judgments

The decision most relied on for Commissioner (Appeals) is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on Commissioner (Appeals)

Jute Corporation of India Ltd. v. CIT

187 ITR 688 · 1991 · Supreme Court

1,372

citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

CIT v. Premkumar Arjundas Luthra (HUF)

297 CTR 614 · 2017 · High Court

659

citing judgments

The Commissioner of Income-tax (Appeals) cannot dismiss an appeal for non-prosecution or default in appearance. Under Section 250(6) of the Income-tax Act, the CIT(A) must decide the appeal on its merits, even in an ex parte proceeding.

Ahmedabad Electricity Co. Ltd. v. CIT

199 ITR 351 · 1993 · High Court

441

citing judgments

Appellate authorities can consider additional grounds for deduction, even if not originally claimed before the Assessing Officer or Appellate Assistant Commissioner, provided the facts are not disputed and it pertains to a legal claim for correct tax liability. This is because the purpose of an appeal is to ascertain the correct tax liability.

CIT v. Kanpur Coal Syndicate

53 ITR 225 · 1964 · Supreme Court

359

citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

CIT v. Shapoorji Pallonji Mistry

44 ITR 891 · 1962 · Supreme Court

278

citing judgments

The Commissioner of Income-tax (Appeals) cannot enhance an assessment by introducing a new source of income or by changing the head of income during appellate proceedings.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar

1 SCC 591 · 1985 · Reported

225

citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

Mahindra and Mahindra Ltd. v. DCIT

30 SOT 374 · 2009 · ITAT

201

citing judgments

The Commissioner of Income Tax (Appeals) cannot expand the scope of an assessment or improve the Assessing Officer's case in a manner that usurps the revisional power of the Commissioner of Income Tax under Section 263 of the Income-tax Act.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.

56 Taxmann.com 286 · 2015 · High Court

196

citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

Judgments citing Commissioner (Appeals)

Kalipada Saha, Hooghly vs. ITO, Ward-24(3), Hooghly.

In the result, all the four appeals of the assessee are dismissed

ITA 1191/KOL/2023[2013-14]Status: DisposedITAT Kolkata12 Jun 2024AY 2013-14

Bench: Shri Rajpal Yadav & Shri Rakesh Mishra

For Appellant: N o n eFor Respondent: Shri B. K. Singh, Addl. CIT

Section 147Section 148Section 250Section 263Section 271(1)(c)

file an appeal is a statutory right and u/s. 253(1)(a), an appeal can be filed against the order passed by a Commissioner (Appeals) u/s. 250 of the Act and under clause (c) of sub- section (1) of section 253 an appeal can also be filed against an order

Kalipada Saha, Hooghly vs. ITO, Ward-24(3), Hooghly.

In the result, all the four appeals of the assessee are dismissed

ITA 1190/KOL/2023[2012-13]Status: DisposedITAT Kolkata12 Jun 2024AY 2012-13

Bench: Shri Rajpal Yadav & Shri Rakesh Mishra

For Appellant: N o n eFor Respondent: Shri B. K. Singh, Addl. CIT

Section 147Section 148Section 250Section 263Section 271(1)(c)

Kalipada Saha, Hoohly vs. ITO, Ward-24(3), Hooghly.

In the result, all the four appeals of the assessee are dismissed

ITA 1189/KOL/2023[2011-12]Status: DisposedITAT Kolkata12 Jun 2024AY 2011-12

Bench: Shri Rajpal Yadav & Shri Rakesh Mishra

For Appellant: N o n eFor Respondent: Shri B. K. Singh, Addl. CIT

Section 147Section 148Section 250Section 263Section 271(1)(c)

Kalipada Saha, Hooghly vs. ITO, Ward-24(3), Hooghly

In the result, all the four appeals of the assessee are dismissed

ITA 1188/KOL/2023[2010-11]Status: DisposedITAT Kolkata12 Jun 2024AY 2010-11

Bench: Shri Rajpal Yadav & Shri Rakesh Mishra

For Appellant: N o n eFor Respondent: Shri B. K. Singh, Addl. CIT

Section 147Section 148Section 250Section 263Section 271(1)(c)

Temenos Headquarters Sa, Switzerland vs. Deputy Commissioner of Income Tax, International Taxation 2(2), Chennai

In the result, appeals filed by the assessee for assessment years 2016-17, 2020-21 & 2021-22 are allowed and stay applications filed by the assessee for assessment years

ITA 1575/CHNY/2023[2021-22]Status: DisposedITAT Chennai12 Jun 2024AY 2021-22

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Ragunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 1573, 1574 & 1575/Chny/2023 िनधा"रणवष" / Assessment Years: 2016-17, 2020-21 & 2021-22 & S.A. Nos. 20, 21/Chny/2024 [In Ita Nos. 1574 & 1575/Chny/2023] िनधा"रण वष" / Assessment Years : 2020-21, 2021-22 Temenos Headquarters Sa, Deputy Commissioner Of No.2, Rue De Lecole De V. Income Tax, Chimie, International Taxation -2(2), 1205 Geneva, Chennai. Switzerland- 1205. [Pan:Aadct-7868-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओरसे/Appellant By : Shri. R. Sivaraman, Advocate ""यथ" क" ओरसे/Respondent By : Shri. V. Nandakumar, Cit सुनवाई क" तारीख/Date Of Hearing : 24.04.2024 घोषणा क" तारीख/Date Of Pronouncement : 12.06.2024

For Appellant: Shri. R. Sivaraman, AdvocateFor Respondent: Shri. V. Nandakumar, CIT

Section 143(2)Section 143(3)

foreign company - Foreign company raised invoices and assessee applied for exemption certificate under section 195 which was denied by Assessing Officer - On appeal, Commissioner (Appeals) confirmed order of Assessing officer - Whether since payment on account of reimbursement was part and parcel in process of advice of a technical character

Temenos Headquarters Sa, Switzerland vs. Deputy Commissioner of Income Tax, International Taxation 2(2), Chennai

In the result, appeals filed by the assessee for assessment years 2016-17, 2020-21 & 2021-22 are allowed and stay applications filed by the assessee for assessment years

ITA 1574/CHNY/2023[2020-21]Status: DisposedITAT Chennai12 Jun 2024AY 2020-21

For Appellant: Shri. R. Sivaraman, AdvocateFor Respondent: Shri. V. Nandakumar, CIT

Section 143(2)Section 143(3)

Temenos Headquarters Sa, Switzerland vs. Deputy Commissioner of Income Tax, International Taxation 2(2), Chennai

In the result, appeals filed by the assessee for assessment years 2016-17, 2020-21 & 2021-22 are allowed and stay applications filed by the assessee for assessment years

ITA 1573/CHNY/2023[2016-17]Status: DisposedITAT Chennai12 Jun 2024AY 2016-17

For Appellant: Shri. R. Sivaraman, AdvocateFor Respondent: Shri. V. Nandakumar, CIT

Section 143(2)Section 143(3)

Chenniappan Ramadurai, Erode vs. DCIT, Central Circle-2, Coimbatore

In the result the appeal is dismissed

ITA 1337/CHNY/2023[2018-19]Status: DisposedITAT Chennai12 Jun 2024AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1337/Chny/2023 & Ita Nos.1340/Chny/2023 निर्धारण वर्ा /Assessment Years: 2018-19 & Ay-2019-20 Shri Chenniappan Ramadurai, Dy. Commissioner Of Income Tax, No.56, Nms Compound, Erode, Central Circle-2, Coimbatore. Tamil Nadu-638001. [Pan: Aelpr2706M] & Ita Nos.1343/Chny/2023 For Ay 2019-20 Smt. Ramadurai Amutha, No.56, Nms Compound, Erode, Dy. Commissioner Of Income Tax, Tamil Nadu-638001. Central Circle-2, Coimbatore. [Pan: Afvpa4816L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.S.Sridhar, Advocate प्रत्यर्थी की ओर से /Respondent By : Shri Arv Srinivasan, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 30.05.2024 घोषणा की तारीख /Date Of Pronouncement : 12.06.2024

For Appellant: Mr.S.Sridhar, AdvocateFor Respondent: Shri ARV Srinivasan, Addl.CIT

Section 133ASection 147Section 148Section 148(1)Section 250Section 270ASection 270A(6)Section 270A(8)Section 270A(9)

examine the provisions of section 270A reproduced hereunder: 270A. Penalty for under-reporting and misreporting of income.—(1) The Assessing Officer or the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person who has under-reported ... include the following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or the Commissioner (Appeals) or the Commissioner or the Principal Commissioner, as the case may be, is satisfied that the explanation is bona fide and the assessee

K & P Enterprises, Mumbai vs. Deputy Commissioner of Income Tax 22(1), Mumbai

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

ITA 1318/MUM/2024[2008-09]Status: DisposedITAT Mumbai12 Jun 2024AY 2008-09

Bench: Shri Pavan Kumar Gadale & Shri Ratnesh Nandan Sahayi T A. No. 1318, 1319 & 1320/Mum/2024 (A.Y. 2008-09, 2009-10 & 2013-14)

Section 143(3)Section 234ASection 271(1)(c)

rule 45, the following rule shall be substituted, namely:- 7 ITA. No. 1318 to 1320/MUM/2024 K & P Enterprises, Mumbai. 45. Form of appeal to Commissioner (Appeals).- (1) An appeal to the Commissioner (Appeals) shall be made in Form No. 35. (2) Form No. 35 shall be furnished in the following

Swatipushp Dealers Pvt. Ltd.(Since Merged With Snowtemp Commercial Pvt. Ltd.), Kolkata vs. ITO, Ward-11(2), Kolkata

The appeal of the assessee is allowed

ITA 258/KOL/2024[2011-12]Status: DisposedITAT Kolkata11 Jun 2024AY 2011-12

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. No. 258/Kol/2024 Assessment Year: 2011-2012 Swatipushp Dealers Pvt. Ltd.,……………………Appellant (Since Merged With Snowtemp Commercial Pvt. Ltd.) 101, 1St Floor, 18, Prince Anwar Shah Road, Kolkata-700033 [Pan:Aapcs5069P] -Vs.- Income Tax Officer,…………………………...…Respondent Ward-11(2), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Abhishak Bansal, A.R., Appeared On Behalf Of The Assessee Shri Loviesh Shelley, Jcit, D.R. Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : May 30, 2024 Date Of Pronouncing The Order : June 11, 2024 O R D E R

Section 143(3)Section 263Section 271Section 271(1)(c)

under:- “Failure to furnish returns, comply with notices, concealment of income, etc. 271:- (1) If the Assessing Officer or the Joint Commissioner or the Commissioner (Appeals) or the Principal Commissioner or Commissioner in the course of any proceedings under this Act, is satisfied that any person

M/S. Philips India Limited (Successor to Erstwhile Philips Software Centre Pvt. Ltd.), Kolkata vs. D.C.I.T./A.C.I.T.(Transfer Pricing) - 2, Kolkata

In the result, appeal of the assessee in ITA No

ITA 33/KOL/2023[2004-2005]Status: DisposedITAT Kolkata11 Jun 2024AY 2004-2005

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Blei.T.A. No. 32 & 33/Kol/2023 Assessment Year: 2004-05 M/S. Philips India Limited Joint Commissioner Of Income-Tax 3Rd Floor, Tower A Vs (Transfer Pricing-Ii), Bangalore [Presently Deputy Dlf Park, 08 Block Af Commissioner/Assistant Major Arterial Road Commissioner Of Income-Tax New Town Transfer Pricing 2, Kolkata Kolkata - 700156 [Pan : Aabcp9487A] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ketan K. Ved, A.R. Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 13/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 11/06/2024 आदेश/O R D E R Per Sanjay Garg: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre (Hereinafter The “Ld. Cit(A)”), Even Dt. 15/11/2022, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2004-05. 2. The Sole Issue Raised In Both The Appeals Is Relating To The Maintainability Of The Appeals Before The Ld. Cit(A) Against The Rectification Orders Passed By The Transfer Pricing Officer (In Short “Tpo”) U/S 154 R.W. Sub-Section (5) To Section 92Ca Of The Act. The Ld. Cit(A) Vide Impugned Orders Has Dismissed The Appeals Of The Assessee Holding That As Per The Provisions Of Section 246A Of The Act, Order U/S 92Ca Or Its Rectification Order U/S 154 Of The Act Passed By The Tpo Is 2

For Appellant: Shri Ketan K. Ved, A.RFor Respondent: Shri Rakesh Kumar Das, CIT, D/R

Section 154Section 246ASection 250Section 92C

passed by the TPO is 2 I.T.A. No. 32 & 33/Kol/2023 Assessment Year: 2004-05 M/s. Philips India Limited not an appealable order before the Commissioner (Appeals) and he accordingly dismissed both the appeals being non-maintainable. 3. Being aggrieved by the said orders of the ld. CIT(A), the assessee ... notice by the assessee 58[or by the deductor] 59[or by the collector], and where the authority concerned is 59a[the Joint Commissioner (Appeals) or] the 60[***] 61[Commissioner (Appeals)], by the 62[Assessing] Officer also. (3) An amendment, which has the effect of enhancing an assessment64 or reducing

M/S. Philips India Limited (Successor to Erstwhile Philips Software Centre Pvt. Ltd.), Kolkata vs. D.C.I.T./A.C.I.T. (Transfer Pricing) - 2, Kolkata

In the result, appeal of the assessee in ITA No

ITA 32/KOL/2023[2004-2005]Status: DisposedITAT Kolkata11 Jun 2024AY 2004-2005

For Appellant: Shri Ketan K. Ved, A.RFor Respondent: Shri Rakesh Kumar Das, CIT, D/R

Section 154Section 246ASection 250Section 92C

DCIT, Chennai vs. Tvs Investments Lrd., Chennai

In the result, the Revenue's appeal as well as the assessee's Cross Objection are allowed for statistical purposes

ITA 262/CHNY/2017[2010-11]Status: DisposedITAT Chennai11 Jun 2024AY 2010-11

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.262/Chny/2017 (िनधा*रण वष* / Assessment Year: 2010-11) Dcit M/S. Tvs Capital Funds (P) Limited (Formerly Known As Tvs Investments Limited) Corporate Circle-3(1) बनाम/ Jayalakshmi Estates, Chennai-600 034. Vs. No.29, (Old No.8), Haddows Road Chennai-600 006. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaact-1154-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Dr. D. Praveen (Jcit) -Ld. Dr " थ"कीओरसे/Respondent By : Shri R. Vijayaraghavan, (Advocate)-Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 15-05-2024 घोषणाकीतारीख /Date Of Pronouncement : 11-06-2024 आदेश / O R D E R

For Appellant: Dr. D. Praveen (JCIT) -Ld. DRFor Respondent: Shri R. Vijayaraghavan, (Advocate)-Ld. AR

company, evidence whereof was with the Assessing Officer. Therefore, the Assessing Officer could not have added the income, which was rightly deleted by the Commissioner (Appeals) as well as the Tribunal" Further, it was held as under: "The Tribunal was right in rejecting the appeal of the revenue by holding

Vilas Ramesh Ambekar, Mumbai vs. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC)

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 4765/MUM/2023[2017-18]Status: DisposedITAT Mumbai11 Jun 2024AY 2017-18

Bench: Shri B R Baskaran, Am & Ms. Kavitha Rajagopal, Jm Vilas Ramesh Ambekar Commissioner Of Income Tax 20-973, Mhb Colony, (Appeals) S C Raheja Marg, Mahim, National Faceless Appeal Centre Vs. Mumbai-400 016 (Nfac) North Block, Delhi-110 001

For Appellant: NoneFor Respondent: Ms. Rajeshwari Menon

Section 143(1)Section 143(2)Section 143(3)Section 250Section 264Section 68

short) and on perusal of the materials available on record. 3. The assessee has challenged this appeal on the following grounds: 1. The Learned Commissioner (Appeals) has erred in passing the Order u/s 250 of income Tax Act,1961 in upholding the addition made by the assessing officer without appreciating ... timely responses who already waited for more than 3 years earlier for hearing to commence under erstwhile physical hearing mode. 2. The Learned Commissioner (Appeals) has erred in passing the Order u/s 250 of Income Tax Act,1961 without giving the proper opportunity of being heard to the appellant

Ashok Chowdhary, Jaipur vs. ITO, Ward, Jhalawar

In the result, the appeal of the assesee is allowed

ITA 238/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Jun 2024AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Rajeev Sogani, CA &For Respondent: Shri Rajesh Kumar Meena, Addl. CIT-DR

Section 115BSection 254Section 68

reason to restrict the power of the Tribunal under section 254 only to decide the grounds which arise from the order of the Commissioner (Appeals). Both the assessee as well as the department have a right to file an appeal/cross objections before the Tribunal. There is no reason

Jaipur Jewellery Show, Jaipur vs. ACIT-DCIT Circle (Exemp.), Jaipur

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

ITA 164/JPR/2024[2012-13]Status: DisposedITAT Jaipur10 Jun 2024AY 2012-13

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri Rajesh Kumar Meena, Addl. CIT-DR

Section 11Section 12ASection 143(3)Section 250Section 264

revised return, it could still be considered, if, the relevant material was available on record, either by the appellate authorities, (which includes both the Commissioner (Appeals) and the Tribunal) by themselves, or on remand, by the Assessing Officer. The failure to advert to the claim in the original return ... reason to restrict the power of the Tribunal in such appeal only to decide the grounds which arise from the order of Commissioner (Appeals). The Tribunal should not be prevented from considering the questions of law arising in assessment proceedings although not raised earlier. 33. In case of Goetze (India

Vijay Prakash Sharma, Jaipur vs. I.T.O, Ward 4(4), Jaipur

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

ITA 774/JPR/2023[A.Y. 2011-12]Status: DisposedITAT Jaipur10 Jun 2024

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri G.M. Mehta, CAFor Respondent: Mrs. Monisha Chaudhary Addl. CIT

Section 249(3)

shall be in the prescribed form and shall be verified in the prescribed manner (and shall, in case of an appeal made to the Commissioner (Appeals) on or after the 1st day of October, 1998, irrespective of the date of initiation of the assessment proceedings relating thereto be accompanied ... appeal within the time specified in that sub-section, he may present such appeal before the 1st day of July, 2000] (3) The [***] [Commissioner (Appeals)] may admit an appeal after the expiration of the said period if he is satisfied that the appellant had sufficient cause for not presenting

Kalasa Lakshmanashetty Mahesh, Chikkamagaluru vs. Income Tax Officer, Income Tax

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

ITA 792/BANG/2024[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Manish Golyan, CA

Section 250

confront the evidence against them. Allowing the respondent to introduce new evidence unfairly prejudices the appellant's rights. 9. Abuse of Discretion: The [Joint Commissioner] (Appeals) and Commissioner (Appeals) have a duty to exercise their discretion judiciously. Allowing the production of additional evidence without sufficient cause or justification constitutes ... deleted. PRAYER The Appellant prays before the Income Tax Tribunal to Set aside the order allowing the production of additional evidence before the [Joint Commissioner] (Appeals) and Commissioner (Appeals). Direct the [Joint Commissioner] (Appeals) and Commissioner (Appeals) to adjudicate the appeal based on the evidence already on record. The Appellant

Income Tax Officer W 1, Hassan vs. Ramachandra Setty and Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1166/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 115BSection 132(4)Section 250Section 69B

ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE

Income Tax Officer, W-1, Vijayanagar vs. Ramachandra Setty and Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1165/BANG/2023[2015-16]Status: DisposedITAT Bangalore10 Jun 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 115BSection 132(4)Section 250Section 69B

ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE