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“Section 132(1)(i)”

Section References (mined)Section 132Section 132(1)(i)20 judgments

VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), BENGALURU -2(2), BENGALURU

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 394/BANG/2025[2019-20]Status: DisposedITAT Bangalore07 Jul 2025AY 2019-20

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

ITA Nos.386 to 394/Bang/2025 Visa Worldwide Ptd. Limited, Bangalore North IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE

VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), BENGALURU -2(2), BENGALURU

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 393/BANG/2025[2018-19]Status: DisposedITAT Bangalore07 Jul 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

ITA Nos.386 to 394/Bang/2025 Visa Worldwide Ptd. Limited, Bangalore North IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE

VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), BENGALURU -2(2), BENGALURU

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 392/BANG/2025[2017-18]Status: DisposedITAT Bangalore07 Jul 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

ITA Nos.386 to 394/Bang/2025 Visa Worldwide Ptd. Limited, Bangalore North IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE

VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), BENGALURU -2(2), BENGALURU

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 391/BANG/2025[2016-17]Status: DisposedITAT Bangalore07 Jul 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

ITA Nos.386 to 394/Bang/2025 Visa Worldwide Ptd. Limited, Bangalore North IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE

VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), BENGALURU -2(2), BENGALURU

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 390/BANG/2025[2015-16]Status: DisposedITAT Bangalore07 Jul 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

ITA Nos.386 to 394/Bang/2025 Visa Worldwide Ptd. Limited, Bangalore North IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE

VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), BENGALURU -2(2), BENGALURU

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 389/BANG/2025[2014-15]Status: DisposedITAT Bangalore07 Jul 2025AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

ITA Nos.386 to 394/Bang/2025 Visa Worldwide Ptd. Limited, Bangalore North IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE

VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), BENGALURU -2(2), BENGALURU

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 388/BANG/2025[2013-14]Status: DisposedITAT Bangalore07 Jul 2025AY 2013-14

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

ITA Nos.386 to 394/Bang/2025 Visa Worldwide Ptd. Limited, Bangalore North IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE

VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), BENGALURU -2(2), BENGALURU

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 387/BANG/2025[2012-13]Status: DisposedITAT Bangalore07 Jul 2025AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

ITA Nos.386 to 394/Bang/2025 Visa Worldwide Ptd. Limited, Bangalore North IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE

VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), BENGALURU -2(2), BENGALURU

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 386/BANG/2025[2011-12]Status: DisposedITAT Bangalore07 Jul 2025AY 2011-12

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

ITA Nos.386 to 394/Bang/2025 Visa Worldwide Ptd. Limited, Bangalore North IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE

M/S. HINDUSTHAN BAWA BUILDERS,MANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, appeals of the assessee in ITA Nos

ITA 271/BANG/2024[2018-19]Status: DisposedITAT Bangalore04 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a) / (b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... justify his estimation of unaccounted income. The whole principle of an assessment which is preceded by search is that an officer specified in section 132(1) has reason to believe in consequence of information in his possession that any of the eventualities stated in section 132(1

M/S. HINDUSTHAN BAWA BUILDERS,MANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, appeals of the assessee in ITA Nos

ITA 270/BANG/2024[2017-18]Status: DisposedITAT Bangalore04 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a) / (b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... justify his estimation of unaccounted income. The whole principle of an assessment which is preceded by search is that an officer specified in section 132(1) has reason to believe in consequence of information in his possession that any of the eventualities stated in section 132(1

M/S. HINDUSTHAN BAWA BUILDERS,MANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, appeals of the assessee in ITA Nos

ITA 269/BANG/2024[2016-17]Status: DisposedITAT Bangalore04 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a) / (b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... justify his estimation of unaccounted income. The whole principle of an assessment which is preceded by search is that an officer specified in section 132(1) has reason to believe in consequence of information in his possession that any of the eventualities stated in section 132(1

M/S. HINDUSTHAN BAWA BUILDERS,MANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , MANGALORE

In the result, appeals of the assessee in ITA Nos

ITA 268/BANG/2024[2014-15]Status: DisposedITAT Bangalore04 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a) / (b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... justify his estimation of unaccounted income. The whole principle of an assessment which is preceded by search is that an officer specified in section 132(1) has reason to believe in consequence of information in his possession that any of the eventualities stated in section 132(1

MR. ABDUL KHADER KODI,KASARGOD, KARNATAKA vs. MR. C. VIJAY JAYAN, DEPUTY COMMISSIONER OF INCOME TAX, MANGALURU

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

ITA 638/BANG/2023[2018-2019]Status: DisposedITAT Bangalore22 Mar 2024AY 2018-2019

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.636 To 638/Bang/2023 Assessment Years: 2016-17 To 2018-19 Mr. Abdul Khader Kodi Darul Huda, Near Salafi Masjid Kunjathur Via Dcit Manjeshwar Central Circle-2 Vs. Kasargod 671 323 Mangaluru Karnataka Pan No : Alhpk5340F Appellant Respondent Appellant By : Shri Ravishankar S.V., A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: These Appeals By Assessee Are Directed By Different Orders Of Nfac For The Assessment Years 2016-17 To 2018-19 Having Common Date Dated 23.5.2022. 2. The Grounds Raised By The Assessee In All These Appeals Are Common In Nature, Except Change In Figures. We Consider Grounds In Ita No.636/Bang/2023, Which Reads As Follows: 1. The Learned Cit(A)-2, Panaji Erred In Passing The Order In The Manner He Did. 2. The Ld. Cit(A)-2, Panaji Erred In Upholding The Additions Made By The Assessing Officer Amounting To Rs.6,25,000 As Undisclosed Business Income & Rs.1,99,40,000 As Unexplained Investments Under Section 68 Of The Income Tax Act, 1961, Which Was Purely On Assumptions & Presumptions Based On The Loose Sheet Found At The Time Of Search.

For Appellant: Shri Ravishankar S.V., A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 132Section 144Section 153ASection 34Section 68Section 69Section 69B

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a) / (b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... justify his estimation of unaccounted income. The whole principle of an assessment which is preceded by search is that an officer specified in section 132(1) has reason to believe in consequence of information in his possession that any of the eventualities stated in section 132(1

MR. ABDUL KHADER KODI,KASARGOD, KARNATAKA vs. MR. C. VINOD JAYAN, DEPUTY COMMISSIONER OF INCOME TAX, MANGALORE

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

ITA 637/BANG/2023[2017-2018]Status: DisposedITAT Bangalore22 Mar 2024AY 2017-2018

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.636 To 638/Bang/2023 Assessment Years: 2016-17 To 2018-19 Mr. Abdul Khader Kodi Darul Huda, Near Salafi Masjid Kunjathur Via Dcit Manjeshwar Central Circle-2 Vs. Kasargod 671 323 Mangaluru Karnataka Pan No : Alhpk5340F Appellant Respondent Appellant By : Shri Ravishankar S.V., A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: These Appeals By Assessee Are Directed By Different Orders Of Nfac For The Assessment Years 2016-17 To 2018-19 Having Common Date Dated 23.5.2022. 2. The Grounds Raised By The Assessee In All These Appeals Are Common In Nature, Except Change In Figures. We Consider Grounds In Ita No.636/Bang/2023, Which Reads As Follows: 1. The Learned Cit(A)-2, Panaji Erred In Passing The Order In The Manner He Did. 2. The Ld. Cit(A)-2, Panaji Erred In Upholding The Additions Made By The Assessing Officer Amounting To Rs.6,25,000 As Undisclosed Business Income & Rs.1,99,40,000 As Unexplained Investments Under Section 68 Of The Income Tax Act, 1961, Which Was Purely On Assumptions & Presumptions Based On The Loose Sheet Found At The Time Of Search.

For Appellant: Shri Ravishankar S.V., A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 132Section 144Section 153ASection 34Section 68Section 69Section 69B

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a) / (b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... justify his estimation of unaccounted income. The whole principle of an assessment which is preceded by search is that an officer specified in section 132(1) has reason to believe in consequence of information in his possession that any of the eventualities stated in section 132(1

MR. ABDUL KHADER KODI,KASARGOD, KARNATAKA vs. MR. C. VINOD JAYAN, DEPUTY COMMISSIONER OF INCOME TAX, MANGALORE

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

ITA 636/BANG/2023[2016-2017]Status: DisposedITAT Bangalore22 Mar 2024AY 2016-2017

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.636 To 638/Bang/2023 Assessment Years: 2016-17 To 2018-19 Mr. Abdul Khader Kodi Darul Huda, Near Salafi Masjid Kunjathur Via Dcit Manjeshwar Central Circle-2 Vs. Kasargod 671 323 Mangaluru Karnataka Pan No : Alhpk5340F Appellant Respondent Appellant By : Shri Ravishankar S.V., A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: These Appeals By Assessee Are Directed By Different Orders Of Nfac For The Assessment Years 2016-17 To 2018-19 Having Common Date Dated 23.5.2022. 2. The Grounds Raised By The Assessee In All These Appeals Are Common In Nature, Except Change In Figures. We Consider Grounds In Ita No.636/Bang/2023, Which Reads As Follows: 1. The Learned Cit(A)-2, Panaji Erred In Passing The Order In The Manner He Did. 2. The Ld. Cit(A)-2, Panaji Erred In Upholding The Additions Made By The Assessing Officer Amounting To Rs.6,25,000 As Undisclosed Business Income & Rs.1,99,40,000 As Unexplained Investments Under Section 68 Of The Income Tax Act, 1961, Which Was Purely On Assumptions & Presumptions Based On The Loose Sheet Found At The Time Of Search.

For Appellant: Shri Ravishankar S.V., A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 132Section 144Section 153ASection 34Section 68Section 69Section 69B

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a) / (b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... justify his estimation of unaccounted income. The whole principle of an assessment which is preceded by search is that an officer specified in section 132(1) has reason to believe in consequence of information in his possession that any of the eventualities stated in section 132(1

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

ITA 1065/BANG/2023[2017-18]Status: DisposedITAT Bangalore22 Mar 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 271ASection 69

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a)/(b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... eventualities stated in section 132(1)(a)/(b) exist. Therefore, section 132(4A) cannot come into play. Consequently, section 292C does not apply. 9.13 Without prejudice to the above, he submitted that assessment u/s 153C have been made in the case of the assessee relying upon the very same material

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

ITA 1064/BANG/2023[2016-17]Status: HeardITAT Bangalore22 Mar 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 271ASection 69

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a)/(b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... eventualities stated in section 132(1)(a)/(b) exist. Therefore, section 132(4A) cannot come into play. Consequently, section 292C does not apply. 9.13 Without prejudice to the above, he submitted that assessment u/s 153C have been made in the case of the assessee relying upon the very same material

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

ITA 1062/BANG/2023[2015-16]Status: DisposedITAT Bangalore22 Mar 2024AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 271ASection 69

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a)/(b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... eventualities stated in section 132(1)(a)/(b) exist. Therefore, section 132(4A) cannot come into play. Consequently, section 292C does not apply. 9.13 Without prejudice to the above, he submitted that assessment u/s 153C have been made in the case of the assessee relying upon the very same material

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

ITA 1061/BANG/2023[2014-15]Status: DisposedITAT Bangalore22 Mar 2024AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 271ASection 69

section (1) of section 132. The books of account or other documents referred to in section 132(4A) are those referred to in section 132(1)(iii) read with section 132(1)(a)/(b). The assessee has established that the authorising officer could not have formed a reasonable belief that ... eventualities stated in section 132(1)(a)/(b) exist. Therefore, section 132(4A) cannot come into play. Consequently, section 292C does not apply. 9.13 Without prejudice to the above, he submitted that assessment u/s 153C have been made in the case of the assessee relying upon the very same material