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“live link”

Judicial DoctrinesReopening / 147Reopening / 1471,109 judgments

The decision most relied on for live link is ITO v. Lakhmani Mewal Das (103 ITR 437), cited in 721 judgments on BharatTax.

Leading authorities on live link

ITO v. Lakhmani Mewal Das
103 ITR 437 · 1976 · Supreme Court
721
citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

PCIT v. RMG Polyvinyl (I) Ltd.
396 ITR 5 · 2017 · High Court
272
citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

CIT v. Foramer France
264 ITR 566 · 2003 · Supreme Court
253
citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

ITO v. Selected Dalurband Coal Co. (P.) Ltd.
217 ITR 597 · 1996 · Supreme Court
180
citing judgments

The Assessing Officer's belief that income has escaped assessment, leading to the reopening of an assessment, is a matter of subjective satisfaction. The materials available at the time of forming this belief do not need to conclusively prove the escapement of income.

153 (Gujarat) 8 Shakti Karnawat v. ITO
296 ITR 90 · 2008 · High Court
171
citing judgments

A live link of third-party information can form the basis for reopening an assessment under Section 148, provided it contains material facts necessary for assessment. The Assessing Officer must demonstrate a "reason to believe" that income has escaped assessment, which can be satisfied by such information even if it pertains to other assessees or relates to accommodation entries.

Kalyanji Mavji & Co. v. CIT
102 ITR 287 · 1976 · Supreme Court
137
citing judgments

The Supreme Court broadly defined 'information' for reassessment under Section 147 to include new facts, external sources, material already on record, or a correct understanding of law from judicial decisions. This definition enables reopening assessments based on subsequent information or mistakes.

Judgments citing live link

Kaushik Pravinchandra Gohel, Bhavnagar vs. The Assessing Officer, Ward-1(2), Bhavnagar

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

ITA 692/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2016-17

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri B. R. Popat, A.RFor Respondent: Shri H. Phani Raju, CIT DR
Section 115BSection 143(2)Section 144Section 147Section 148Section 69Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER& SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Kaushik Pravinchandra Gohel, Bhavnagar vs. The Assessing Officer, Ward-1(2), Bhavnagar

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

ITA 691/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2015-16

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri B. R. Popat, A.RFor Respondent: Shri H. Phani Raju, CIT DR
Section 115BSection 143(2)Section 144Section 147Section 148Section 69Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER& SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Kaushik Pravinchandra Gohel, Bhavnagar vs. The Assessing Officer, Ward-1(2), Bhavnagar

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

ITA 690/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2015-16

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri B. R. Popat, A.RFor Respondent: Shri H. Phani Raju, CIT DR
Section 115BSection 143(2)Section 144Section 147Section 148Section 69Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER& SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

V.K.Nanavaty Share and Stock Brokers Private Limited, Mumbai vs. Income Tax Officer Ward-4(2)(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2614/MUM/2023[2012-13]Status: DisposedITAT Mumbai12 Apr 2024AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Ms Padmavathy S, Am आयकर अपील सं/ I.T.A. No.2614/Mum/2023 (निर्धारण वर्ा / Assessment Years: 2012-13) V. K. Nanavaty Share & बिधम/ Ito, Ward-4(2)(4) R. No. 647, 6Th Floor, Stock Brokers Pvt. Ltd Vs. R-709, Rotunda Building, Aaykar Bhavan, Bombay Stock Exchange, Maharishi Karve Road, M. S. Marg, Fort, Mumbai- Churchgate, Mumbai- 400023. 400020. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaacv9670N (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Ravikant Pathak Revenue By: Dr. Yogendra T. Wakare सुनवाई की तारीख / Date Of Hearing: 20/02/2024 घोषणा की तारीख /Date Of Pronouncement: 12/04/2024 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi, Dated 30.05.2023 For Ay. 2012-13. 2. The Assessee Has Challenged The Validity Of The Reopening By Ao (Jurisdiction) U/S 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”). So The Legal Issue Is Taken Up First.

For Appellant: Shri Ravikant PathakFor Respondent: Dr. Yogendra T. Wakare
Section 143(3)Section 147Section 148Section 68

part of assessee to disclose fully and truly all material facts necessary for his assessment, for that assessment year. And there must be a live link between the reasons recorded and formation of the belief that income chargeable to tax has escaped assessment because of failure on the part ... purpose of the section.” “It is, therefore, essential that before such action is taken the requirements of the law should be satisfied. The live link or close nexus which should be there between the material before the Income-tax Officer.” 11. We find that the ‘reasons recorded’, do not state

M/S Godawari Traders Pvt. Ltd., Kolkata vs. ITO, Ward-6(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 1445/KOL/2023[2011-12]Status: DisposedITAT Kolkata08 Apr 2024AY 2011-12

Bench: Shri Anikesh Banerjee & Shri Girish Agrawalassessment Year: 2011-12

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Arup Chatterjee, Addl. CIT
Section 147Section 148Section 151Section 69C

with the Ld. AO to come to conclusion that there is an escapement of income. According to him, said reasons to believe have no live link with the formation of the belief by the AO. He contended that assessment has been opened only to examine the source and creditworthiness ... Godawari Traders Pvt. Ltd. AY 2011-12 147, it can be used by the Ld. AO if there is any tangible material having live links with the escapement of income from assessment. An assessment cannot be reopened merely to verify the genuineness of expenses as it would amount

Anavya Investments Pvt. Ltd., New Delhi vs. ITO Ward-2(4), New Delhi

In the result, appeal of the assessee is allowed

ITA 4828/DEL/2019[2010-11]Status: DisposedITAT Delhi08 Apr 2024AY 2010-11

Bench: Shri C. N. Prasad & Shri M. Balaganeshm/S. Anavya Investments Pvt. Ltd, Vs. Ito, C/O. Sanjay & Sanjay, A-1-A, 14B, Ward-2(4), Janakpuri, New Delhi New Delhi (Appellant) (Respondent) Pan:Aahc4820A Assessee By : Shri Sanjay Garg, Ca Shri Akarsh Garg, Adv Revenue By: Shri Kanv Bali, Sr. Dr Date Of Hearing 11/01/2024 Date Of Pronouncement 08/04/2024

For Appellant: Shri Sanjay Garg, CAFor Respondent: Shri Kanv Bali, Sr. DR
Section 115JSection 139(1)Section 143(3)Section 147Section 148Section 68

find that the reasons recorded by the ld AO for reopening of the assessment in the instant case are very vague without having any live link to form a reasonable belief that the income of the assessee had escaped assessment. The reasons recorded and the assessment order only talk about ... sure about that, the appellant claimed loss or profit by misuse of the CCM. 5.3 He also submitted that there is no live link or direct nexus between alleged material and, inference drawn by the Assessing Officer. The M/s. Anavya Investments Pvt. Ltd learned Counsel relied on decision

K.P. Construction, Chennai vs. ACIT, Chennai

In the result, appeal filed by the assessee in ITA No

ITA 437/CHNY/2021[2016-17]Status: DisposedITAT Chennai05 Apr 2024AY 2016-17

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri G. Baskar, Advocate &For Respondent: Shri P. Sajit Kumar, JCIT
Section 115BSection 142(1)Section 143(2)Section 153CSection 153D

there is no reference to said seized material and thus, from the above, it is undisputedly clear that there is no live link between incriminating material and satisfaction recorded by the AO. The Ld.Counsel for the assessee further referring to the decision of the Hon’ble Karnataka High Court ... said material did not find mention by the AO in the satisfaction note. From the above, it is undisputedly clear that there is no live link between the satisfaction arrived at by the AO and incriminating material found during the course of search and thus, in our considered view

ACIT Circle-65(1), New Delhi vs. Sanjay Pratap Singh, New Delhi

In the result, the appeal of the revenue in ITA No

ITA 4492/DEL/2019[2009-10]Status: DisposedITAT Delhi04 Apr 2024AY 2009-10

Bench: Shri Kul Bharat & Shri M. Balaganesh

For Appellant: Shri R. K. Singhal, CAFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 2(8)Section 271(1)(c)

view of the above, it is held that neither the AO was having any tangible material in his possession nor could he establish any live link between the said material and formation of belief in the case of appellant. He has merely verified and reviewed the information already available ... considered opinion, the existence of tangible material is prerequisite for reopening of an assessment and that tangible material should have live link or nexus with formation of belief for the ld AO to conclude that income of the assessee had escaped assessment. Under these circumstances alone, the assessment could

ACIT Circle-65(1), New Delhi vs. Sanjay Pratap Singh, New Delhi

In the result, the appeal of the revenue in ITA No

ITA 4491/DEL/2019[2009-10]Status: DisposedITAT Delhi04 Apr 2024AY 2009-10

Bench: Shri Kul Bharat & Shri M. Balaganesh

For Appellant: Shri R. K. Singhal, CAFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 2(8)Section 271(1)(c)

view of the above, it is held that neither the AO was having any tangible material in his possession nor could he establish any live link between the said material and formation of belief in the case of appellant. He has merely verified and reviewed the information already available ... considered opinion, the existence of tangible material is prerequisite for reopening of an assessment and that tangible material should have live link or nexus with formation of belief for the ld AO to conclude that income of the assessee had escaped assessment. Under these circumstances alone, the assessment could

Balaji Buillion & Commodities (India) Pvt. Ltd., Mumbai vs. DCIT - CC- 7(1), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 3599/MUM/2018[2009-10]Status: DisposedITAT Mumbai03 Apr 2024AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Years: 2009-10 M/S Balaji Bullion & Dcit Central Circle-7(1), Commodities (India) Pvt. Ltd., Mumbai. 118/120, 3Rd Floor, Ashoka Vs. House Zaveri Baazar, Mumbai-400 002. Pan No. Aadcb 0236 F Appellant Respondent : Mr. N.M. Porwal Assessee By Revenue By : Mr. S. Srinivasu, Cit-Dr : 27/03/2024 Date Of Hearing Date Of Pronouncement : 03/04/2024

For Respondent: Mr. N.M. Porwal
Section 234BSection 68

come to the there is escapement of income from escapement of income from assessment. Reasons must have a live assessment. Reasons must have a live link with the formation o link with the formation of the belief."⁠ 18. Before interfering with the proposed reopening of the 18. Before interfering with

Compact Texfab Pvt. Ltd., New Delhi vs. ITO Ward - 6(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 9524/DEL/2019[2011-12]Status: DisposedITAT Delhi03 Apr 2024AY 2011-12

Bench: Shri Saktijit Dey, Hon’Ble & Shri M. Balaganeshcompact Texfab Pvt. Ltd, Vs. Ito, 1032, H. No. 66, Gali No. Ward-6(2), 33, Jafrabad, New Delhi New Delhi (Appellant) (Respondent) Pan: Aadcc3621P Assessee By : Shri Akhilesh Kumar, Adv Shri Ankit Kumar, Adv Revenue By: Shri Vivek Kumar Upadhyay, Sr. Dr Date Of Hearing 07/02/2024 Date Of Pronouncement 03/04/2024

For Appellant: Shri Akhilesh Kumar, AdvFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 139(1)Section 143(1)Section 147Section 148

escaped assessment would not be sufficient. The ld. AO should have tangible material or information in his possession and such material / information should have live link or nexus with the formation of belief that income of a person had escaped assessment. In the instant case, the ld. AO had merely ... escapement of income of the assessee. Apparently as between the information received and the inference drawn by the ld. AO, there is absolutely no live link or nexus which would enable him to form a belief that income of the assessee had escaped assessment warranting reopening

Hem Lata Jhunjhunwala, Kolkata vs. ACIT, Cir-11(2), Kolkata.

In the result, grounds taken by the assessee in this respect for AY 2011-12 are allowed

ITA 751/KOL/2023[2012-13]Status: DisposedITAT Kolkata01 Apr 2024AY 2012-13

Bench: Shri Rajpal Yadav & Shri Girish Agrawal

For Appellant: Shri Manoj Kataruka, AdvocateFor Respondent: Shri Prabhakar Prakash Ranjan, Addl. CIT
Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

reopen, provided there is “tangible material” to come to the conclusion that there is escapement of income from assessment. Reasons must have a live link with the formation of the belief.” 7.6. We also take assistance from the decision of Hon’ble High Court of Bombay in the case

Hem Lata Jhunjhunwala, Kolkata vs. ACIT, Cir-11(2), Kolkata.

In the result, grounds taken by the assessee in this respect for AY 2011-12 are allowed

ITA 750/KOL/2023[2011-12]Status: DisposedITAT Kolkata01 Apr 2024AY 2011-12

Bench: Shri Rajpal Yadav & Shri Girish Agrawal

For Appellant: Shri Manoj Kataruka, AdvocateFor Respondent: Shri Prabhakar Prakash Ranjan, Addl. CIT
Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

reopen, provided there is “tangible material” to come to the conclusion that there is escapement of income from assessment. Reasons must have a live link with the formation of the belief.” 7.6. We also take assistance from the decision of Hon’ble High Court of Bombay in the case

Thota Venkateswara Rao, Kakinada vs. Income Tax Officer, Ward-1, Kakinada

In the result, appeal of the assessee is allowed

ITA 221/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam28 Mar 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.221/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2017-18) Thota Venkateswara Rao Vs. Income Tax Officer D.No.67-21-12/4 Ward-1 Lb Nagar Ss Kakinada Kakinada [Pan : Abipt6770F] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Aparna Villuri, DR
Section 147Section 148Section 187(3)Section 69A

reopen, provided there is "tangible material" to come to the conclusion that there is escapement of income from assessment. Reasons must have a live link with the formation of the belief. Respectfully following the above ratio laid down in the decision of the Hon’ble Supreme Court, we are inclined

Sri Prakash Bhajandas Talreja, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

ITA 1066/BANG/2023[2018-19]Status: DisposedITAT Bangalore22 Mar 2024AY 2018-19

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 234BSection 271ASection 69

page nos. 65, 68, 70 & 107, which are not the material considered for recording the satisfaction. 6.4 According to ld. A.R., there was no live link between the material considered for recording satisfaction u/s 153C of the Act and framing of assessment u/s 153C of the Act. As such satisfaction ... page nos. 65, 68, 70 & 107, which are not the material considered for recording the satisfaction. 6.4 According to ld. A.R., there was no live link between the material considered for recording satisfaction u/s 153C of the Act and framing of assessment u/s 153C of the Act. As such satisfaction

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

page nos. 65, 68, 70 & 107, which are not the material considered for recording the satisfaction. 6.4 According to ld. A.R., there was no live link between the material considered for recording satisfaction u/s 153C of the Act and framing of assessment u/s 153C of the Act. As such satisfaction

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

page nos. 65, 68, 70 & 107, which are not the material considered for recording the satisfaction. 6.4 According to ld. A.R., there was no live link between the material considered for recording satisfaction u/s 153C of the Act and framing of assessment u/s 153C of the Act. As such satisfaction

Sri Prakash Bhajandas Talreja, Bengaluru vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

ITA 1063/BANG/2023[2016-17]Status: DisposedITAT Bangalore22 Mar 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri G. Manoj Kumar, D.R
Section 153CSection 234BSection 271ASection 69

page nos. 65, 68, 70 & 107, which are not the material considered for recording the satisfaction. 6.4 According to ld. A.R., there was no live link between the material considered for recording satisfaction u/s 153C of the Act and framing of assessment u/s 153C of the Act. As such satisfaction ... page nos. 65, 68, 70 & 107, which are not the material considered for recording the satisfaction. 6.4 According to ld. A.R., there was no live link between the material considered for recording satisfaction u/s 153C of the Act and framing of assessment u/s 153C of the Act. As such satisfaction

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

page nos. 65, 68, 70 & 107, which are not the material considered for recording the satisfaction. 6.4 According to ld. A.R., there was no live link between the material considered for recording satisfaction u/s 153C of the Act and framing of assessment u/s 153C of the Act. As such satisfaction

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

page nos. 65, 68, 70 & 107, which are not the material considered for recording the satisfaction. 6.4 According to ld. A.R., there was no live link between the material considered for recording satisfaction u/s 153C of the Act and framing of assessment u/s 153C of the Act. As such satisfaction