M/S. UDUPI NIRMITHI KEDRA,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE - 1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1,, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

M/S. DAKSHINA KANNADA NIRMITHI KENDRA,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE -1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

SRI SRINIVASA TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

12A of the Act. Accordingly, the ground of appeal of the assessee is dismissed. 9. The issue raised by the assessee in Ground No. 2(iii) is that the Ld. CIT(A) erred in confirming the addition of ₹39,99,359.00 by treating certain expenses as not allowable as an application of income. 9.1 During the assessment proceedings

SRI SRINIVASA TRUST,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

12A of the Act. Accordingly, the ground of appeal of the assessee is dismissed. 9. The issue raised by the assessee in Ground No. 2(iii) is that the Ld. CIT(A) erred in confirming the addition of ₹39,99,359.00 by treating certain expenses as not allowable as an application of income. 9.1 During the assessment proceedings

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, , BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No:Aaajk0398K\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

12A of the Act.\n\n8. The ld. D.R. on the other hand, vehemently supported the orders of the authorities below.\n\n9. We have heard the rival submissions and perused the materials available on record. The only issue raised in this appeal is with regard to the denial of the exemption under section 11 of the Act. The brief

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No :Aaajk0398K\Nappellant\Nrespondent\N\Nappellant By\Nrespondent By\N: Sri Padamchand Khincha, A.R.\N: Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing\N: 17.09.2025\Ndate Of Pronouncement\N: 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed\Nagainst The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide\Ndin & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For\Nthe Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With\Ndin & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For\Nthe Assessment Year 2015-16 Passed U/S 250 Of The Income Tax\Nact, 1961 (In Short “The Act”). Since The Issues In Both The Appeals\Nare Similar, These Are Clubbed Together, Heard Together And\Ndisposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025\Nfor The Assessment Year 2021-22 For Adjudication. The Assessee\Nhas Raised The Following Grounds Of Appeal:\N\N1. General Ground\N1.

12A of the Act.\n\n8. The ld. D.R. on the other hand, vehemently supported the\norders of the authorities below.\n\n9. We have heard the rival submissions and perused the\nmaterials available on record. The only issue raised in this appeal is\nwith regard to the denial of the exemption under section 11 of the\nAct. The brief

KOGOD BASAVARAJU JAYACHANDRA ,HASSAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result the ITA No

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

TDS on such interest payment. Assessee was also unable to establish the nature of business carried out . The Learned DR further submitted that the assessee has claimed interest expenditure of Rs.1,55,16,,000/- which is also not substantiated. 26. Considering the rival submissions and perusing the materials available on record and Order of the authorities below, we noted that

KOGOD BASAVARAJU JAYACHANDRA ,HASSAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result the ITA No

TDS on such interest payment. Assessee was also\nunable to establish the nature of business carried out. The Learned DR further\nsubmitted that the assessee has claimed interest expenditure of Rs.1,55,16,000/-\nwhich is also not substantiated.\n\n26.\nConsidering the rival submissions and perusing the materials available on\nrecord and Order of the authorities below, we noted

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, appeals filed by the assessee are partly allowed in above\nterms

TDS on such interest payment in\nthe light of provisions of section 40(a)(ia) of the Act but there is no compliance\nof the provision of section 40(a)(ia) of the Act by the assessee since on this issue,\nthe assessee was unable to substantiate the genuineness of expenditure incurred\nfor business purposes as well

SMT. NISHITA NANDISH ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

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

TDS on such interest payment. Assessee was also unable to establish the nature of business carried out by her. The learned DR has also filed a letter received from Income Tax Officer (Inv. Unit – 3), Bangalore, dated 15.06.2017 which is placed on record.Learned DR further submitted that the assessee has claimed interest expenditure of Rs.50,00,000/- which is also

SMT. NISHITA NANDISH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

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

TDS on such interest payment. Assessee was also unable to establish the nature of business carried out by her. The learned DR has also filed a letter received from Income Tax Officer (Inv. Unit – 3), Bangalore, dated 15.06.2017 which is placed on record.Learned DR further submitted that the assessee has claimed interest expenditure of Rs.50,00,000/- which is also

SMT. NISHITA NANDISH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

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

TDS on such interest payment. Assessee was also unable to establish the nature of business carried out by her. The learned DR has also filed a letter received from Income Tax Officer (Inv. Unit – 3), Bangalore, dated 15.06.2017 which is placed on record.Learned DR further submitted that the assessee has claimed interest expenditure of Rs.50,00,000/- which is also

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

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

TDS on such interest payment. Assessee was also unable to establish the nature of business carried out by her. From computation of income, the assessee has shown salary income from Xentrix Studio Pvt. Ltd., and the entire cash deposits have been shown as other income of the assessee and the assessee has claimed ITA Nos.1656 to 1658/Bang/2024 Page

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

TDS on such interest payment in\nthe light of provisions of section 40(a)(ia) of the Act but there is no compliance\nof the provision of section 40(a)(ia) of the Act by the assessee since on this issue,\nthe assessee was unable to substantiate the genuineness of expenditure incurred\nfor business purposes as well

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory