BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for Assessment Years

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

purchases as bogus. In view of the above detailed discussion, facts and judicial pronouncements, we hold that addition made solely based on statement without having corroborative materials cannot be sustained. Therefore, we hereby set aside the finding of the learned CIT(A) and direct the AO . ITA No.399-410/Bang/2025 Page 22 of 33 to delete the addition made by him. Hence

BYSANI ADINARAYAGUPATHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

bogus purchases.\n7.8 Furthermore, the assessee has consistently argued that whatever\nmaize was purchased, whether in cash or through banking channels, was\nfully sold to reputed buyers like Karnataka Milk Federation and Suguna\nFoods. The sales are not doubted, nor has any discrepancy in stock or\nquantitative tally been pointed out. We note that the argument of the\nassessee

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BENGALURU

Bogus\n2019-20\n11,51,54,100\nExpenditure\n6. Relevant Provisions of the Act\n6.1 Sub-sections 4 and 5 of section 12AB of the Act is reproduced below\n[(4) Where registration or provisional registration of a trust or an institution has been q\nunder clause (a) or clause (b) or clause (c) of sub-section (1) or clause

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

bogus purchases.\n7.8 Furthermore, the assessee has consistently argued that whatever\nmaize was purchased, whether in cash or through banking channels, was\nfully sold to reputed buyers like Karnataka Milk Federation and Suguna\nFoods. The sales are not doubted, nor has any discrepancy in stock or\nquantitative tally been pointed out. We note that the argument of the\nassessee

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE 1(3), BENGALURU

In the result, all the appeals of the assessee for A

bogus purchases.\n\n7.8 Furthermore, the assessee has consistently argued that whatever\nmaize was purchased, whether in cash or through banking channels, was\nfully sold to reputed buyers like Karnataka Milk Federation and Suguna\nFoods. The sales are not doubted, nor has any discrepancy in stock or\nquantitative tally been pointed out. We note that the argument of the\nassessee

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

bogus purchases.\n7.8 Furthermore, the assessee has consistently argued that whatever\nmaize was purchased, whether in cash or through banking channels, was\nfully sold to reputed buyers like Karnataka Milk Federation and Suguna\nFoods. The sales are not doubted, nor has any discrepancy in stock or\nquantitative tally been pointed out. We note that the argument of the\nassessee

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

bogus purchases.\n7.8 Furthermore, the assessee has consistently argued that whatever\nmaize was purchased, whether in cash or through banking channels, was\nfully sold to reputed buyers like Karnataka Milk Federation and Suguna\nFoods. The sales are not doubted, nor has any discrepancy in stock or\nquantitative tally been pointed out. We note that the argument of the\nassessee

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

bogus purchases.\n\n7.8 Furthermore, the assessee has consistently argued that whatever\nmaize was purchased, whether in cash or through banking channels, was\nfully sold to reputed buyers like Karnataka Milk Federation and Suguna\nFoods. The sales are not doubted, nor has any discrepancy in stock or\nquantitative tally been pointed out. We note that the argument of the\nassessee

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX, (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

bogus purchases.\n\n7.8 Furthermore, the assessee has consistently argued that whatever\nmaize was purchased, whether in cash or through banking channels, was\nfully sold to reputed buyers like Karnataka Milk Federation and Suguna\nFoods. The sales are not doubted, nor has any discrepancy in stock or\nquantitative tally been pointed out. We note that the argument of the\nassessee

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

bogus purchases.\n\n7.8 Furthermore, the assessee has consistently argued that whatever\nmaize was purchased, whether in cash or through banking channels, was\nfully sold to reputed buyers like Karnataka Milk Federation and Suguna\nFoods. The sales are not doubted, nor has any discrepancy in stock or\nquantitative tally been pointed out. We note that the argument of the\nassessee

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

bogus purchases.\n7.8 Furthermore, the assessee has consistently argued that whatever\nmaize was purchased, whether in cash or through banking channels, was\nfully sold to reputed buyers like Karnataka Milk Federation and Suguna\nFoods. The sales are not doubted, nor has any discrepancy in stock or\nquantitative tally been pointed out. We note that the argument of the\nassessee

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL, BENGALURU

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

127 of the act and further referred to the provisions of section 12 double a of the act and submitted that the principal Commissioner is empowered to deal with the cases pertaining to the registration under section 12 AA/12 AB under the income tax act 1961. She submitted that if such empowerment was not to be legislatively envisaged

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BANGALORE

bogus billings/invoicing, including\nunaccounted and unexplained cash transactions across the years.\nDIVERSION OF CHARITABLE TRUST FUNDS FOR PURCHASE\nOF PROPERTIES IN THE NAME OF TRUSTEES\n3.1.1 On perusal of seized documents and other evidence and\nstatements recorded, it is seen that Mr. P. Shyamaraju and Mr. Umesh\nS. Raju (Trustees of M/s. Rukmini Educational Charitable Trust) had\npurchased properties using

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BENGALURU

bogus billings/invoicing, including\nunaccounted and unexplained cash transactions across the years.\n3.1 DIVERSION OF CHARITABLE TRUST FUNDS FOR PURCHASE\nOF PROPERTIES IN THE NAME OF TRUSTEES\n3.1.1 On perusal of seized documents and other evidence and\nstatements recorded, it is seen that Mr. P. Shyamaraju and Mr. Umesh\nS. Raju (Trustees of M/s. Rukmini Educational Charitable Trust) had\npurchased properties

M/S. SRI . ADICHUNCHANAGIRI SHILKSHANA TRUST,MANDYA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

In the result ITA no.1096/bang/2024 filed by assessee is partly\nallowed and ITA No

127\nITA Nos.1096 & 1207/Bang/2024\nRs.61,000, for income-tax and excess profits tax and\nbusiness profits tax purposes, representing the value of the\nhigh denomination notes which were encashed.”\n214. Further the Hon’ble Supreme Court in the case of CIT v.\nOdeon Builders (P.) Ltd., 418 ITR 315 (SC) head-note is as\nfollows:- “Section

JOHN DISTILLERIES PVT LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 292B of the Act lacks merit as the plain language of the said Section makes it abundantly clear that this provision condones the invalidity which may arise merely by mistake, defect or omission in notice. The said Section reads as under: - 292-B. Return of income, etc., not to be invalid on certain grounds.—No return of income, assessment

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1) , BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 292B of the Act lacks merit as the plain language of the said Section makes it abundantly clear that this provision condones the invalidity which may arise merely by mistake, defect or omission in notice. The said Section reads as under: - 292-B. Return of income, etc., not to be invalid on certain grounds.—No return of income, assessment

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 292B of the Act lacks merit as the plain language of the said Section makes it abundantly clear that this provision condones the invalidity which may arise merely by mistake, defect or omission in notice. The said Section reads as under: - 292-B. Return of income, etc., not to be invalid on certain grounds.—No return of income, assessment