M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

bogus entry and it is proved beyond reasonable doubt that it is only an adjustment entry to reduce the profits as per books by inflating expenditure and reducing tax liability thereon. In the light of the above, the assessee was further asked to substantiate why section 40A(3) of the Act should not be invoked in the assessee’s case

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

bogus entry and it is proved beyond reasonable doubt that it is only an adjustment entry to reduce the profits as per books by inflating expenditure and reducing tax liability thereon. In the light of the above, the assessee was further asked to substantiate why section 40A(3) of the Act should not be invoked in the assessee’s case

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

bogus entry and it is proved beyond reasonable doubt that it is only an adjustment entry to reduce the profits as per books by inflating expenditure and reducing tax liability thereon. In the light of the above, the assessee was further asked to substantiate why section 40A(3) of the Act should not be invoked in the assessee's case

M/S. CRYSTAL GRANITE AND MARBLE PRIVATE LIMITED,RAMANAGARAM vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes and Stay Petition is dismissed as infructuous

Bench: Shri George George K & Shri Laxmi Prasad Sahus.P No.29/Bang/2023 Assessment Year: 2017-18

purchase bills to various entities, and there was no actual supply of goods. Further during the post search enquiry statement of Shri Urvil A Jani, one of the key persons of the Oneworld group of companies recorded on 08.02.2020, wherein he admitted that various Oneworldd group entities have made bogus purchase/bogus sales transactions with various entities controlled and managed

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

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

purchase of shares of Mahaveer Advanced Rem for Rs.10,60,000/- on the facts and circumstances of the case. b. The authorities below have failed to appreciate that the provisions of section 69A of the Act is not mandatory but discretionary in nature on the facts and circumstances of the case. b. The authorities below have failed to appreciate that

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

Section\n153D. It is not an exercise dealing with a immaterial matter which\ncould be corrected by taking recourse to Section 292B of the Act.\n16. We are not inclined to interdict the order of the Tribunal.\n17. Accordingly, the appeal is closed.\n6.5 The above view taken by the Hon’ble Delhi High Court in the case of PCIT

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX OFFICER, CENTRAL CIRCLE-2(2), BENGALURU

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

purchase consideration of Rs.13.60 crores shall be towards transfer of intangible assets of SHL to BNHL such as goodwill, revenue rights, tenancy rights, permits etc. Page 41 of 47 ITA Nos.21 to 26/Bang/2024 12. On the other hand, learned DR relied on the Order of lower authorities and submitted that assessee has raised additional grounds challenging the validity under section

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

purchased. The Agreement itself indicates that slump sale included sale of goodwill and the balance sheet drawn up on 22nd September, 2006 specifically recorded goodwill at Rs.40,58,75,529.40/-. As indicated hereinbefore Goodwill includes a host of intangible assets, which a person acquires, on acquiring a business as a going concern and valuing the same at the excess consideration

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

purchased. The Agreement itself indicates that slump sale included sale of goodwill and the balance sheet drawn up on 22nd September, 2006 specifically recorded goodwill at Rs.40,58,75,529.40/-. As indicated hereinbefore Goodwill includes a host of intangible assets, which a person acquires, on acquiring a business as a going concern and valuing the same at the excess consideration

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, appeals filed by the assessee are partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

purchased. The Agreement itself indicates that slump sale included sale of goodwill and the balance sheet drawn up on 22nd September, 2006 specifically recorded goodwill at Rs.40,58,75,529.40/-. As indicated hereinbefore Goodwill includes a host of intangible assets, which a person acquires, on acquiring a business as a going concern and valuing the same at the excess consideration

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

b). For the above your proposal to treat the payments made to these concerns as inflated expenditure is without any basis. Further, there being actual purchases of bottles and grapes and the transaction being genuine, any attempt to treat the entire payment made to the two concerns as inflated expenditure would be without any basis and against the principles

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

b). For the above your proposal to treat the payments made to these concerns as inflated expenditure is without any basis. Further, there being actual purchases of bottles and grapes and the transaction being genuine, any attempt to treat the entire payment made to the two concerns as inflated expenditure would be without any basis and against the principles

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

b). For the above your proposal to treat the payments made to these concerns as inflated expenditure is without any basis. Further, there being actual purchases of bottles and grapes and the transaction being genuine, any attempt to treat the entire payment made to the two concerns as inflated expenditure would be without any basis and against the principles

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

b). For the above your proposal to treat the payments made to these concerns as inflated expenditure is without any basis. Further, there being actual purchases of bottles and grapes and the transaction being genuine, any attempt to treat the entire payment made to the two concerns as inflated expenditure would be without any basis and against the principles

M/S. ANNAPURNESHWARI INVESTMENTS,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2(2), BANGALORE

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

Bench: Shri A. K. Garodia & Smt. Beena Pillai

bogus and therefore, this claim of the assessee that the assessee has proved genuineness of payments to sub contractors is factually incorrect. CIT (A) has noted in para 18 of the impugned order that the assessee has failed to produce any documentary evidence in support of the contentions and therefore, no interference is called for in the assessment order

M/S. ANNAPURNESHWARI INVESTMENTS,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2(2), BANGALORE

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

Bench: Shri A. K. Garodia & Smt. Beena Pillai

bogus and therefore, this claim of the assessee that the assessee has proved genuineness of payments to sub contractors is factually incorrect. CIT (A) has noted in para 18 of the impugned order that the assessee has failed to produce any documentary evidence in support of the contentions and therefore, no interference is called for in the assessment order

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

149 to 151of the assessment order wherein the AO has computed the alleged “unaccounted cash generated from UG-MBBS course and PG course conducted by the appellant. The remarks column essentially describes the material relied upon by the learned assessing officer to make the aforementioned computation. This has been discussed in detail in the separate submissions made for each