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

bogus entry and it is proved beyond reasonable doubt\nthat it is only an adjustment entry to reduce the profits as per books by inflating\nexpenditure and reducing tax liability thereon. In the light of the above, the\nassessee was further asked to substantiate why section 40A(3) of the Act should\nnot be invoked in the assessee's case

M/S. CONCORDE HOUSING CORPORATION PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

153(1) of the Act on 27.12.2017. The final assessed income was Rs.28,94,66,747/-, which encompassed an addition of Rs.5,00,40,364/- for AY 2015-16. Income Overview Table: Particulars Original ROI 153A ROI Revised (3011.2015) (12.12.2016) computation (10.11.2017) Business Rs.22,75,16,696/- Rs.23,56,46,839/- Rs.28,87,77,351/- income Income from Rs.37

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, appeals of the assessee in ITA Nos

1)\nSri K. Mohammed Haris, Director of M/s Mukka Sea\nFood Industries Pvt. Ltd., a working Director of the\ncompany, in the statement recorded u/s 132(4) of the\nAct, in reply to Q.No.24 agreed that these are bogus\nentries in books.\n(2)\nSo, when ‘NO PURCHASE” was made, obviously there\nwas “NO SALE”. So, there

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

153\ntaxmann.com 591, has held that where a prohibitory order under section\n132(3) of the Act is not revoked within one month as per the CBDT’s\ndirective, any panchanama drawn thereafter loses its legal validity and\ncannot be considered for computing limitation under section 153B of the\nAct. The relevant finding of the Tribunal in said case reads

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

153/- made on the scrip sale of Pearl Electric Limited on the facts and circumstances of the case. b. The authorities below were not justified in invoking the provisions of section 69A of the Act with respect to the purchase of shares of Mahaveer Advanced Rem for Rs.10,60,000/- on the facts and circumstances of the case

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

153\ntaxmann.com 591, has held that where a prohibitory order under section\n132(3) of the Act is not revoked within one month as per the CBDT’s\ndirective, any panchanama drawn thereafter loses its legal validity and\ncannot be considered for computing limitation under section 153B of the\nAct. The relevant finding of the Tribunal in said case reads

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, MANGALORE

1)\nSri K. Mohammed Haris, Director of M/s Mukka Sea\nFood Industries Pvt. Ltd. , a working Director of the\ncompany, in the statement recorded u/s 132(4) of the\nAct, in reply to Q.No.24 agreed that these are bogus\nentries in books.\n(2)\nSo, when ‘NO PURCHASE” was made, obviously there\nwas “NO SALE”. So, there

M/S. HARIS MARINE PRODUCTS,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, MANGALORE

In the result, both the appeals of the assessee are\nallowed

153 of the Act. By virtue of the 2017 Amending\nAct, significant amendments came to be introduced in Section\n153A. These included, inter alia, the search assessment block\nbeing enlarged to ten AYs' consequent to the addition of the\nstipulation of “relevant assessment year” and which was\ndefined to mean those years which would fall beyond the six\nyear block

M/S. HARIS MARINE PRODUCTS,MANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALORE

In the result, both the appeals of the assessee are\nallowed

153 of the Act. By virtue of the 2017 Amending\nAct, significant amendments came to be introduced in Section\n153A. These included, inter alia, the search assessment block\nbeing enlarged to ten AYs' consequent to the addition of the\nstipulation of “relevant assessment year” and which was\ndefined to mean those years which would fall beyond the six\nyear block

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3) , BENGALURU

In the result, the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

1,55,60,250/- from M/s ExCom enterprises. 50. The first contention of the assessee is that assessment year 2018-19 is a concluded assessment which could have been disturbed only based on incriminating material found during search. If that be so the addition made by the ld AO of Bogus purchases did not arise from the incriminating material

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3) , BENGALURU

In the result, the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

1,55,60,250/- from M/s ExCom enterprises. 50. The first contention of the assessee is that assessment year 2018-19 is a concluded assessment which could have been disturbed only based on incriminating material found during search. If that be so the addition made by the ld AO of Bogus purchases did not arise from the incriminating material

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

1,55,60,250/- from M/s ExCom enterprises. 50. The first contention of the assessee is that assessment year 2018-19 is a concluded assessment which could have been disturbed only based on incriminating material found during search. If that be so the addition made by the ld AO of Bogus purchases did not arise from the incriminating material

DCIT, CENTRAL CIRCLE-1(3), BAENGALURU vs. LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA), BENGALURU

In the result, the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

1,55,60,250/- from M/s ExCom enterprises. 50. The first contention of the assessee is that assessment year 2018-19 is a concluded assessment which could have been disturbed only based on incriminating material found during search. If that be so the addition made by the ld AO of Bogus purchases did not arise from the incriminating material

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

153 or section 153B thereof, expires on the 30th day of April, 2021 due to its extension by the said notifications, such time limit shall further stand extended to the 30th day of June, 2021; (b) the completion of any action, referred to in clause (a) of sub-section (1) of section 3 of the said Act, relates to passing

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall