M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

e d t h a t n o investment/ development activity can be carried out in the SEZ unit without approval of development officer which is obtained only in Financial year 2017-18 (15.06.2017). Moreover, MOU was entered on 29.03.2017 i.e 2 days prior to the financial year end. It would be irrational to estimate the investment

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

e d t h a t n o investment/ development activity can be carried out in the SEZ unit without approval of development officer which is obtained only in Financial year 2017-18 (15.06.2017). Moreover, MOU was entered on 29.03.2017 i.e 2 days prior to the financial year end. It would be irrational to estimate the investment

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

e d t h a t n o investment/ development activity can be carried out in the SEZ unit without approval of development officer which is obtained only in Financial year 2017-18 (15.06.2017). Moreover, MOU was entered on 29.03.2017 i.e 2 days prior to the financial year end. It would be irrational to estimate the investment

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

e d t h a t n o investment/ development activity can be carried out in the SEZ unit without approval of development officer which is obtained only in Financial year 2017-18 (15.06.2017). Moreover, MOU was entered on 29.03.2017 i.e 2 days prior to the financial year end. It would be irrational to estimate the investment

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

e d t h a t n o investment/ development activity can be carried out in the SEZ unit without approval of development officer which is obtained only in Financial year 2017-18 (15.06.2017). Moreover, MOU was entered on 29.03.2017 i.e 2 days prior to the financial year end. It would be irrational to estimate the investment

INTACT DEVELOPERS PRIVATE LIMITED ,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

E R PER KESHAV DUBEY, JUDICIAL MEMBER: These appeals at the instance of the assessee are directed against the consolidated order of the ld. CIT(A)-11, Bengaluru, dated 10.02.2025 vide DIN : ITBA/APL/M/250/2024- 25/1073061567(1) for the AY 2015-16; vide DIN: ITBA/APL/M/250/2024-25/1073061747(1) for the AY 2016-17 and vide DIN : ITBA/APL/M/250/2024-25/1073061874(1) for the AY 2017-18 passed

INTACT DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

E R PER KESHAV DUBEY, JUDICIAL MEMBER: These appeals at the instance of the assessee are directed against the consolidated order of the ld. CIT(A)-11, Bengaluru, dated 10.02.2025 vide DIN : ITBA/APL/M/250/2024- 25/1073061567(1) for the AY 2015-16; vide DIN: ITBA/APL/M/250/2024-25/1073061747(1) for the AY 2016-17 and vide DIN : ITBA/APL/M/250/2024-25/1073061874(1) for the AY 2017-18 passed

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

e date of search till\nthe end of the previous year i.e. 31.3.2006.\"\n5.14 In the case of CIT Vs. President Industries, reported in\n258 ITR 654, the Hon'ble Gujarat High Court held as under:\n\"In the course of survey conducted in the premises of assessee, excise records were found\nwhich disclosed godown sales not disclosed

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

e. The Appellant cannot be held responsible for the cash drawals of the vendors. f. The LAO and CIT(A) did not adduce any evidence to demonstrate that the purchases were bogus apart from the statement of Sri Janardhan. No efforts have been made by the LAO and CIT(A) to demonstrate that the purchases were bogus. g. The fact

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

e. The Appellant cannot be held responsible for the cash drawals of the vendors. f. The LAO and CIT(A) did not adduce any evidence to demonstrate that the purchases were bogus apart from the statement of Sri Janardhan. No efforts have been made by the LAO and CIT(A) to demonstrate that the purchases were bogus. g. The fact

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

e. The Appellant cannot be held responsible for the cash drawals of the vendors. f. The LAO and CIT(A) did not adduce any evidence to demonstrate that the purchases were bogus apart from the statement of Sri Janardhan. No efforts have been made by the LAO and CIT(A) to demonstrate that the purchases were bogus. g. The fact

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

e. The Appellant cannot be held responsible for the cash drawals of the vendors. f. The LAO and CIT(A) did not adduce any evidence to demonstrate that the purchases were bogus apart from the statement of Sri Janardhan. No efforts have been made by the LAO and CIT(A) to demonstrate that the purchases were bogus. g. The fact

M/S ANANTHA REFINERY PVT. LTD. vs. DCIT,

In the result, both the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

E R PER CHANDRA POOJARI, A.M: The assessee originally came in appeal before this Tribunal in ITA Nos.1553, 1554 & 1555/Bang/2013 for the AYs.2006-07, 2007-08 & 2011-12, wherein the assessee raised various grounds with regard to the additions made by the AO in these assessment years with regard to bogus purchases. 2. The facts relating to AY.2006-07

M/S ANANTHA REFINERY PVT. LTD. vs. DCIT,

In the result, both the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

E R PER CHANDRA POOJARI, A.M: The assessee originally came in appeal before this Tribunal in ITA Nos.1553, 1554 & 1555/Bang/2013 for the AYs.2006-07, 2007-08 & 2011-12, wherein the assessee raised various grounds with regard to the additions made by the AO in these assessment years with regard to bogus purchases. 2. The facts relating to AY.2006-07

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

2,04,92,250/- and Grishneshwar Engineers Pvt. Ltd. of Rs. 1,55,60,250/-, so why this amount should not be added u/s 69C of the Act. ITA Nos.410-412-169-170- CO 6/Bang/2024 Page 6 of 40 (vii) Therefore, assessee was asked that why the addition of unaccounted cash sales, unaccounted bogus purchases could not be added to the income

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

2,04,92,250/- and Grishneshwar Engineers Pvt. Ltd. of Rs. 1,55,60,250/-, so why this amount should not be added u/s 69C of the Act. ITA Nos.410-412-169-170- CO 6/Bang/2024 Page 6 of 40 (vii) Therefore, assessee was asked that why the addition of unaccounted cash sales, unaccounted bogus purchases could not be added to the income

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

2,04,92,250/- and Grishneshwar Engineers Pvt. Ltd. of Rs. 1,55,60,250/-, so why this amount should not be added u/s 69C of the Act. ITA Nos.410-412-169-170- CO 6/Bang/2024 Page 6 of 40 (vii) Therefore, assessee was asked that why the addition of unaccounted cash sales, unaccounted bogus purchases could not be added to the income

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

2,04,92,250/- and Grishneshwar Engineers Pvt. Ltd. of Rs. 1,55,60,250/-, so why this amount should not be added u/s 69C of the Act. ITA Nos.410-412-169-170- CO 6/Bang/2024 Page 6 of 40 (vii) Therefore, assessee was asked that why the addition of unaccounted cash sales, unaccounted bogus purchases could not be added to the income

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