INCOME TAX OFFICER, WARD-1, SHIVAMOGGA, SHIVAMOGGA vs. SUVARNA, SHIVAMOGGA

In the result, the appeal of the revenue is allowed for statistical purposes

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadavassessment Year : 2021-22

201. PAN: HCDPS 6641R APPELLANT RESPONDENT Appellant by : Shri C. Ramesh, CA Respondent by : Shri E. Sridhar, CIT(DR)(ITAT), Bengaluru. Date of hearing : 20.01.2025 Date of Pronouncement : 27.01.2025 O R D E R Per Prakash Chand Yadav, Judicial Member The present appeal of the revenue is arising out of the order of the ld. CIT(Appeals), National Faceless Appeal

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU vs. HIREHAL JAIRAJ BALRAM, BENGALURU

In the result, appeal filed by the assessee is allowed for statistical\npurposes

201.\nPAN: AFAPC 4016 M\nAPPELLANT\nVs.\nDCIT,\nCentral Circle – 1(1),\nBangalore.\nRESPONDENT\nAssessee by\n: Shri. T. Srinivasa, CA\nRevenue by\n: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore.\nDate of hearing\n: 19.11.2025\nDate of Pronouncement: 18.12.2025\nORDER\nPer Laxmi Prasad Sahu, Accountant Member :\nThis is an appeal filed by the assessee against the Order passed

THE HAMLET,BANGALORE vs. THE INCOME-TAX OFFICER-WARD-6(2)(4), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2012-13 M/S. The Hamlet, No. 11, Kemwell House, The Income Tax Tumkur Road, Officer, Yeshwanthpur, Ward – 6(2)(4), Bangalore – 560 022. Bangalore. Vs. Pan: Aaaft6690D Appellant Respondent Assessee By : Shri H.N. Kincha, Ca : Shri D.K. Mishra, Cit - Revenue By Dr Date Of Hearing : 24-08-2023 Date Of Pronouncement : 16-11-2023 Order Per Beena Pillaipresent Appeal Arises Out Of The Order Dated 27.12.2022 Passed By The Nfac, Delhi For A.Y. 2012-13 On Following Grounds Of Appeal: “1. The Learned Commissioner Of Income Tax (Appeals) Has Erred In Passing The Appellate Order In The Manner Passed. The Appellate Order As Passed Is Bad In Law & Is Liable To Be Quashed. 2. In Any Case, The Learned Commissioner Of Income Tax (Appeals) Has Erred In Confirming The Assessment Order Passed By The Learned Assessing Officer. On The Facts & Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeals) Should Have Quashed, The Order Passed By Assessing Officer Or Atleast Should Have Deleted The Additions Made By The Assessing Officer.

bogus Page 12 of 52 M/s. The Hamlet, Bangalore share capital/bogus share premium, which was used for routing funds through web of bank transactions. The Ld.AR submitted that, based on a borrowed satisfaction, the Ld.AO also doubted the sale of shares by assessee that another two companies by the name M/s. Swift Residency Pvt. Ltd. and M/s. Rootstart Builders

GANGOTHRI VENTURES,BANGALORE vs. INCOME-TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2018-19

Purchase of immovable property Rs.7,26,32,800/- Rs.8,44,24,940/- Gross alleged escapement of Income. 3.2 He submitted that the Assessee in response to the show cause notice has filed the submissions on 14.12.2022, 21.12.2022, 24.12.2022, 21.01.2023 and 13.02.2023. However, the NFAC has not appreciated the submissions and documents furnished and ultimately it was held that the Assessee

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

purchases, is non-existent in the present case. In the said\ncase, there was a factual finding to the effect that the Assessees were habitual\noffenders, indulging in clandestine operations whereas there is nothing in the\npresent case, whatsoever, to suggest that any statement made by Mr. Anu\nAggarwal or Mr. Harjeet Singh contained any such admission.”\n5.6 Further

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

201 Hassan PAN NO : AAEFS4881R APPELLANT RESPONDENT Assessee by : Shri C. Ramesh, A.R. Revenue by : Ms. Neera Malhotra, D.R. Date of Hearing : 15.05.2024 Date of Pronouncement : 10.06.2024 ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 2 of 104 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: ITA Nos.1163 to 1165/Bang/2023 filed by the revenue

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

201 Hassan PAN NO : AAEFS4881R APPELLANT RESPONDENT Assessee by : Shri C. Ramesh, A.R. Revenue by : Ms. Neera Malhotra, D.R. Date of Hearing : 15.05.2024 Date of Pronouncement : 10.06.2024 ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 2 of 104 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: ITA Nos.1163 to 1165/Bang/2023 filed by the revenue

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

201 Hassan PAN NO : AAEFS4881R APPELLANT RESPONDENT Assessee by : Shri C. Ramesh, A.R. Revenue by : Ms. Neera Malhotra, D.R. Date of Hearing : 15.05.2024 Date of Pronouncement : 10.06.2024 ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 2 of 104 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: ITA Nos.1163 to 1165/Bang/2023 filed by the revenue

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

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

201 Hassan PAN NO : AAEFS4881R APPELLANT RESPONDENT Assessee by : Shri C. Ramesh, A.R. Revenue by : Ms. Neera Malhotra, D.R. Date of Hearing : 15.05.2024 Date of Pronouncement : 10.06.2024 ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 2 of 104 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: ITA Nos.1163 to 1165/Bang/2023 filed by the revenue

INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

201 Hassan PAN NO : AAEFS4881R APPELLANT RESPONDENT Assessee by : Shri C. Ramesh, A.R. Revenue by : Ms. Neera Malhotra, D.R. Date of Hearing : 15.05.2024 Date of Pronouncement : 10.06.2024 ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 2 of 104 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: ITA Nos.1163 to 1165/Bang/2023 filed by the revenue

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

purchases, is non-existent in the present case. In the said\ncase, there was a factual finding to the effect that the Assessees were habitual\noffenders, indulging in clandestine operations whereas there is nothing in the\npresent case, whatsoever, to suggest that any statement made by Mr. Anu\nAggarwal or Mr. Harjeet Singh contained any such admission.”\n5.6 Further

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are\npartly allowed and ITA No

section 131 or 132(4) cannot\nbe termed as information relating to investigation which the assessing\nofficer has no obligation to share. Copies of statements obtained under\nsections 131 or 132(4) should necessarily be furnished to the assessee. If\nthe same have not been furnished it means that the same have not been\nrelied upon. The Hon'ble Apex

INDEPENDENT AND PUBLIC SPIRITED MEDIA FOUNDATION ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, (CENTRAL), BENGALURU

In the result appeal of the assessee is dismissed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : Na

201 EXCISE LAW TIMES 513 (SC) [2006] 2006 taxmann.com 1488 [ SC) stating that allegation in the show cause notice should be very definite and then the adjudicating authority cannot go out of that show cause notice. Thus, his argument was that the allegation cannot be enlarged after the issue of the show cause notice while adjudicating the issue

SUHAS RAMESH RAO RANGADHOL ,SHIVAMOGGA vs. INCOME TAX OFFICER, WARD-2, SHIMOGA

In the result, we direct the Ld

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year :2017-18 Sri Suhas Ramesh Rao Rangadhol, Seetharama Sadana, Beside Adhichunchanagiri The Income Tax Officer, Samudaya Bhavana, Ward-4, Vs. Sharavathi Nagar,Shivamogga, Shimoga. Karnataka – 577 201. Pan: Agopr8445C Appellant Respondent

201. PAN: AGOPR8445C APPELLANT RESPONDENT Assessee by : Shri Narendra Sharma, Advocate : Shri Ganesh R Ghale, Advocate - Revenue by Standing Counsel for Revenue Date of Hearing : 26-11-2025 Date of Pronouncement : 09-02-2026 ORDER PER PRASHANT MAHARISHI, VICE – PRESIDENT 1. ITA No. 1912/Bang/2025 is filed by Sri Suhas Ramesh Rao Rangadhol (the Assessee/Appellant) for Assessment Year 2017-18 against