M/S. BANGALORE ELECTRICITY SUPPLY COMPANY LTD.,,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2), BANGALORE

In the result, the appeal by the assessee is partly allowed and appeal of the ld

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

bogus expenses, as assessee is bound by KERC rates. It was noted by him that this is one of the issues on the side of the liability. And there may be many such issues. As assessee failed to provide all the details, the learned that AO presumed that some expenses are ceased to exist for the year under consideration

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE- 1(1)(1), BANGALORE, BMTC BUILDING, KORAMANGALA, BAQNGALORE vs. BANGALORE ELECTRICITY SUPPLY COMPANY LIMITED , BESCOM CORPORATE OFFICE

In the result, the appeal by the assessee is partly allowed and appeal of the ld

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

bogus expenses, as assessee is bound by KERC rates. It was noted by him that this is one of the issues on the side of the liability. And there may be many such issues. As assessee failed to provide all the details, the learned that AO presumed that some expenses are ceased to exist for the year under consideration

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

vii. On bogus purchases, assessee submitted a reply stating that it is not made purchases from one of the entities where the assessing officer is alleging the purchase of ₹ 7,752,500. With respect to the other entities was submitted that the assessee has purchased goods from these parties who are having sales tax number or VAT number and payments

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

vii. On bogus purchases, assessee submitted a reply stating that it is not made purchases from one of the entities where the assessing officer is alleging the purchase of ₹ 7,752,500. With respect to the other entities was submitted that the assessee has purchased goods from these parties who are having sales tax number or VAT number and payments

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

vii. On bogus purchases, assessee submitted a reply stating that it is not made purchases from one of the entities where the assessing officer is alleging the purchase of ₹ 7,752,500. With respect to the other entities was submitted that the assessee has purchased goods from these parties who are having sales tax number or VAT number and payments

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

vii. On bogus purchases, assessee submitted a reply stating that it is not made purchases from one of the entities where the assessing officer is alleging the purchase of ₹ 7,752,500. With respect to the other entities was submitted that the assessee has purchased goods from these parties who are having sales tax number or VAT number and payments

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

bogus so as to disallow the same and brought to tax as\nundisclosed income of the assessee.\n5.7 Further, there was a CBDT circular file no.286/98/2013-IT\n(Inv.II) dated 18.12.2014 which states as under:\n“Instances/complaints of undue influence/coercion have come to notice of\nthe CBDT that some assessees were coerced to admit undisclosed income\nduring Searches/Surveys conducted

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

bogus so as to disallow the same and brought to tax as\nundisclosed income of the assessee.\n5.7 Further, there was a CBDT circular file no.286/98/2013-IT\n(Inv.II) dated 18.12.2014 which states as under:\n“Instances/complaints of undue influence/coercion have come to notice of\nthe CBDT that some assessees were coerced to admit undisclosed income\nduring Searches/Surveys conducted

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

vii) The materials never came from Maharashtra as attributed; & (viii) The bank accounts opening forms show different proprietors for the same concern. 6. After taking the above facts into consideration and for the elaborate reasons recorded in the respective assessment orders, the AO concluded the assessments u/s. 153A r.w.s.143(3) of the Act dated 13.02.2013, determining the assessee's incomes

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

vii) The materials never came from Maharashtra as attributed; & (viii) The bank accounts opening forms show different proprietors for the same concern. 6. After taking the above facts into consideration and for the elaborate reasons recorded in the respective assessment orders, the AO concluded the assessments u/s. 153A r.w.s.143(3) of the Act dated 13.02.2013, determining the assessee's incomes

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

DEPUTY COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE- 1(3), BANGALORE vs. SHRI. T. NADAKRISHNA, BANGALORE

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus purchase of Rs.27,49,31,180/- from various concerns for which Shri Suresh Gowda, Executive Director of the company agreed and offered additional income of Rs.9.96 crores in the hands of SPR Group Holdings Pvt. Ltd. Vide his statement recorded u/s 132(4) of the Act on 9.2.2011 for the financial year 2008-09 to financial year ITA Nos.1658

M/S SPR SPIRITS PVT.LTD. ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1 (3) , BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus purchase of Rs.27,49,31,180/- from various concerns for which Shri Suresh Gowda, Executive Director of the company agreed and offered additional income of Rs.9.96 crores in the hands of SPR Group Holdings Pvt. Ltd. Vide his statement recorded u/s 132(4) of the Act on 9.2.2011 for the financial year 2008-09 to financial year ITA Nos.1658

M/S SPR SPIRITS PVT. LTD.,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1 (3), BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus purchase of Rs.27,49,31,180/- from various concerns for which Shri Suresh Gowda, Executive Director of the company agreed and offered additional income of Rs.9.96 crores in the hands of SPR Group Holdings Pvt. Ltd. Vide his statement recorded u/s 132(4) of the Act on 9.2.2011 for the financial year 2008-09 to financial year ITA Nos.1658

M/S SPR SPIRITS PVT. LTD.,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1 (3) , BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

bogus purchase of Rs.27,49,31,180/- from various concerns for which Shri Suresh Gowda, Executive Director of the company agreed and offered additional income of Rs.9.96 crores in the hands of SPR Group Holdings Pvt. Ltd. Vide his statement recorded u/s 132(4) of the Act on 9.2.2011 for the financial year 2008-09 to financial year ITA Nos.1658