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

section 69C of the Act. Accordingly, he made an addition of ₹ 43,815,000 as bogus purchases u/s. 69C of the Act for AY 2018–19. 16. Consequently

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

section 69C of the Act. Accordingly, he made an addition of ₹ 43,815,000 as bogus purchases u/s. 69C of the Act for AY 2018–19. 16. Consequently

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

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

bogus purchases are required\nto be added to the total income of the assessee under section 69C of\nthe Act. Accordingly

SWAMY HOLAGUNDI,HUVINA HADAGALI vs. INCOME TAX OFFICER, WARD-1 & TPS, HOSPET

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2018-19 Swamy Holagundi Prop: Raviteja Traders 7C/10, 3Rd Ward Ito Bangarappanagar Vs. Ward-1 & Tps Karnataka 583 219 Hospet Pan: Dwjps7047P Appellant Respondent Appellant By : Sri V. Srinivasan, Advocate, A.R Respondent By : Sri Subramanian S., Jcit D.R. Date Of Hearing : 08.05.2025 Date Of Pronouncement : 05.08.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Cit(A)/Nfac Dated 19.07.2024Vide Din & Order No. Itba/Nfac/S/250/2-24-25/1066829871(1) Passed U/S.250 Of The Income Tax Act, 1961 (In Short “The Act”) For The Assessment Year 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal: -

bogus, it is obvious that the purchases which led to sales/closing stock have been done out of books and the same amounts to unexplained expenditure and accordingly the entire purchases from M/s Sri Sai baba Rice industries wastreated as unexplained expenditure and disallowed under section 69C

ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION) CIRCLE-1, BENGALURU vs. COSMOPOLIS EDUCATIONAL TRUST, BENGALURU

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2021-22

purchase consideration of school EPS and remaining amount of Rs. 41,85,16,746/- was transferred or credited to corpus/capital found account. 6. In addition to the above, the assessee trust has received inter- trust funds of Rs. 20,22,96,029/- throughout the year from the schools . Page 3 of 24 run by M/s CET for construction its school

M/S. MUKKA PROTENIS LIMITED,MANGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL, BANGALORE

In the result, the appeal filed by the assessee stands dismissed

bogus purchases and additional income on account of alleged difference in Stock. Page 4 2.4 For the year under consideration, assessee filed its return of income on 23/11/2018 declaring total income of Rs.17,78,99,390/-, wherein the assessee declared income on account of inflated purchases and also on account of alleged difference in stock amounting to only Rs.5

EXCELLENT POWER CONTROLS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, not the full amount. 7. It was also submitted by the assessee that there is no dispute regarding the source of payment for the impugned purchases. Therefore, such payments cannot be classified as unexplained expenditure under the provisions of Section 69C

EXCELLENT POWER CONTROLS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1(, BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, not the full amount. 7. It was also submitted by the assessee that there is no dispute regarding the source of payment for the impugned purchases. Therefore, such payments cannot be classified as unexplained expenditure under the provisions of Section 69C

EXCELLENT POWER CONTROLS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

bogus purchases, not the full amount. 7. It was also submitted by the assessee that there is no dispute regarding the source of payment for the impugned purchases. Therefore, such payments cannot be classified as unexplained expenditure under the provisions of Section 69C

INCOME TAX OFFICER, WARD-1 & TPS, SHIVAMOGGA vs. HANUMANTHAPPA PATHRERA LAXMANA, SHIVAMOGGA

In the result, the assessee’s appeal is partly allowed whereas the Revenue’s appeal is dismissed

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmedassessment Year: 2020-21

69C of the Act. 3.1 Similarly. the AO further noted that the assessee has shown high amount of liabilities in the balance sheet whereas it has shown low- . ITA No.247 & 1066/Bang/2025 Page 3 of 8 income /receipt in the income tax return and therefore the AO added sundry creditors of ₹8.62 crores, treating them as unexplained liabilities. On appeal

HANUMANTHAPPA PATHRERA LAXMANA,SHIVAMOGGA vs. INCOME TAX OFFICER, WARD-(1) & TPS, SHIMOGGA

In the result, the assessee’s appeal is partly allowed whereas the Revenue’s appeal is dismissed

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmedassessment Year: 2020-21

69C of the Act. 3.1 Similarly. the AO further noted that the assessee has shown high amount of liabilities in the balance sheet whereas it has shown low- . ITA No.247 & 1066/Bang/2025 Page 3 of 8 income /receipt in the income tax return and therefore the AO added sundry creditors of ₹8.62 crores, treating them as unexplained liabilities. On appeal

DRESS CODE ,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishiassessment Year : 2018-19

section 69C of the Act amounting to Rs.18,69,992 and the learned CIT(A) has erred in confirming such addition. 3. The learned AO and the learned CIT(A) have erred in concluding that purchases made by the Appellant from M/s. Manjunatha Marketing aggregating to Rs.18,69,992 are bogus

TABESCO HINDUSTAN INFRA DEVELOPERS PVT LTD., ,KERALA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , MANGALORE

In the result, appeals of the assessee in ITA Nos

bogus shareholders through\nbanking channels that as disputed. There were no countering\nevidences with the department in the form of seized materials etc in\nthat case to disprove the claim. Further, the ratio arrived at in the\naforesaid case have been nullified by a specific amendment to\nsection 68 vide Finance Act 2012. None of the above facts apply

NAVUNDA ABDULLA BADRUDDIN,UDUPI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL, BANGALORE

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

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.Shri Navunda Abdulla Badruddin Vs Pcit, Central O Thuwfeeq Manzil C.R. Building, Queen'S Road Maski Navunda, Kundapur Bengaluru 560001 Udupi 576224 Pan – Aevpa6893G (Appellant) (Respondent) Assessee By: Shri V. Narendra Sharma, Advocate Revenue By: Shri Manjunath Karkihalli, Cit-Dr Date Of Hearing: 14/09/2022 Date Of Pronouncement: 20/09/2022 O R D E R Per: Padmavathy, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Principal Commissioner Of Income Tax(Pcit) U/S.263 Of The Income Tax Act 1961 (The Act), Bangalore In Appeal No. 263/Pr.Cit(C)/2001-02 Dated 28.03.2022 For Ay 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “1. The Order Of Revision Passed By The Learned Principal Commissioner Of Income Tax [Central], Bengaluru, Under Section 263 Of The Act Dated 28/03/2022, In So Far As It Is Against The Appellant Is Opposed To Law, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Appellant'S Case. 2. The Learned Principal Commissioner Of Income Tax Is Not Justified In Law & On Facts To Set Aside The Assessment Order Passed Under Section 143[3] R.W.S. 153D Of The Act Dated 19/12/2019 & Direct

69C of the Act and should have been taxed under Section 115BBE of the Act and since the AO is did not enquire or verify the said expenditure the order of the AO is erroneous and prejudicial to the interest of Revenue to that extent. 7. Before us the learned A.R. reiterated the submissions made before the lower authorities

MKH INFRASTRUCTURE,KERALA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

bogus shareholders through\nbanking channels that as disputed. There were no countering\nevidences with the department in the form of seized materials etc in\nthat case to disprove the claim. Further, the ratio arrived at in the\naforesaid case have been nullified by a specific amendment to\nsection 68 vide Finance Act 2012. None of the above facts apply

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

TEXAS INSTRUMENTS (INDIA) PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

In the result, the appeal by the revenue is dismissed and the appeal by the assessee is partly allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

69C of the Act have be looked into afresh. The AO will afford opportunity of being heard to the assessee in the set aside proceedings. 65. Ground No.9 raised by the assessee reads as follows: 9. Disallowance of information technology support services 9.1 The learned CIT(A) and the AO have erred in law and on facts in disallowing

JOINT COMMISIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S TEXAS INSTRUMENTS INDIA PVT LTD , BANGALORE

In the result, the appeal by the revenue is dismissed and the appeal by the assessee is partly allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

69C of the Act have be looked into afresh. The AO will afford opportunity of being heard to the assessee in the set aside proceedings. 65. Ground No.9 raised by the assessee reads as follows: 9. Disallowance of information technology support services 9.1 The learned CIT(A) and the AO have erred in law and on facts in disallowing