MAHESH REDDY ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE

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

capital gains\nof Rs.7,12,17,657/- on which deduction of Rs.4,82,00,000/- had\nbeen claimed u/s 54F of the IT Act. The assessee has not made any\nsubmissions regarding the alternative claim made in place of the\nclaim already made in the return, nor has he submitted the details\nof deduction claimed u/s 54F therefore, the claim

MAHESH REDDY,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-2, BENGALURU

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

capital gains\nof Rs.7,12,17,657/- on which deduction of Rs.4,82,00,000/- had\nbeen claimed u/s 54F of the IT Act. The assessee has not made any\nsubmissions regarding the alternative claim made in place of the\nclaim already made in the return, nor has he submitted the details\nof deduction claimed u/s 54F therefore, the claim

ROOPA JAGADISH ,MYSURU vs. ACIT, CIRCLE-1(1), MYSURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2012-13

capital gains by adopting the cost at Rs 1,790/ based on the valuation report given by a valuer. The AO accepted the computation and passed an order on 27/03/2015. The CIT revised the assessment u/s 263

BSNL EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LIMITED ,HUBBALLI vs. PR. CIT, HUBBALLI , HUBBALLI

In the result the appeal filed by the assessee is allowed

263 of the Act does not visualize a case of\nsubstitution of the judgment of the Commissioner for that of the subordinate\nauthority who passed the order which is sought to be revised. The Order passed by\na subordinate authority in exercise of its quasi-judicial power vested in him in\naccordance with law, cannot be termed erroneous merely because

VAIDYA SRIKANTAPPA SADASHIVAIAH SRIKANTH,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE- 1, , BANGALORE

revision and therefore the order passed by the\nlearned Principal Commissioner of Income-tax, Bangalore is ultra vires to\nthe scope of Section 263 and requires to be cancelled under the facts and\ncircumstances of the Appellant's case.\n3. The Hon'ble Pr. CIT is not justified in invoking the provision u/s 263 and\nholding that the order passed

ADARSHA SOUHARDA SAHAKARI NIYAMIT SIRSI,SIRSI vs. PR. COMMISSIONER OF INCOME TAX, , HUBALLI

In the result the appeal filed by the assessee is allowed

263 of the Act does not\nvisualize a case of substitution of the judgment of the\nCommissioner for that of the subordinate authority who passed the\norder which is sought to be revised. The Order passed by a\nsubordinate authority in exercise of its quasi-judicial power vested\nin him in accordance with law, cannot be termed erroneous merely\nbecause

SRI RAMASEVA BAHUSARA KSHARIYA CO-OP. SOCIETY LIMITED,SHIMOGA vs. PR. CIT, BENGALURU-1, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21 M/S. Sri Ramaseva Bahusara Kshariya Co-Op. Society Ltd. 01, Ramanna Setty Park Spm Road, Doddapete So Vs. Principal Cit Shimoga 577 202 Bengaluru-1 Karnataka Pan No :Aaajs0083P Appellant Respondent Appellant By : Sri V. Srinivasan, A.R. Respondent By : Sri Kiran D., D.R. Date Of Hearing : 11.12.2025 Date Of Pronouncement : 30.01.2026

263 of the Act does not visualize a case of substitution of the judgment of the Commissioner for that of the subordinate authority who passed the order which is sought to be revised. The Order passed by a subordinate authority in exercise of its quasi-judicial power vested in him in accordance with law, cannot be termed erroneous merely because

BHARATH CREDIT CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. PR. CIT, BANGALORE -1, BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2020-21

263 of the Act does not visualize a case of substitution of the judgment of the Commissioner for that of the subordinate authority who passed the order which is sought to be revised. The Order passed by a subordinate authority in exercise of its quasi-judicial power vested in him in accordance with law, cannot be termed erroneous merely because

GONIKOPPAL PRIMARY RURAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-3, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

263 of the Act does not visualize a case of substitution of the judgment of the Commissioner for that of the subordinate authority who passed the order which is sought to be revised. The Order passed by a subordinate authority in exercise of its quasi- M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 25 of 31 judicial power vested

BHAVANA CO-OP CREDIT SOCIETY NIYAMITA ,SIRSI vs. INCOME TAX OFFICER, WARD-1, SIRSI

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

263 of the Act does not visualize a case of substitution of the judgment of the Commissioner for that of the subordinate authority who passed the order which is sought to be revised. The Order passed by a subordinate authority in exercise of its quasi- M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 25 of 31 judicial power vested

CISCO SYSTEMS (INDIA) PRIVATE LIMITED,BANGALORE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 2, KORAMANGALA, BANGALORE

In the result, the appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

u/s 143(3) r.w.s. 44AB dated 29.12.2022 is set aside for the purpose of making a fresh assessment in accordance with law. The AO is directed to revise the assessment after verifying thoroughly the assessee’s claims of re-measurement of post-employment benefit obligations and foreign exchange gains realized on payment towards capital creditors for the purchase of fixed

MUTHYALA SURYABABU,BENGALURU vs. PR. COMMISSIONER OF INCOME TAX, BANGALORE-1, BANGALORE

In the result appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2020-21

capital gain (LTCG), a sum of Rs.10,42,815/- expended towards “Arrears of Property Tax” as cost against the above sale consideration, had been allowed. The ld. PCIT is of the opinion that the above expenditure towards property tax arrears would neither qualified as cost of acquisition nor as cost of improvement and thus the same need to be disallowed

SRI GURU RAMALINGESHWARA SOUHARDA PATTINA SAHAKARI NIYAMITHA ,MASKI vs. PR. COMMISSIONER OF INCOME TAX , HUBLI

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2020-21

revised under section 263 of the Act merely Page 9 of 12 because the Principal Commissioner holds a different opinion. The revisionary jurisdiction under section 263 of the Act cannot be exercised to substitute the view of the ld. PCIT for that of the AO. In holding so, we draw support and guidance from the landmark judgment

SPARKLE ESTATES PRIVATE LIMITED ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-1, BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Years : 2017-18

revised the circle rate only after the from 1/4/2016 i.e. transfer of right in the land by the assessee in M/s KEHBC. At last, the counsel for the assessee argued that the impugned sale deeds which are considered by the PCIT, Bangalore for assuming jurisdiction of 263 are in fact executed by M/s KEHBC in the capacity of seller

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued. Pursuant to the said notice, the assessee filed the revised return of income showing higher income. The said return of income was accompanied by a note in which the assessee submitted that he surrendered

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued. Pursuant to the said notice, the assessee filed the revised return of income showing higher income. The said return of income was accompanied by a note in which the assessee submitted that he surrendered

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued. Pursuant to the said notice, the assessee filed the revised return of income showing higher income. The said return of income was accompanied by a note in which the assessee submitted that he surrendered

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued. Pursuant to the said notice, the assessee filed the revised return of income showing higher income. The said return of income was accompanied by a note in which the assessee submitted that he surrendered

SRI MUNIRAJU KEMPANNA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(4), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

263, wherein no enquiry was conducted by Ld.AO, as was discerned by him from assessment records. 32. In decision relied on by Ld.AR of Hon’ble Bombay High Court in case of CIT vs Slum Rehabilitation Authority (supra), Hon’ble Court considered the issue in case of trust, wherein, facts were that, assessee therein challenged revision order before Mumbai Tribunal