SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

153D has been granted\nin a mechanical manner and without application of mind and\nthus it is invalid and bad in law and consequently vitiated the\nassessment order for want of valid approval u/s 153D of the\nAct.\nIn view of the above discussion, we hold that the order passed u/s\n153A r.w.s.43(3) has to be quashed, thus ordered

SHRI VANKADARI CHINNA REDDEPPA CHETTY ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(1) , BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2013-14

section 143(3) proceedings on the income from the same property would be against the principal of estoppel and consistency which has been affirmed in the following rulings: a. Dalmia Promoters Developers (P.) Ltd. (151 Taxman 202) - refer page 1 of the CLC. b. NeoPoly Pack (P.) Ltd. (112 Taxman 363)-refer page 8 of the CLC. c. Man Mohan

M/S. CONCORDE HOUSING CORPORATION PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

capital gain earned was as genuine but no heed was given thereon and without carrying any independent inquiry the penalty was imposed solely relying on the statement of applicant. For the purpose of levying penalty u/s 271(1)(c) of the Act, the concealment of income has to be independently established by the other evidences and not on the basis

SHRI. KEMPAREDDY GOVINDRAJ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BENGALURU

In the result the appeals of the assessee in ITA No’s 1022 to \n1024/ Bang/ 2024, for the

capital gain. Therefore, \nthere can be no protective assessment.” \n\nIn view of the above judicial precedents, the entire protective addition \nof Rs.86,95,409/- made in the hands of the assessee, in the absence of a \nsubstantive addition in the hands of his wife, is also bad in law and \nneeds to be deleted. \n\nIn any case

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

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

gain of the individuals involved.\nThere is no proof that the trust authorized such collections or payments.\n12.5 The learned AR pointed out that the appellant requested copies of\nstatements of parents and students recorded during the search, but\nthese were not provided on the reason that they were not being used\nagainst the assessee. This indicates that the statements

M/S. SRI. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES(REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

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

gain of the individuals involved.\nThere is no proof that the trust authorized such collections or payments.\n12.5 The learned AR pointed out that the appellant requested copies of\nstatements of parents and students recorded during the search, but\nthese were not provided on the reason that they were not being used\nagainst the assessee. This indicates that the statements

DCIT, CENTRAL CIRCLE-1(4), BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

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

gain of the individuals involved.\nThere is no proof that the trust authorized such collections or payments.\n12.5 The learned AR pointed out that the appellant requested copies of\nstatements of parents and students recorded during the search, but\nthese were not provided on the reason that they were not being used\nagainst the assessee. This indicates that the statements

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

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

gain of the individuals involved.\nThere is no proof that the trust authorized such collections or payments.\n12.5 The learned AR pointed out that the appellant requested copies of\nstatements of parents and students recorded during the search, but\nthese were not provided on the reason that they were not being used\nagainst the assessee. This indicates that the statements

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1(4), BENGALURU, BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD), KOLAR

gain of the individuals involved.\nThere is no proof that the trust authorized such collections or payments.\n12.5 The learned AR pointed out that the appellant requested copies of\nstatements of parents and students recorded during the search, but\nthese were not provided on the reason that they were not being used\nagainst the assessee. This indicates that the statements

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

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

gain of the individuals involved.\nThere is no proof that the trust authorized such collections or payments.\n12.5 The learned AR pointed out that the appellant requested copies of\nstatements of parents and students recorded during the search, but\nthese were not provided on the reason that they were not being used\nagainst the assessee. This indicates that the statements

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST ,KOLAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

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

gain of the individuals involved.\nThere is no proof that the trust authorized such collections or payments.\n12.5 The learned AR pointed out that the appellant requested copies of\nstatements of parents and students recorded during the search, but\nthese were not provided on the reason that they were not being used\nagainst the assessee. This indicates that the statements

SHRI. KEMPAREDDY GOVINDRAJ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3) , BENGALURU

In the result the appeals of the assessee in ITA No’s 1022 to\n1024/ Bang/ 2024, for the

153D of the\nAct.\n\n9. Aggrieved from the above Order, assessee filed appeal before\nthe ld. CIT(A) raising the legal issue as well as on merits of the case.\nThe assessee also filed written submissions on 28.01.2022 in detail\nwhich has been incorporated by the CIT(A) in his Order at Para No.6\nfrom page

SHRI. KEMPAREDDY GOVINDRAJ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BENGALURU

153D of the \nAct.\n\n9. Aggrieved from the above Order, assessee filed appeal before \nthe ld. CIT(A) raising the legal issue as well as on merits of the case. \nThe assessee also filed written submissions on 28.01.2022 in detail \nwhich has been incorporated by the CIT(A) in his Order at Para No.6 \nfrom page

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), QUEENS ROAD, BENGALURU vs. SHRI KEMPAREDDY GOVINDRAJU, DOMLUR, BENGALURU

153D of the\nAct.\n9. Aggrieved from the above Order, assessee filed appeal before\nthe ld. CIT(A) raising the legal issue as well as on merits of the case.\nThe assessee also filed written submissions on 28.01.2022 in detail\nwhich has been incorporated by the CIT(A) in his Order at Para No.6\nfrom page

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(3), BENGLAURU vs. SHRI KEMPAREDDY GOVINDRAJU, DOMLUR, BENGALURU

In the result the appeals of the assessee in ITA No’s 1022 to 1024/ Bang/ 2024, for the Assessment Years 2014-15, 2015-16 and 2016-17 are allowed and the appeals of the Revenue in ITA Nos

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

153D of the Act. 9. Aggrieved from the above Order, assessee filed appeal before the ld. CIT(A) raising the legal issue as well as on merits of the case. The assessee also filed written submissions on 28.01.2022 in detail which has been incorporated by the CIT(A) in his Order at Para No.6 from page

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

153D of the Act. 2.1 During the pendency of the assessment proceeding, Shri V.G. Sidhartha died as on 29th July 2019. In the assessment proceedings, several notices and show cause notices etc were issued which were replied by the legal heirs of late Shri V.G. Sidhartha. Finally, the AO came to finalized the assessment order for respective assessment years

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

153D of the Act. 2.1 During the pendency of the assessment proceeding, Shri V.G. Sidhartha died as on 29th July 2019. In the assessment proceedings, several notices and show cause notices etc were issued which were replied by the legal heirs of late Shri V.G. Sidhartha. Finally, the AO came to finalized the assessment order for respective assessment years