K A SUJIT CHANDAN,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE BENGALURU.-5(2)(1), BENGALURU

In the result all the three appeals in ITA Nos

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

154 of the Act was passed and the same was processed on 18/08/2022 by determining the total income of Rs.5,07,94,880/-. A search u/s. 132 of the Act was conducted on 23/02/2022 in the case of Komrala and Nanda Group of Companies, in the course of which the residential premise of the assessee at 66/1(164), Pranav, South

SHRI K.G SUBBARAMA SETTY ,BANGALORE vs. ACIT 5(2)(1) BANGALORE, C R BUILDING

In the result all the three appeals in ITA Nos

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

154 of the Act was passed and the same was processed on 18/08/2022 by determining the total income of Rs.5,07,94,880/-. A search u/s. 132 of the Act was conducted on 23/02/2022 in the case of Komrala and Nanda Group of Companies, in the course of which the residential premise of the assessee at 66/1(164), Pranav, South

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 4(1)(1), BANGALORE, BANGALORE vs. RAMESH NARAYANA REDDY (HUF), BANGALORE

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavdcit, Circle - 4(1)(1) Ramesh Narayana Reddy (Huf) Room No. 230, 2Nd Floor #62, Sonnenahalli Bmtc Building, Koramangala Vs. Mahadevapura Bangalore 560095 Bangalore 560048 Pan – Aamhr4231A (Appellant) (Respondent) Assessee By: Shri V. Srinivasan, Advocate Revenue By: Shri Subramanian S., Jcit-Dr Date Of Hearing: 24.07.2024 Date Of Pronouncement: 30.07.2024 O R D E R Per: Prakash Chand Yadav, J.M. The Present Appeal Of The Revenue Challenges The Din & Order No. Itba/Nfac/S/2003-24/1061428431(1) Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 23.02.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (The Act) In Respect Of Assessment Year (Ay) 2020-21. 2. Aggrieved With The Order Of The Ld. Cit(A) The Revenue Has Come Up In Appeal Before Us & Raised The Following Grounds: - “The Ld. Addl. Cit(A) Has Erred In Deleting The Addition Of Rs. 1,18,01,752 As Deemed Rental Income On The Ground That There Was No Addition Made In The Case Of Other Two Co-Owners Of The Same Property For The Same Assessment Year. The Nfac Has Not Considered That The Assessments Of Three Different Co-Owners Were Completed In Faceless Manner. There Is No Algorithm For Allocation Of Cases Of Three Different Assessees Having Common Interest In A Single Property To A Single Assessing Officer For Assessment. Hence, Omission Of Addition In Cases Of Other Two Co-Owners Of The Property Wherein Assesses Is An Owner May Be Because

154 taxmann.com 653 (Mum-Trib.) to contend that the deemed rent of unsold stock is to be computed notionally by the AO. In respect of the issue of gain to be taxed as LTCG or STCG the Ld DR has relied upon on the order of AO, similarly for the issue of hiring income from plant and machinery

M/S PARAMANAND AND SONS,BENGALURU vs. INCOME TAX OFFICER, WARD 5(2)(1), BENGALURU

In the result, the appeal of the assessee is allowed

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

capital gains remained unchanged at Rs. 3,58,312/-. 3. Against the intimation order, the assessee filed a rectification application under section 154

HANCHIPURA CHANNAIAH NANDAKISHORE,MAHALKSHMIPURAM vs. INCOME TAX OFFICER WARD INTL, TAXATION 1(2) BANGALORE, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.258/Bang/2025 Assessment Year : 2018-19 Hanchipura Channaiah Nandakishore 87, 2Nd Stage & Phase Mahalakshmipuram 2Nd Stage, 14Th Main, West Of Chord Ito Road Vs. Ward International Taxation 1(2) Mahalakshmipuram Bangalore Bangalore 560 086 Pan No :Blrpn0428A Appellant Respondent Appellant By : Sri Siddesh N Gaddi, A.R. Respondent By : Dr. Divya K.J., D.R. Date Of Hearing : 07.08.2025 Date Of Pronouncement : 04.11.2025

section 54/54F of the Act. The essence of the said provision is whether the assessee who received capital gains has invested in a residential house. Once it is demonstrated that the consideration received on transfer has been invested either in purchasing a residential house or in construction of a residential house even though the transactions are not complete

SHANTHA ALIAS SHANTHAMMA,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(4), BANGALORE

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

section 153C of the Act dated 07th September 2020.\nPage 5 of 22\nITA No.465/Bang/2025\n8. During the assessment proceeding, the AO was of the view that\nthe assessee should have offered the construction cost of 365 flats as\ncapital gain in JDA transaction with M/s SJR Prime Corporation Pvt in\nΑ.Υ. 2013-14 i.e. the JD agreement year

VINOD PRASAD INJETI ,BANGALORE vs. INCOME TAX OFFICER, WARD-2(3)(3), BANGALORE

In the result, we reverse the orders of the ld

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2014-15

section 154 of the Act only mistake apparent from record could have been rectified. Here, the ld. AO has tried to consider capital gain

M/S. PRAZIM TRADING AND INVESTMENT COMPANY PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2021-22 M/S. Prazim Trading & Investment Vs. Dcit, Company Private Limited, Circle – 3(1)(1), 574, Next To Wipro Corporate Office, Bengaluru. Sarjapur Road, Doddakkanelli, Bengaluru – 560 035. Pan : Aaacp 4921 G Appellant Respondent Assessee By : Shri. B. K. Manjunath, Ca Revenue By : Shri. Subramanian S, Addl. Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 02.05.2024 Date Of Pronouncement : 24.06.2024

154 of the Act by the Centralized Processing Center, which mistake was continuing from the intimation u/s 143(1) of the Act, being an erroneous addition of Rs. 4,93,34,784/- by the IT portal and imputing the same amount as income under the head "profits and gains of business or profession", even when the Appellant had no income

MR. HOTHUR MOHAMMED TAUSEEF,BELLARY vs. DCIT-CIRCLE-1, BELLARY

Bench: Shri Chandra Poojari & Shri Anikesh Banerjeeassessment Year : 2016-17 Shri Hothur Mohammed Tauseef, Sofia House, The Deputy Opp: State Bank Of Commissioner Of Mysore, Income Tax, Infantry Road, Circle – 1, Cantonment, Vs. Bellary. Bellary – 583 104. Pan: Acwpt0308C Appellant Respondent Assessee By : Shri B.S. Balachandran, A.R. Revenue By : Shri K. Sankar Ganesh, D.R. Date Of Hearing : 01-02-2023 Date Of Pronouncement : 21-03-2023 Order Per Anikesh Banerjee

section 50C as per the Act. Needless to say the assessee should get reasonable opportunity of hearing in set aside proceeding. Accordingly, Ground no. 2 is partly allowed for statistical purposes. 7. Ground no. 3 – Addition of LTCG for sale of land and building amounting to Rs.97,77,387/-. 7.1 Facts of the case are that as per Sale Deed

Y. SRINIVASA RAJU & COMPANY PRIVATE LIMITED ,BENGALURU vs. INCOME TAX OFFICER, WARD-7(1)(3), BANGALORE

Appeal of the assessee is allowed for statistical\npurposes

capital gains. Accordingly, the case of\nthe assessee was reopened by issue of notice under section\n148 of the Act on 30.03.2021. The assessee filed return by\ndeclaring income of Rs.1,41,52,230/-and in response to\nthat the Ld. Assessing Officer (“the Ld.AO”) issued notice\nunder section 143(2) of the Act. Consequently, the Ld. AO\nfound that

CANARA BANK,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

Bench: SHRI WASEEM AHMED, ACCOUNTANT MEMBER\nAND\nSHRI KESHAV DUBEY, JUDICIAL MEMBER\nITA No.210/Bang/2024\nAssessment Year: 2017-18\nM/s Canara Bank\nFM wing, Head Office,\n112, J.C. Road\nBangalore 560002\nVs.\nDCIT\nCircle-2(1)(1)\nBangalore\nPAN NO : AAACC6106G\nAPPELLANT\nRESPONDENT\nITA No.222/Bang/2024\nAssessment Year: 2017-18\nDCIT\nCircle-2(1)(1)\nBangalore\nVs.\nM/s Canara Bank\nFM wing, Head Office,\n112, J.C. Road\nBangalore 560 002\nAPPELLANT\nRESPONDENT\nITA No.1154/Bang/2023\nAsses

Capital Gain on Sale of shares of CanFin\nHome Ltd.\n9.\nDisallowance of Provision for Bad & Doubtful Debt u/s\n36(1)(viia) (viiu)\n10.\nShort Allowance of Tax Deducted at Source\n11.\nShort Allowance of Tax Paid by Overseas Branch u/s\n90/91\n12.\nApplicability of Provisions of MAT u/s 115JB\nTOTAL\n1,02,865\n703,92,01,889\n1569

PALLASANNA KRISHNA SUBRAMANIAN,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX , CIRCLE-4(2)(1), BENGALURU

In the result, the appeal of the assessee is allowed

capital gain, income from house property and income from other sources. The gross total income of the assessee was Rs.36,51,368/- and claimed deduction under Chapter VI A of Rs.1,10,000/-. Accordingly, the return of income declared of Rs.35,44,370/- and filed return of income on 29/07/2013. The return of income of the assessee was processed

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

Gain". The assessee did not receive the sum in question for giving up any source of income as the assessee was free to exploit independently owned IPR as well as Foreground information and therefore the argument that the sum received is capital receipt for losing a source of income and therefore not chargeable to tax, is devoid of any merits

INCOME TAX OFFICER, WARD-1(2)(1), BANGALORE vs. SHRI MUNI REDDY SANTHOSH REDDY, BENGALURU

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

Bench: Shri Chandra Poojariassessment Year: 2014-15

capital gain in a residential property and (b) construction of residential property within three years from date of transfer. Therefore, it is incorrect to invoke the provisions of section 154

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

capital gain was also earned on\nsale of shares of M/s Mindtree limited. We notice that, as in the earlier\nyear, the disallowance made by the assessee voluntarily is more than\nthe amount of exempted income. Hence, we are of the view that the\ndisallowance voluntarily made by the assessee would meet the\nrequirements of sec.14A of the Act. Accordingly

M/S. BHARAT ELECTRONICS LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

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

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahuassessment Year : 2012-13 M/S. Bharat Electronics The Assistant Ltd., Commissioner Of Registered Office, Income Tax, Outer Ring Road Ltu, Nagawara, Circle – 1, Vs. Bangalore – 560 045. Bangalore. Pan: Aaacb5985C Appellant Respondent

154 DTR 241 / 188 TTJ 1 (SB) (Delhi) (Trib.)  Dy.CIT v. Diamond Co. Ltd. (2017) 162 ITD 131 (Kol.) (Trib.)  Yashoda Health Care Services P. Ltd. v. DCIT (2017) 54 ITR 26 (Hyd.) (Trib.)  Electrosteel Castings Ltd. v. DCIT (2017) 53 ITR 5 (Kol.) (Trib.) 7. While calculating the disallowance under section 14A, only the investments that have generated exempt

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

capital gain was also earned on\nsale of shares of M/s Mindtree limited. We notice that, as in the earlier\nyear, the disallowance made by the assessee voluntarily is more than\nthe amount of exempted income. Hence, we are of the view that the\ndisallowance voluntarily made by the assessee would meet the\nrequirements of sec.14A of the Act. Accordingly

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, appeal of the revenue in ITA No

capital\nasset.\n3.22 The ld. A.R. further submitted that, if at all any substantive /\nprotective assessment is to be undertaken, at best it can be\nundertaken in the hands of SPR Developers. SPR Developers is the\nentity which entered into arrangements with various persons of the\nSri M Thimmegowda group, including Sri T Nadakrishna. for\naggregating lands for onward development