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

164), Pranav, South Cross Road, Basavangudi, Bengaluru-560004 was covered. Thereafter, the case was centralized with the Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru vide order u/s. 127 of the Act dated 05/03/2022 of the Principal Commissioner of income Tax, Bengaluru-3, Bengaluru. Accordingly, notices u/s. 143(2) as well

SRI ALAGAPPA ANNAMALAI(HUF),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(4), BANGALORE

In the result, both the appeals of the assessees are allowed\nand revenue appeals are dismissed

164\n3.6 Accordingly, they stated that they would be offering capital\ngains for the assessment year 2018-19 on the above basis in course\nof assessment proceedings after receipt of notice.\n3.7 Both these persons had accordingly filed returns in response\nto notice u/s.153C of the Act offering capital gains by adopting the\nvalue determined by the registered valuer

SRI ALAGAPPA MUTHIAH(HUF),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(4), BANGALORE

In the result, both the appeals of the assessees are allowed\nand revenue appeals are dismissed

164\n3.6 Accordingly, they stated that they would be offering capital\ngains for the assessment year 2018-19 on the above basis in course\nof assessment proceedings after receipt of notice.\n3.7 Both these persons had accordingly filed returns in response\nto notice u/s.153C of the Act offering capital gains by adopting the\nvalue determined by the registered valuer

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY, CENTRAL CIRCLE, BELLARY vs. M/S VIRGO PROPERTIES PRIVATE LIMITED, CHENNAI

In the result, appeal filed by the Revenue is dismissed

section 148 of the\nAct to disclose fully and truly all material facts necessary for assessment for\nthat Assessment Year. Therefore the case was rightly reopened by the AO.\nThe learned CIT(A) has wrongly allowed appeal of the assessee.\n6. On the other hand, learned Counsel for the assessee relied on the Order\nof learned

M/S. GOKULDAS EXPORTS,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(2), BANGALORE

In the result, the appeal filed by the assessee is partly allowed in above terms

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Gokaldas Exports Vs. Dcit, Circle - 11(2) (Presently Gokaldas Exports Ltd.) Bengaluru No. 25, 2Nd Cross, 3Rd Main Industrial Suburb, Yashwanthpur Bengaluru 560022 Pan – Aaacg8239J (Appellant) (Respondent) Assessee By: Shri S.V. Ravishankar, Advocate Revenue By: Shri Gudimella Vp Pavan Kumar, Jcit Date Of Hearing: 28.03.2023 Date Of Pronouncement: 31.03.2023 O R D E R Per: Laxmi Prasad Sahu, A.M. This Appeal By The Assessee Is Directed Against The Order Of The Cit(A)-1, Bangalore Dated 31.03.2004 For Ay 1995-06. This Is The Third Round Of Proceedings Before The Tribunal In Pursuant Of The Judgement Of The Hon'Ble Jurisdictional High Court In Ita No. 635 Of 2016 Order Dated 19.07.2022 Which Is Placed On Record On Pages 164 To 176 Of The Paper Book.

164 to 176 of the paper book. 2. The assessee filed additional grounds before the Tribunal on 27.03.2023 challenging legal as well as other issues as under: - “1. The notice issued under section 148 of the Act is invalid in law without obtaining the sanction as per provisions of section 151(1) of the Act on the facts and circumstances

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

capital gain has been earned by sale of share as penny stock. After recording of reasons and taking necessary approval from the competent authorities as per extended date by the CBDT, the approval was granted and notice under section 148 of the Act was issued to the assessee. The assessee furnished reply on 30.10.2023 and the assessee also furnished reply

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

section 14A as computed under Rule 8D(2)(iii) cannot be more than the actual expenditure which can be relatable for earning the exempt income and debited to the Profit and Loss account. In the case on hand the disallowance made by the assessee on its own is not the total expenditure debited to the profit and loss account

B S SOMASEKHAR,BENGALURU vs. INCOME TAX OFFICER, WARD-5(1)(1), BANGALORE

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

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2013-14 Mr. Bommanayakanahalli Siddaiah Somashekhar, Vs. Ito, #51/4 21St Main, 22Nd Cross, Behind Maruthi Ward – 5(1)(1), Mandira, Vijaynagar, Bangalore. Bangalore – 560 040, Karnataka. Pan : Ainps 4894 D Appellant Respondent Assessee By : Shri. Adarsh, Ca Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 06.10.2025 Date Of Pronouncement : 15.10.2025

164. In this regard, assessee has filed reason for delay in filing the appeal. On going through the above reasons, we noted that there is reasonable cause for delay and reasons have been explained. On going through the explanation submitted by the learned Counsel and by relying on the judgment of the Hon’ble Supreme Court in the case

BINDUMALYAM PANDURANGA ALLANHARINARAYAN ,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

In the result, appeal filed by the assessee is partly\nallowed

Capital Gain (Exempt Income)\n9,88,565\nIncome from Other Sources(as per return)\n9,74,634\nGross Total Income\n3,05,05,085\nLess Deduction U/C VI A\n1,68,750\nAssessed Income\n3,03,36,335\n\n4. Aggrieved by the assessment completed u/s 143(3) of the Act\ndated 28.2.2021, the assessee had preferred an appeal before

RAAJRATNA ENERGY HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

section 56(2)(viib) of the\nAct for the Assessment Year 2017-18. Further for the Assessment Year 2018-\n19, AO has disallowed short term capital loss of Rs.5,10,000/- as per his Order\nat para No.5 on sale of investment in Venu Hydro Powers Ltd., and observed\nthat the assessee has claimed excess long term capital loss

RAAJRATNA ENERGY HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

Accordingly, this\nground is allowed for statistical purposes

gain profit by trading in them or with an intention\nto earn dividend/interest from there. All these investments were\nmade in our subsidiaries which are closely held private limited\ncompanies exclusively doing power generation business. In fact,\nwe are not allowed to trade in these investments as they are all\nclosely held private limited companies and hence cannot be traded

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

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

Capital Gains. [\"India-\nIreland DTAA\"]. Article 12 of the aforesaid treaty\ndefining \"royalties\" would alone be relevant to determine\ntaxability under the DTAA, as it is more beneficial to the\nassessee as compared to section 9(l)(vi) of the Income-tax\nAct, as construed by the High Court. Here again, section\n90(2) of the Income-tax Act, read

SRI. D. K SHIVAKUMAR ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

Section 69A of the Act.The addition is made out on basis of loose sheets of documents, which does not come under the ambit of ‘books of entry’ or as ‘evidence’ under the Indian Evidence Act. Reliance is placed on following decisions: 57  CBI Vs. V.C. Shukla (1998) 3 SCC 410  Common Cause and others Vs. Union of India

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

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

Capital Gains. ["India- Ireland DTAA'']. Article 12 of the aforesaid treaty defining "royalties" would alone be relevant to determine taxability under the DTAA, as it is more beneficial to the assessee as compared to section 9(l)(vi) of the Income-tax Act, as construed by the High Court. Here again, section 90(2) of the Income-tax Act, read

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

Capital Gains. ["India- Ireland DTAA'']. Article 12 of the aforesaid treaty defining "royalties" would alone be relevant to determine taxability under the DTAA, as it is more beneficial to the assessee as compared to section 9(l)(vi) of the Income-tax Act, as construed by the High Court. Here again, section 90(2) of the Income-tax Act, read

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENAGLURU

Capital Gains. [\"India-\nIreland DTAA\"]. Article 12 of the aforesaid treaty\ndefining \"royalties\" would alone be relevant to determine\ntaxability under the DTAA, as it is more beneficial to the\nassessee as compared to section 9(l)(vi) of the Income-tax\nAct, as construed by the High Court. Here again, section\n90(2) of the Income-tax Act, read

THE HAMLET,BANGALORE vs. THE INCOME-TAX OFFICER-WARD-6(2)(4), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2012-13 M/S. The Hamlet, No. 11, Kemwell House, The Income Tax Tumkur Road, Officer, Yeshwanthpur, Ward – 6(2)(4), Bangalore – 560 022. Bangalore. Vs. Pan: Aaaft6690D Appellant Respondent Assessee By : Shri H.N. Kincha, Ca : Shri D.K. Mishra, Cit - Revenue By Dr Date Of Hearing : 24-08-2023 Date Of Pronouncement : 16-11-2023 Order Per Beena Pillaipresent Appeal Arises Out Of The Order Dated 27.12.2022 Passed By The Nfac, Delhi For A.Y. 2012-13 On Following Grounds Of Appeal: “1. The Learned Commissioner Of Income Tax (Appeals) Has Erred In Passing The Appellate Order In The Manner Passed. The Appellate Order As Passed Is Bad In Law & Is Liable To Be Quashed. 2. In Any Case, The Learned Commissioner Of Income Tax (Appeals) Has Erred In Confirming The Assessment Order Passed By The Learned Assessing Officer. On The Facts & Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeals) Should Have Quashed, The Order Passed By Assessing Officer Or Atleast Should Have Deleted The Additions Made By The Assessing Officer.

164 Taxman 33 (Delhi)  Surani Steel Tubes Ltd. reported in 136 taxmann.com 139 (Guj.) Right of cross examination:  Chandra Devi Kothari – W.P. No. 3970/2014 (T-IT) Assessment Year 2007-08  Gourav Gupta vs. ITO in ITA No. 2513/Bang/2018 Page 15 of 52 M/s. The Hamlet, Bangalore 3.8. The Ld. DR on the contrary submitted that, there was material received from