DIVYA DINESH ,BENGALURU vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result appeal of the assessee is allowed

250 of the Income Tax Act, 1963 (hereafter the Act) for A.Ys.\n2019-20 & 2021-22 dated 19/06/2025 and 29/08/2025.\n2. First, we take up assessee's appeal in ITA No. 2194/Bang/2025\nfor the Assessment Year 2019-20\n3. The issue raised by the assessee is that the CPC erred in\nadjusting the STT suffered short term capital loss

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

250 of the Income Tax Act, 1961 (in short “The Act”). Since the issues in all these four appeals isarising out of the common Joint development agreement, these are clubbed together, heard together and disposed of by this common order. 3. First, we take up the ITA No.963/Bang/2025 for the AY 2021-22, wherein the assessee has raised the following

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

250 of the Income Tax Act, 1961 (in short “The Act”). Since the issues in all these four appeals isarising out of the common Joint development agreement, these are clubbed together, heard together and disposed of by this common order. 3. First, we take up the ITA No.963/Bang/2025 for the AY 2021-22, wherein the assessee has raised the following

NABHIRAJ RATNA BALRAJ BY LEGAL HEIR B.R.RAKESH,BANGALORE vs. INCOME-TAX OFFICER, WARD-7(2)(1), BANGALORE

In the result the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

capital gains under this anti-avoidance provision. It is a case of a curative amendment to take care of unintended consequences of the scheme of section 50C. xi. Parliament has introduced third proviso in section 50C(1) of the Act, as per which the difference in stamp duty valuation and actual consideration should be ignored, if it is less than

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

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

250 of the Income Tax Act, 1961 (in short “The Act”). Since the issues inall these cross appeals are common, these are clubbed together, heard together and disposed of by this common order for the sake of convenience. 2. The grounds raised by the assessee for the Asst. year 2017- 18 in ITA No.210/Bang/2024 are taken as base for deciding

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 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

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 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

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

250 of the Act by the learned CIT(A), NFAC to the extent prejudicial to the appellant be quashed or in the alternative the addition of Rs.1,09,55,534/- made under section 10AA and consequential levy of tax including interest thereon be deleted. The Appellant submits that each of the above grounds / sub-grounds are independent and without prejudice

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

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 and raised the following grounds: - “The Ld. Addl. CIT(A) has erred in deleting the addition of Rs. 1

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

250 of the Income tax\n(here after the Act) dated 31st March 2025 bearing DIN:\nITBA/APL/M/250/2024-25/1075322373(1) and ITBA/APL/M/250/2024-\n25/1075322383(1) respectively.\n\n2. First, we take up ITA No. 939/Bang/2025, an appeal by\nthe assessee for the A.Y. 2020-21.\n\n3. The assessee has raised extensive grounds of appeal which are\nnumbered as Ground Nos.1

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

1. The order passed by the learned Commissioner of Income Tax (Appeals), Bengaluru-12, under section 250 of the Act in so far as it is against the Appellant is opposed to law, weight of evidence, probabilities, facts and circumstances of the Appellant’s case. 2. The appellant denies himself to be assessed at Rs. 83,17,454/- as against

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

250 of the Income tax\n(here after the Act) dated 31st March 2025 bearing DIN:\nITBA/APL/M/250/2024-25/1075322373(1) and ITBA/APL/M/250/2024-\n25/1075322383(1) respectively.\nITA No.939 & 940/Bang/2025\nPage 2 of 145\n2. First, we take up ITA No. 939/Bang/2025, an appeal by\nthe assessee for the A.Y. 2020-21.\n3. The assessee has raised extensive grounds of appeal which are\nnumbered

CHANDRASHEKAR HEMANTH ,BENGALURU vs. INCOME TAX OFFICER WARD 7(2)(4) BANGALORE, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

250, to the extent it is against the Appellant, be quashed and the relief sought to be granted.” 2. The brief facts of the case are that the assessee is an individual and filed his return of income on 28/03/2018 declaring a total income of Rs. 4,64,440/-. The assessee is running a hotel in the name and style

NALAPAD PROPERTIES ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-2(3) , BANGALORE

250 of the Act dated 30.6.2024 passed by the\nld. CIT(A) Bangalore 15 is opposed to law, facts and circumstances of\nthe case.\n2. The Ld. CIT(A) has erred in passing the impugned Appellate order\nconfirming the additions of alleged Business income amounting to\nRs.111,53,50,377/- for the A.Y.2017-18 on the ground of alleged\nexchange

M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojariassessment Year: 2018-19

gains", and this has been the consistent view of this Court. In our opinion, the High Court in the impugned judgment, as well as the Tribunal and the Income Tax authorities have approached the matter from an erroneous angle. In the present case, the assessee borrowed the fund from the bank and lent some of it to its sister concern

SHRI. ANANTULA VIJAY MOHAN ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\Nita Nos.2059 & 2060/Bang/2024\N Assessment Years: 2016-17 & 2017-18\Nanantula Vijay Mohan\N9, Banjara Avenue Road\Nno.1, Banjara Hills\Nhyderabad 500 034\Npan No: Aelpm6515K\Nappellant\Nvs.\Nvs.\Ndcit\Ncircle-6(1)(1)\Nbangalore\Nrespondent\Nsp No.67/Bang/2024\N(Arising Out Of Ita No.2060/Bang/2024)\N Assessment Year: 2017-18\Nanantula Vijay Mohan\N9, Banjara Avenue Road\Nno.1, Banjara Hills\Nhyderabad 500 034\Npan No: Aelpm6515K\Nappellant\Ndcit\Ncircle-6(1)(1)\Nbangalore\Nrespondent\Nappellant By\Nrespondent By\Nsri Padma Khincha, A.R.\Nsri Sridhar E., D.R.\Ndate Of Hearing\N: 18.02.2025\Ndate Of Pronouncement: 07.05.2025\Norder\Nper Laxmi Prasad Sahu:\Nthese Appeals At The Instance Of The Assessee Are Directed\Nagainst The Orders Of Ld. Cit(A)/Nfac, Delhi Both Dated 23.09.2024\Nvide Din & Order No. Itba/Nfac/S/250/2024-25/1068988279(1)\Nfor The Assessment Year 2016-17 & Vide Din & Order\Nno.Itba/Nfac/S/250/2024-25/1068999127(1) For The Assessment\Nyear 2017-18 Passed U/S 250 Of The Income Tax Act, 1961 (In Short\N'The Act'). Since Both These Appeals & The Stay Petition Are Of The\Nsame Assessee For The Different Assessment Years, These Are Clubbed\Ntogether, Heard Together & Disposed Of By This Common Order For\Nthe Sake Of Convenience & Brevity.\Nita No.2059/Bang/2024 (Ay 2016-17):\N2. First, We Take Up Ita No.2059/Bang/2024 For The Ay 2016-\N17 Wherein The Assessee Has Raised The Following Grounds Of Appeal:\N1. General\N1.

250 of the Income Tax Act, 1961 (in short\n'The Act'). Since both these appeals and the stay petition are of the\nsame assessee for the different assessment years, these are clubbed\ntogether, heard together and disposed of by this common order for\nthe sake of convenience and brevity.\nITA No.2059/Bang/2024 (AY 2016-17):\n2. First, we take