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

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

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

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. 1,18,01,752 as deemed

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

6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth- tax Act, 1957 (27 of 1957), shall, with necessary modifications, apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that

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

SMT SUSHAMA RAJESH RAO ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-5(2)(1) , BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan Kassessment Year: 2012-13 Sushama Rajesh Rao, Vs. The Deputy Commissioner No.159, Priyadarshani, R. T. Nagar, Of Income Tax, Mla Layout, Circle – 6(2)(1), Bangalore – 560 032. Bangalore. Pan : Acypr 5251 J Appellant Respondent Appellant By : Shri. V. Chandrashekar, Advocate Respondent By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 23.07.2025 Date Of Pronouncement : 18.08.2025

250 r.w.s 254 of the Income Tax Act, 1961 (hereinafter referred to as "Act") dated 07.12.2022 for Assessment Year 2012-13 in so far as it is against the Appellant is opposed to law, weight of evidence, natural justice, probabilities, facts and circumstances of the Appellant's case. 2. The Appellant denies herself liable to be assessed on a total

SHRI. THIMMAIAH SURESH,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-6(2)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2016-17

section 143(3) of the Act dated 29.12.2018 by the Assistant Commissioner of Income-tax, Circle 6(2)(1) treating a business income a sum of Rs. 2,33,19,841/ - as against capital gain a sum of Rs. 83,39,250

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

250 of the Income-tax Act, 1961 ("IT Act") in so far as it confirms the additions/adjustments made by the learned Assessing Officer ("Ld AO"), is contrary to law and facts of the case Page 2 of 8 and is passed in contravention of principles of natural justice. B. GROUNDS IN RELATION TO SHORT TERM CAPITAL GAINS

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

250 of the Act dated 04.11.2022 by treating the capital gains arising from sale of residential flats at Ramya Residency and sale of residential sites obtained by 'Will' as 'Business income'. 3. Ground Nos.1 & 2(a) of the assessee’s appeal are reproduced as under: Vankadari Chinna Reddappa Chetty, Bangalore Page 4 of 7 1. The order

M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

capital gains (based on the assessed income) of Rs. 96,52,74,468/-. We shall adjudicate the above two issues as under: - Re-computation of arm's length price of shares sold by the assessee amounting to Rs. 262,27,80,021/- (Ground Nos. 1 to 14): 6. The brief facts in relation to the above issue are that

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

capital gains (based on the assessed income) of Rs. 96,52,74,468/-. We shall adjudicate the above two issues as under: - Re-computation of arm's length price of shares sold by the assessee amounting to Rs. 262,27,80,021/- (Ground Nos. 1 to 14): 6. The brief facts in relation to the above issue are that

MR. VIKRAM DHONDU RAO,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2020-21

250 of the Income-tax Act,1961 ['the Act' for short] for the assessment year 2020-21 dated 16.3.2023. The only issue in this appeal is with regard to taxability of Rs.6,57,138/- declared under the head “Profit & gains of business”. 2. Facts of the case are that the assessee is an individual and Management Consultant having income under

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

250 of the Income Tax Act, 1961 (in brevity the Act) for A.Y. 2016-17 by order dated 29.08.2022. Page 2 of 12 2. The impugned order was emanated from the order of Ld. DCIT, Circle – 1, Bellary (in brevity the AO), order passed u/s. 143(3) of the Act, order dated 19.12.2018. 3. The assessee has taken the following

LATE JAGJIT SINGH BAJWA LEAGAL HEIR HARLEEN BAJWA ,BANGALORE vs. INCOME TAX OFFICER, WARD-4(2)(3), BANGALORE

In the result, appeal of the assessee is allowed

250 of the\nIncome Tax Act, 1961 (in short “The Act\").\n2.\nThe assessee is in appeal before us for not granting benefit u/s\n54F of the Act at Rs.1,56,00,000/-.\n3.\nFacts of the case are that Assessee, during the financial year\n2013-14, being in transport business, had filed the return\ndeclaring following income:\nIncome from

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

6, Bangalore. Bangalore - 560 102. PAN :AJTPR 2149 D APPELLANT RESPONDENT Assessee by : Shri. Ravishankar S. V, Advocate Revenue by : Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore. Date of hearing : 07.04.2025 Date of Pronouncement : 07.05.2025 ORDER Per Laxmi Prasad Sahu, Accountant Member : This appeal filed by the assessee is against the Order passed by the CIT(A) vide

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. ENZEN GLOBAL SOLUTIONS PVT LTD , BENGALURU

In the result, the appeal of the Revenue is dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K

250 of the Act for the assessment years 2017- 18 and 2018-19. ITA Nos.696 & 718/Bang/2024 Page 2 of 13 2. Since common issues/facts for consideration are involved in both the years under consideration including the figures, both the appeals are being disposed of by way of a common order. Therefore, the view to be taken for assessment year

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU vs. ENZEN GLOBAL SOLUTIONS PVT LTD, BENGALURU

In the result, the appeal of the Revenue is dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K

250 of the Act for the assessment years 2017- 18 and 2018-19. ITA Nos.696 & 718/Bang/2024 Page 2 of 13 2. Since common issues/facts for consideration are involved in both the years under consideration including the figures, both the appeals are being disposed of by way of a common order. Therefore, the view to be taken for assessment year

M/S. ANAND DIAGNOSTIC LABORATORY,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

250 under the head ‘other discount’. The accountant was asked who submitted that to substantiate the above sum, she needs time. This was as per Q.6 of her statement recorded u/s. 132 of the Act. Further in answer to Q.10 where also the same question arose, the accountant stated that it needs to be reconciled. The partner of the assessee