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

1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the 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

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

1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the 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

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

1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the 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

TECNOTREE CONVERGENCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2009-10

271(1)(c) was levied on the ground that the assessee violated of provisions of section 94(7) of the Act by not ignoring losses while computing short-term capital gains

SHRI. MUNINAGA REDDY,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal for A

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

Capital Gains (LTCG) thereon; apart from declaring income / loss from other heads such as house property, business and other sources. The assessment was completed under section 143(3) of the Act by order dt.15.12.2008 wherein the income of the assessee was determined at Rs.5,45,59,686. Penalty proceedings under section 271(1

SIMPLEX TMC PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(1),BENGALURU, BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2018-19

Capital Gains. The AO further held that as the assessee had not offered the amount of Rs. 5,00,000/- as income, the undisclosed income is covered by provision of clause(b) Simplex TMC Pvt. Ltd., Bangalore Page 4 of 17 of Section 271AAB(1A) of the Act and accordingly a penalty

DCIT vs. SRI. P. SUBRAMANI,

In the result, Revenue’s appeal for Assessment Year 2006-07 is dismissed

Bench: Shri Rajpal Yadav & Shri Jason P. Boaz

1)(c) of the Act, vide order dt.26.4.2012 only on the issue of denial of the assessee's claim for exemption under section 54B of the Act made in the computation of capital gains on sale of lands. 2.3 Aggrieved by the order dt.26.4.2012 levying penalty of Rs.10,24,846 under section 271

MR K. P. MANJUNATHA REDDY,BANGALORE vs. THE INCOME TAX OFFICER, WARD 4(3)(2), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

271(1)(c) of the Act. 10. The appellant submits that each of the above grounds is independent and without prejudice to one another. 2. Facts of the case are that the A.O. made addition of Rs.2.06 crores as long term capital gain arising from sale of land situated at Survey No.40, Chikkanahalli Kammanahalli, Sarjapur hobli, Anekal Taluk, Bengaluru

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

1). The question now is no longer res integra having regard to the decision of the Apex Court in CIT v. Podar Cement (P.) Ltd. [1997] 226 ITR 6252. The Apex Court categorically held that section 22 of the Act does not require registration of sale deed. The meaning of the word ‘owner’ in the context of section

DCIT, BANGALORE vs. M/S EPSILON ADVISORS PVT. LTD.,, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

Gain and disallowed to the Assessee the short term capital loss of Rs. 117,76,40,000 in respect of sale of equity shares of Jupiter Capital Private Limited by the Assessee to M/s Vectra Holdings Private Limited.” 20. In the result, the quantum appeal of the assessee is partly allowed in the terms indicated above and the quantum appeal

EPSILON ADVISORS P. LTD.,,BANGALORE vs. CIT, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

Gain and disallowed to the Assessee the short term capital loss of Rs. 117,76,40,000 in respect of sale of equity shares of Jupiter Capital Private Limited by the Assessee to M/s Vectra Holdings Private Limited.” 20. In the result, the quantum appeal of the assessee is partly allowed in the terms indicated above and the quantum appeal

EPSILON ADVISORS P. LTD.,,BANGALORE vs. CIT, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

Gain and disallowed to the Assessee the short term capital loss of Rs. 117,76,40,000 in respect of sale of equity shares of Jupiter Capital Private Limited by the Assessee to M/s Vectra Holdings Private Limited.” 20. In the result, the quantum appeal of the assessee is partly allowed in the terms indicated above and the quantum appeal

DCIT, BANGALORE vs. M/S EPSILON ADVISORS PVT. LTD.,, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

Gain and disallowed to the Assessee the short term capital loss of Rs. 117,76,40,000 in respect of sale of equity shares of Jupiter Capital Private Limited by the Assessee to M/s Vectra Holdings Private Limited.” 20. In the result, the quantum appeal of the assessee is partly allowed in the terms indicated above and the quantum appeal

SMT B SUMATHY,BANGALORE vs. THE INCOME TAX OFFICER WARD-1(2)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2005-06 is allowed as indicated above

Bench: Shri N. V. Vasudevan & Shri Jason P Boazassessment Year : 2005-06 Smt. B. Sumathy, Vs. The Income Tax Officer, #T-401, Poorva Park, Ward – 1(2), Now Jeevana Halli Main Road, Ito, Ward – 1[2][2], Cox Town, Bangalore-560 005. Bangalore. Pan : Aseps 7079 K Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. T. Chandrasekhar, Addl. Cit Date Of Hearing : 27.03.2019 Date Of Pronouncement : 16.04.2019

capital gains by virtue of denying the assessee’s claim for exemption under section 54F of the Act. 3.2 Penalty proceedings under section 271(1

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

DCIT vs. M/S MINITECHS AEROTOOLS PVT. LTD.,,

In the result, the appeal by the Revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Abraham P. Georgeassessment Year : 2007-08

section 271(1)(c) of the Act. It held that the law does not Page 11 of 12 absolve the assessee from concealment penalty merely because a voluntary disclosure of concealed income is made. 16. The Hon’ble Supreme Court held that the surrender of income in this case is not voluntary and the surrender was in view

SRI. LAXMIDAS BAPUDAS DARBAR,BAGALKOT vs. ITO, BAGALKOT

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

Bench: Shri N.V. Vasudevan & Shri Abraham P. Georgeassessment Year : 2006-07

271 Less: Cost of Acquisition As tenancy right hence value as on Nil 1981 as compensation received including residential structure constructed by lessee during tenure of lease, the lessee is absolute owner and hence valuation of structure as on 1981 (as per Valuation Report) Rs.205120 Hence inflation cost as per index 2005/06

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

Section\n153D. It is not an exercise dealing with a immaterial matter which\ncould be corrected by taking recourse to Section 292B of the Act.\n16. We are not inclined to interdict the order of the Tribunal.\n17. Accordingly, the appeal is closed.\n6.5 The above view taken by the Hon’ble Delhi High Court in the case of PCIT