SREENIVASULU SAGALETI,BENGALURU vs. INCOME TAX OFFICER, WARD-2(2)(2), BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri. Laxmi Prasad Sahuandshri.Keshav Dubeyassessment Year :2018-19

capital gains under sections 54 to 54G of the Act, to 30.09.2020 which is placed at Page Nos.137 to 138. The construction

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 are: (i) Assessee should be an individual or a Hindu Undivided Family; (ii) Capital assets should result from the transfer of a long term capital asset; (iii) Capital gain

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

gains arising from\nthe transfer of a capital asset effected in the\nprevious year shail, save as otherwise\nprovided in sections 54

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

The appeals of the assessees are allowed\nand revenue appeals are dismissed

gains arising from\nthe transfer of a capital asset effected in the\nprevious year shail, save as otherwise\nprovided in sections 54

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

54 restricted to 71,67,207 Rs.71,67,207/- Less: Exemption claimed u/s. 54EC 50,00,000 Net Capital Gains on sale of villas for FY 20-21 4,92,69,179 As the assessee had declared a capital gains of Rs.4,74,72,475 in the ITR filed for AY 2021-22, therefore the additional capital gains ITA Nos.962

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

54 restricted to 71,67,207 Rs.71,67,207/- Less: Exemption claimed u/s. 54EC 50,00,000 Net Capital Gains on sale of villas for FY 20-21 4,92,69,179 As the assessee had declared a capital gains of Rs.4,74,72,475 in the ITR filed for AY 2021-22, therefore the additional capital gains ITA Nos.962

NAVJYOTI SHARMA,BANGALORE vs. DCIT ASMNT, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 54 are: (i) Assessee should be an individual or a Hindu Undivided Family; (ii) Capital assets should result from the transfer of a long term capital asset; (iii) Capital gain

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

gains arising from\nthe transfer of a capital asset effected in the\nprevious year shail, save as otherwise\nprovided in sections 54

SHARADA MOHAN SHETTY,KARWAR vs. ITO, WARD-2, KARWAR

In the result, appeal of the assessee is partly allowed

Bench: Or During The Courses Of Appeal Hearing.” 2. The Brief Facts Of The Case Are That The Assessee Filed Return Of Income On 30/09/2015 For The Assessment Year 2015-16 Declaring Page 2 Of 16

gains - Exemption under section 54 - Assessee purchased residential site and used portion of net sale consideration for construction of new house – Page 8 of 16 Assessee not appropriated the balance sale consideration either in investment in .in'iion of residential house or deposit into account notified by Central Govt. Assessee claimed exemption under section 54 for having invested the capital

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 was quoted correctly by the deductor.” 3 Ramesh Narayana Reddy (HUF) 3. At the outset the revenue has challenged the order of the CIT(A) on three counts. a. NAFC has erred in deleting the addition of Rs 1,81,01,752/- on account of deemed rental income from the flats owned by assessee, these flats were allotted

M/S. ATRIA WIND (KADAMBUR) PRIVATE LIMITED,BENGALUAU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

In the result, appeal filed by the assessee is allowed

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

gains arising from the transfer of a capital asset effected in the previous year shall, save as otherwise provided in sections 54

PRAKASH BARE,BENGALURU vs. DCIT CIRCLE 2(2)(1), KORAMANGALA, BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year :2020-21

Capital Gains Account Scheme Account in terms of Section 54(2) of the Income Tax Act 1961, may please be pardoned

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE vs. M/S OLIVIYA APPARELS PRIVATE LIMITED, BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

54,17,542 – – towards property improvement Undisclosed capital 1,44,00,000 – – Unexplained gain on – – 6,07,621 sale of mutual fund 6. Aggrieved, the assessee preferred appeals before the CIT(Appeals). The CIT(Appeals) gave full relief to the assessee in respect of the addition made towards bad debts written off. With regard to unexplained expenditure incurred towards property

M/S OLIVIA APPARELS PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

54,17,542 – – towards property improvement Undisclosed capital 1,44,00,000 – – Unexplained gain on – – 6,07,621 sale of mutual fund 6. Aggrieved, the assessee preferred appeals before the CIT(Appeals). The CIT(Appeals) gave full relief to the assessee in respect of the addition made towards bad debts written off. With regard to unexplained expenditure incurred towards property

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE vs. M/S OLIVIYA APPARELS PRIVATE LIMITED, BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

54,17,542 – – towards property improvement Undisclosed capital 1,44,00,000 – – Unexplained gain on – – 6,07,621 sale of mutual fund 6. Aggrieved, the assessee preferred appeals before the CIT(Appeals). The CIT(Appeals) gave full relief to the assessee in respect of the addition made towards bad debts written off. With regard to unexplained expenditure incurred towards property

M/S OLIVIA APPARELS PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

54,17,542 – – towards property improvement Undisclosed capital 1,44,00,000 – – Unexplained gain on – – 6,07,621 sale of mutual fund 6. Aggrieved, the assessee preferred appeals before the CIT(Appeals). The CIT(Appeals) gave full relief to the assessee in respect of the addition made towards bad debts written off. With regard to unexplained expenditure incurred towards property

M/S. OLIVIA APPARELS PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BANGALORE

In the result, all the appeals filed by the revenue and the assessee are dismissed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

54,17,542 – – towards property improvement Undisclosed capital 1,44,00,000 – – Unexplained gain on – – 6,07,621 sale of mutual fund 6. Aggrieved, the assessee preferred appeals before the CIT(Appeals). The CIT(Appeals) gave full relief to the assessee in respect of the addition made towards bad debts written off. With regard to unexplained expenditure incurred towards property

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

section says "to transfer" means the said\ncontract is in respect of a transfer and not for any other purpose.\nThe term \"transfer\" is to be read along with the s. 45 and s. 2(47)(v)\nof IT Act. It is pertinent to clarify that one must not mistake to\nidentify the issue of capital gain with the term

NAGAMMA,RAICHUR vs. INCOME TAX OFFICE-WARD 1, RAICHUR

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

54(F) deals with capital gains on transfer of certain capital assets not to be\ncharged in case, of investment on house. It reads as under:\n54F. Capital gain on transfer of certain capital assets not to be charged income of\ninvestment in residential house. — (1) [Subject to the provisions of sub-section