SHRI. KEMPAREDDY GOVINDRAJ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3) , BENGALURU

In the result the appeals of the assessee in ITA No’s 1022 to\n1024/ Bang/ 2024, for the

69C or 69D of\nthe Act.\n\nxxi. The CIT(A) also grossly erred in not taking note of the fact that if\nthese amounts were really the income of the appellant, there must\nhave been assets to represent these corresponding incomes which\nought to have been unearthed in the course of search proceedings.\nxxii. The very fact that there

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

69C of the Income Tax Act. A comprehensive tabulation of the amounts across assessment years was provided. In total, Rs. 4 crore and Rs. 1 on account of loan form Shri Ankit and Shri Rachit added to the total income of the assessee for A.Ys. 2015-16 and 2018-19 respectively. Furthermore, addition on account of payment of interest

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), QUEENS ROAD, BENGALURU vs. SHRI KEMPAREDDY GOVINDRAJU, DOMLUR, BENGALURU

capital gain. Therefore, there can\nbe no protective assessment.” [Para 28]\nIn view of the above judicial precedents, the protective addition\nof Rs.95,45,000/- made in the hands of the assessee, in the\nabsence of a substantive addition in the hands of his wife, is also\nbad in law and needs to be deleted.\nC. The Third issue

SHRI. KEMPAREDDY GOVINDRAJ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BENGALURU

gain. Therefore, there can\nbe no protective assessment.” [Para 28]\nIn view of the above judicial precedents, the protective addition\nof Rs.95,45,000/- made in the hands of the assessee, in the\nabsence of a substantive addition in the hands of his wife, is also\nbad in law and needs to be deleted.\nC. The Third issue is that

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

69C of the Income Tax Act. A comprehensive tabulation\nof the amounts across assessment years was provided. In total, Rs.4\ncrore and Rs.1 on account of loan form Shri Ankit and Shri Rachit added\nto the total income of the assessee for A.Ys.2015-16 and 2018-19\nrespectively. Furthermore, addition on account of payment of interest\nwas made

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

69C of the Income Tax Act. A comprehensive tabulation\nof the amounts across assessment years was provided. In total, Rs.4\ncrore and Rs.1 on account of loan form Shri Ankit and Shri Rachit added\nto the total income of the assessee for A.Ys.2015-16 and 2018-19\nrespectively. Furthermore, addition on account of payment of interest\nwas made

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

69C of the Income Tax Act. A comprehensive tabulation\nof the amounts across assessment years was provided. In total, Rs.4\ncrore and Rs.1 on account of loan form Shri Ankit and Shri Rachit added\nto the total income of the assessee for A.Ys.2015-16 and 2018-19\nrespectively. Furthermore, addition on account of payment of interest\nwas made

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

69C of the Income Tax Act. A comprehensive tabulation\nof the amounts across assessment years was provided. In total, Rs.4\ncrore and Rs.1 on account of loan form Shri Ankit and Shri Rachit added\nto the total income of the assessee for A.Ys.2015-16 and 2018-19\nrespectively. Furthermore, addition on account of payment of interest\nwas made

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

69C of the Income Tax Act. A comprehensive tabulation\nof the amounts across assessment years was provided. In total, Rs.4\ncrore and Rs.1 on account of loan form Shri Ankit and Shri Rachit added\nto the total income of the assessee for A.Ys.2015-16 and 2018-19\nrespectively. Furthermore, addition on account of payment of interest\nwas made