ACIT, BANGALORE vs. SRI. T.G. RANGANATH, BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2008-09

capital account in a partnership firm m/s. Karkesia Estates shows distinctively In the financial statements and the same has been allowed by the same CIT(A) for A Y 2009- 10 on cumulative basis under the facts and circumstances of the case. ITA Nos.1457, 1466, 1467/Bang/2012 & T.G. Ranganath, Bangalore Page 5 of 107 18. The learned

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

Credits (P) Ltd., 292 ITR 339 [Del] iii. CIT vs. Girish Bhagwatprasad, 256 ITR 772 [Guj] iv. CIT vs. Brilliant Tutorials Private Limited, 292 ITR 399 [Mad] v. CIT vs. Autometers Ltd., 292 ITR 345 [Del] vi. Board Circular No. 551, dated 23, 1990, 183 ITR (St.) 7 vi. Unreported decision of the Jurisdictional High Court in the case

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

Credits (P) Ltd., 292 ITR 339 [Del] iii. CIT vs. Girish Bhagwatprasad, 256 ITR 772 [Guj] iv. CIT vs. Brilliant Tutorials Private Limited, 292 ITR 399 [Mad] v. CIT vs. Autometers Ltd., 292 ITR 345 [Del] vi. Board Circular No. 551, dated 23, 1990, 183 ITR (St.) 7 vi. Unreported decision of the Jurisdictional High Court in the case

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

Credits (P) Ltd., 292 ITR 339 [Del] iii. CIT vs. Girish Bhagwatprasad, 256 ITR 772 [Guj] iv. CIT vs. Brilliant Tutorials Private Limited, 292 ITR 399 [Mad] v. CIT vs. Autometers Ltd., 292 ITR 345 [Del] vi. Board Circular No. 551, dated 23, 1990, 183 ITR (St.) 7 vi. Unreported decision of the Jurisdictional High Court in the case

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

Credits (P) Ltd., 292 ITR 339 [Del] iii. CIT vs. Girish Bhagwatprasad, 256 ITR 772 [Guj] iv. CIT vs. Brilliant Tutorials Private Limited, 292 ITR 399 [Mad] v. CIT vs. Autometers Ltd., 292 ITR 345 [Del] vi. Board Circular No. 551, dated 23, 1990, 183 ITR (St.) 7 vi. Unreported decision of the Jurisdictional High Court in the case

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

Credits (P) Ltd., 292 ITR 339 [Del] iii. CIT vs. Girish Bhagwatprasad, 256 ITR 772 [Guj] iv. CIT vs. Brilliant Tutorials Private Limited, 292 ITR 399 [Mad] v. CIT vs. Autometers Ltd., 292 ITR 345 [Del] vi. Board Circular No. 551, dated 23, 1990, 183 ITR (St.) 7 vi. Unreported decision of the Jurisdictional High Court in the case

SHRI. SHANTHISAGAR CO OP CREDIT SOCIETY LIMITED,HUBLI vs. INCOME TAX OFFICER, WARD-2(1), HUBLI

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

capital by the cooperative societies engaged in providing credit facilities to the members is squarely covered in favour of the assessee by the ruling of Jurisdictional High Court in the cases of Tumkur Merchants Souharda Credit Cooperative Ltd(supra), Guttigedarara Credit Co-operative Society Ltd. and Lalitamba Pattina Souharda Sahakari Niyamita vs. ITO as well as by the decision

JAYANTILAL BHAGWANCHAND,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(4), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Shri Waseem Ahmedassessment Year : 2011-12

capital gain under section 10(38) of the Act for Rs. 10,86,720/- only and treating the same as unexplained cash credit

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

credits were fully explainable and\ndocumented.\n\nITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024\nPage 34 of 116\n31.11 Another significant point raised by the assessee was that these\ncash transactions spanned multiple financial years, namely A.Ys.2015–\n16, 2016–17, and 2017–18. Therefore, even if considered, the entire\nsum of ₹5 crores

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

credits were fully explainable and documented. . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 35 of 116 31.11 Another significant point raised by the assessee was that these cash transactions spanned multiple financial years, namely A.Ys. 2015– 16, 2016–17, and 2017–18. Therefore, even if considered, the entire sum of ₹5 crores could

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

credits were fully explainable and documented. . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 35 of 116 31.11 Another significant point raised by the assessee was that these cash transactions spanned multiple financial years, namely A.Ys. 2015– 16, 2016–17, and 2017–18. Therefore, even if considered, the entire sum of ₹5 crores could

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

credits were fully explainable and documented. . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 35 of 116 31.11 Another significant point raised by the assessee was that these cash transactions spanned multiple financial years, namely A.Ys. 2015– 16, 2016–17, and 2017–18. Therefore, even if considered, the entire sum of ₹5 crores could

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

credits were fully explainable and documented. . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 35 of 116 31.11 Another significant point raised by the assessee was that these cash transactions spanned multiple financial years, namely A.Ys. 2015– 16, 2016–17, and 2017–18. Therefore, even if considered, the entire sum of ₹5 crores could

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

credits were fully explainable and documented. . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 35 of 116 31.11 Another significant point raised by the assessee was that these cash transactions spanned multiple financial years, namely A.Ys. 2015– 16, 2016–17, and 2017–18. Therefore, even if considered, the entire sum of ₹5 crores could

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

credits were fully explainable and documented. . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 35 of 116 31.11 Another significant point raised by the assessee was that these cash transactions spanned multiple financial years, namely A.Ys. 2015– 16, 2016–17, and 2017–18. Therefore, even if considered, the entire sum of ₹5 crores could

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

credits were fully explainable and documented. . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 35 of 116 31.11 Another significant point raised by the assessee was that these cash transactions spanned multiple financial years, namely A.Ys. 2015– 16, 2016–17, and 2017–18. Therefore, even if considered, the entire sum of ₹5 crores could

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

credits were fully explainable and documented. . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 35 of 116 31.11 Another significant point raised by the assessee was that these cash transactions spanned multiple financial years, namely A.Ys. 2015– 16, 2016–17, and 2017–18. Therefore, even if considered, the entire sum of ₹5 crores could

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

credits were fully explainable and documented. . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 35 of 116 31.11 Another significant point raised by the assessee was that these cash transactions spanned multiple financial years, namely A.Ys. 2015– 16, 2016–17, and 2017–18. Therefore, even if considered, the entire sum of ₹5 crores could