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

charitable\ntrust incorporated under section 25 of the companies Act 1956\ncorresponding to section 8 of the companies Act 2013. The assessee\ntrust was granted registration under section 12AA of the Act, which was\nsubsequently migrated to section 12AB of the Act as per the amended\nprovisions introduced by the Finance Act, 2020. The assessee operates\neducational institutions, including schools

THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU vs. M/S. BLUELINE FOODS (INDIA) PVT. LTD.,, MANGALURU

Charitable Trust, Mansukhbhai\nK. Shah, with the direction to find valuable articles or things in Indian\nOverseas Bank at different branches. In the said warrant of\nauthorization also, the authorized Officer was directed to enter and\nsearch the building, etc. persons and to seize books of accounts,\ndocuments, money, bullion, jewellery, etc. as are provided under\nsection 132

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BENGALURU

1)(ac)(i)\nof the Income Tax Act in your case (PAN: AABTR1107Q)-Reference by\nthe Assessing Officer for AY 2016-17-reg\n********\n2.0 Please refer to the above.\nThe Assessee Trust, Rukmini Educational Charitable Society\nfounded in 2003 is a charitable trust registered u/s 12AA vide certificate\nNo. DIT[E]/12A/Vol I/B-706/W-01/02-03 dated 19.03.2003. The case had\nbeen

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BANGALORE

1)(ac)(i)\nof the Income Tax Act in your case (PAN: AABTR1107Q)-Reference by\nthe Assessing Officer for AY 2016-17-reg\n********\n2.0\nPlease refer to the above.\nThe Assessee Trust, Rukmini Educational Charitable Society\nfounded in 2003 is a charitable trust registered u/s 12AA vide certificate\nNo. DIT[E]/12A/Vol I/B-706/W-01/02-03 dated 19.03.2003. The case had\nbeen

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

1)(i) to (v) for which he is authorized. Therefore, assessment under section 153C r.w.s. 132 of the Act is a unique kind of assessment where the focus is on assessing income on incriminating material and such material should be representative of concealed income. The AO cannot merely say that it is difficult to find directly incriminating evidence and hence

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

1)(i) to (v) for which he is authorized. Therefore, assessment under section 153C r.w.s. 132 of the Act is a unique kind of assessment where the focus is on assessing income on incriminating material and such material should be representative of concealed income. The AO cannot merely say that it is difficult to find directly incriminating evidence and hence

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

1)(i) to (v) for which he is authorized. Therefore, assessment under section 153C r.w.s. 132 of the Act is a unique kind of assessment where the focus is on assessing income on incriminating material and such material should be representative of concealed income. The AO cannot merely say that it is difficult to find directly incriminating evidence and hence

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

1)(i) to (v) for which he is authorized. Therefore, assessment under section 153C r.w.s. 132 of the Act is a unique kind of assessment where the focus is on assessing income on incriminating material and such material should be representative of concealed income. The AO cannot merely say that it is difficult to find directly incriminating evidence and hence

M/S. ISLAMIC ACADEMY OF EDUCATION,MANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX(CENTRAL), BANGALORE

In the result, appeal filed by the assessee is partly\nallowed

charitable in nature and thus, there was no specified violation as per\nExplanation [e] to Section 12AB[4] of the Act under the facts and in the\ncircumstances of the appellant's case.\n12. For the above and other grounds that may be urged at the time of hearing of the\nappeal, your appellant humbly prays that the appeal

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BENGALURU

Charitable Trust by any\nregistered transfer/sale deed. Mr. P Shyamaraju in his sworn statement has\nconfirmed that the properties have been purchased in his name and in name of his\nson (Mr. Umesh S. Raju) in their individual capacities, by utilizing the funds given by\nthe Trust. Mr. P. Shyamaraju has admitted that the titles of said properties and legal

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are\npartly allowed and ITA No

1)(i) to (v) for which he is authorized. Therefore, assessment under\nsection 153C r.w.s. 132 of the Act is a unique kind of assessment where the\nfocus is on assessing income on incriminating material and such material\nshould be representative of concealed income. The AO cannot merely say\nthat it is difficult to find directly incriminating evidence and hence

M/S. SRI. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES(REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

charitable trust and of\nsection 13(1)(c) of the Act.\n22.1 The learned DR pointed out that section 13(1)(c) of the Act\nspecifically denies the benefit of section 11 of the Act, if any income or\nproperty of the trust is used for the personal benefit of trustees or other\nspecified persons. Since

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST ,KOLAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

charitable trust and of\nsection 13(1)(c) of the Act.\n22.1 The learned DR pointed out that section 13(1)(c) of the Act\nspecifically denies the benefit of section 11 of the Act, if any income or\nproperty of the trust is used for the personal benefit of trustees or other\nspecified persons. Since

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

charitable trust and of\nsection 13(1)(c) of the Act.\n22.1 The learned DR pointed out that section 13(1)(c) of the Act\nspecifically denies the benefit of section 11 of the Act, if any income or\nproperty of the trust is used for the personal benefit of trustees or other\nspecified persons. Since

DCIT, CENTRAL CIRCLE-1(4), BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

charitable trust and of\nsection 13(1)(c) of the Act.\n22.1 The learned DR pointed out that section 13(1)(c) of the Act\nspecifically denies the benefit of section 11 of the Act, if any income or\nproperty of the trust is used for the personal benefit of trustees or other\nspecified persons. Since

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

charitable trust and of\nsection 13(1)(c) of the Act.\n22.1 The learned DR pointed out that section 13(1)(c) of the Act\nspecifically denies the benefit of section 11 of the Act, if any income or\nproperty of the trust is used for the personal benefit of trustees or other\nspecified persons. Since

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1(4), BENGALURU, BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD), KOLAR

charitable trust and of\nsection 13(1)(c) of the Act.\n22.1 The learned DR pointed out that section 13(1)(c) of the Act\nspecifically denies the benefit of section 11 of the Act, if any income or\nproperty of the trust is used for the personal benefit of trustees or other\nspecified persons. Since

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

charitable trust and of\nsection 13(1)(c) of the Act.\n22.1 The learned DR pointed out that section 13(1)(c) of the Act\nspecifically denies the benefit of section 11 of the Act, if any income or\nproperty of the trust is used for the personal benefit of trustees or other\nspecified persons. Since

M/S. ADARSH VIDYA KENDRA TRUST,BENGALURU vs. THE PR. COMMISSIONER OF INCOME TAX, CENTRAL , BANGALORE

In the result, appeals of the assessee are allowed

132 of the Act in the office premises of\nassessee trust situated at Survey No.69, Pipeline Road, BWSSB\nColony, Magadi Main Road, Bengaluru on 18.12.2021. During the\ncourse of search, various incriminating materials were found which\nwere confronted to Shri Rajeev Kumar Rai, the Trustee and the\nChairman of the Trust and Nikita Rai, the Trustee and Secretary of\nthe