MR. LALASAB IMAMSAB ARAGANJI,GADAG vs. INCOME-TAX OFFICER, WARD-2, GADAG

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

02,4157- Total tax effect (see note below) 2. At the outset, it was observed that there was delay in filing the appeal in ITA No.128/Bang/2023 to the extent of 1553 days. The assessee has explained this delay by way of an affidavit along with petition as follows: ITA Nos.127 & 128/Bang/2023 Mr. Lalasab Imamsab Araganji, Gadag Page

M/S. MULKI SUNDAR RAM SHETTY NAGAR AYYAPPA SWAMY TEMPLE TRUST,BANGALORE vs. INCOME TAX OFFICER, EXEMPTIONS, WARD-2, BANGALORE

In the result, the appeal is allowed in favour of the assessee

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.Assessment Year: 2017-18

condoning the delay caused in filing of Form 10B for the impugned assessment year. 9. Without prejudice, the learned Assessing Officer is not justified in determining the income at Rs.99,08,785 failing to apply the commercial principles under the facts and circumstances of the case. Further, the learned Assessing Officer failed to appreciate that the capital receipts of Rs.39

YASHODA PUTTARAJU JAYANTHKUMAR ,MYSORE vs. INCOME TAX OFFICER, WARD-1(1) , MYSORE

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

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

condoned the delay by exercising the powers conferred under section 249(3) of the Act, on the facts and circumstances of the case. c. The dismissal of the appeal on delay has resulted in collection of taxes on income which has not been earned by the appellant, thus, defeating the basic tenets of the taxation law, on the facts

S B MANGHANANI CHARTIABLE,BANGALORE vs. INCOME TAX OFFICER, EXEMPTIONS,WARD-3, BANGALORE

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

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

02-03-2026 ORDER PER SOUNDARARAJAN K., JUDICIAL MEMBER This is an appeal filed by the assessee challenging the order of the NFAC, Delhi dated 12/06/2024 in respect of the A.Y. 2016-17 and raised the following grounds: “1. The order passed by the learned Commissioner of Income Tax (Appeal), NFAC under section

M/S SARTORIOUS MECHTRONICS INDIA (P) LTD. vs. DCIT,

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

section 32 of the Act. 6. The ld. counsel for the assessee drew our attention to the decision of the Hon’ble Supreme Court rendered in the case of CIT v. Smifs Securities Ltd., 348 ITR 302 (SC) wherein it was held that goodwill is an asset on which depreciation is allowable u/s. 32 of the Act. The aforesaid development

M/S. PRESTIGE ESTATES PROJECTS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

02,700 as the returned income. In response, the Appellant filed a rectification application u/s 154 on 25.07.2019 requesting rectification of the said order. However, the said application u/s 154 was rejected vide letter / order dated 28.05.2020. Subsequently, the assessee was not operating fully considering the fear of spread of COVID-19. This has resulted in the delay in filing

M/S. PRESTIGE ESTATES PROJECTS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

02,700 as the returned income. In response, the Appellant filed a rectification application u/s 154 on 25.07.2019 requesting rectification of the said order. However, the said application u/s 154 was rejected vide letter / order dated 28.05.2020. Subsequently, the assessee was not operating fully considering the fear of spread of COVID-19. This has resulted in the delay in filing

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1)(, BENGALURU

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1) , BENGALURU

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BENGALURU

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BENGALURU

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BENGALURU

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1) , BANGALORE

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BENGALURU

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1) , BANGALORE

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BENGALURU

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1) , BENGALURU

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham

M/S. PRAKAT SOLUTIONS PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 3(1)(1), BENGALURU

In the result, all the appeals by the assessee are treated as allowed for statistical purpose

Bench: Shri George George K & Shri Laxmi Prasad Sahu

condoning the delay in filing of the appeal. 4. Reliance is also placed on the following orders of ITAT, Bangalore Kooud Software Pvt. Ltd. V The Dy. Director of Income-tax, CPC - TDS, Ghaziabad - ITA No.82 to 90/Bang/2022 Nagesh Consultants Vs. DCIT CPC-TDS Circle - 2(1.), Bangalore ITA No. 32/Bang/2023 dtd: 07-03-2023 Thomas Abraham