THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(1), BANGALORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K.

144B Penalty u/s 20.09.2022 20.10.2022 06.10.2023 351 271(1)(b) Penalty u/s 20.09.2022 20.10.2022 01.10.2023 346 271(1)(c) 3.2 He submitted that the assessee has filed condonation petition for quantum proceedings upon receiving deficiency letter and no ITA Nos.699 to 704/Bang/2024 The Karnataka Chemists & Druggists Association, Bangalore Page 4 of 23 deficiency letter was received for appeal filed against

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K.

144B Penalty u/s 20.09.2022 20.10.2022 06.10.2023 351 271(1)(b) Penalty u/s 20.09.2022 20.10.2022 01.10.2023 346 271(1)(c) 3.2 He submitted that the assessee has filed condonation petition for quantum proceedings upon receiving deficiency letter and no ITA Nos.699 to 704/Bang/2024 The Karnataka Chemists & Druggists Association, Bangalore Page 4 of 23 deficiency letter was received for appeal filed against

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K.

144B Penalty u/s 20.09.2022 20.10.2022 06.10.2023 351 271(1)(b) Penalty u/s 20.09.2022 20.10.2022 01.10.2023 346 271(1)(c) 3.2 He submitted that the assessee has filed condonation petition for quantum proceedings upon receiving deficiency letter and no ITA Nos.699 to 704/Bang/2024 The Karnataka Chemists & Druggists Association, Bangalore Page 4 of 23 deficiency letter was received for appeal filed against

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

section 142[1], either the Assessing Officer or the Prescribed Income- tax Authority, as the case may be, if, it is considered necessary or expedient to ensure that an assessee has not understated the income or has not computed excessive loss or has not underpaid tax in any manner, shall serve on the assessee a notice for attendance or production

BETHALA PETROPACKS PVT LTD., (FORMERLY KNOWN AS DEEPAK EXTRUSIONS PVT LTD.,),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGLALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144B r.w.s. 147 of the Act 20.12.2019 ITA No. 281/Bang/2024 Appeal field before CIT(A) 03.03.2023 03.03.2023 03.03.2023 03.03.2023 7.1 The above table shows the chronological events for delay in filing the appeals before ld. CIT(A). Thus, the contention of the ld. A.R. is that the delay was due to pursuing alternative remedy by way of writ and writ

SRI PRAJA CO-OPERATIVE CREDIT SOCIETY LIMITED,BANGALORE vs. INCOME-TAX OFFICER, WARD-2(2)(1), BANGALORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2020-21 M/S. Sri Praja Co-Operative Credit Society Ltd., Vs. Ito, No.1, 3Rd Main Road, Nagappa Block, Ward – 2(2)(1), Sriramapura, Bengaluru. Bengaluru – 560 021. Pan : Aaajs 1557 Q Appellant Respondent Assessee By : Shri. Srinivas Bharath, Ca Revenue By : Shri. Subramanian S, Addl. Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 06.03.2024 Date Of Pronouncement : 06.03.2024

condonation of delay in filing return of Income. The assessment unit erred in not considering the delay in filing of return of income as a mere technical delay since all the other documents were filed within time. 5. The learned Income Tax Officer has erred in disallowing deduction under Section 80P(2)(a) of Rs 31,09,361 being interest

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(2) , BANGALORE

Bench: Shri Chandra Poojari & Shri Soundararajan K.

144B 17.03.2022 16.04.2022 06.01.2023 265 Penalty u/s 271(1)(b) 20.09.2022 20.10.2022 06.10.2023 351 Penalty u/s 271(1)(c) 20.09.2022 20.10.2022 01.10.2023 346 3.2 He submitted that the assessee has filed condonation petition for quantum proceedings upon receiving deficiency letter and no ITA Nos.699 to 704/Bang/2024 The Karnataka Chemists & Druggists Association, Bangalore Page 4 of 23 deficiency letter was received

BHASKAR REDDY NANDYALA HANUMANTHA REDDYGARI,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(1), BENGALURU

In the result, all these appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

condone the delay in filing of appeal before CIT (A) and non-compliances for submission of necessary documents during CIT(A) proceedings due the reasons cited in PARA 2 above, 4. Assessment Order passed by Ld, Assessing Officer u/s. 147 r.w,s 144 read with section 144B

BHASKAR REDDY NANDYALA HANUMANTHA REDDYGARI,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(1), BENGALURU

In the result, all these appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

condone the delay in filing of appeal before CIT (A) and non-compliances for submission of necessary documents during CIT(A) proceedings due the reasons cited in PARA 2 above, 4. Assessment Order passed by Ld, Assessing Officer u/s. 147 r.w,s 144 read with section 144B

BHASKAR REDDY NANDYALA HANUMANTHA REDDYGARI,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(1), BENGALURU

In the result, all these appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

condone the delay in filing of appeal before CIT (A) and non-compliances for submission of necessary documents during CIT(A) proceedings due the reasons cited in PARA 2 above, 4. Assessment Order passed by Ld, Assessing Officer u/s. 147 r.w,s 144 read with section 144B

IRENE PEREIRA ,UDUPI vs. ITO WARD- 1&TPS, UDUPI

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2016-17

section 148A(d) of the Act, assessee’s submission filed before the NFAC, bank statements, Details of payment made to Plama Developers, property purchase agreement along with passport copy and immigration details. The assessee has also submitted employment letter of Kuwait Oil Company as well as salary letter of Kuwait Oil Company. 7. Before us, learned AR of the assessee

SAROJAMMA,RAMANAGAR vs. INCOME TAX OFFICER, WARD-1, , RAMANAGAR

In the result, the appeal of the assessee is allowed

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

delay of 8 days in filing the appeal is condoned. 8. The interconnected issues raised by the assessee in the grounds of appeal are that the learned CIT(A) erred in dismissing the appeal by invoking the provisions of section 249(4)(b) of the Act and thereby confirming the addition of Rs. 10 Lakh on account of cash deposit

SHREE HANUMAN CREDIT SOUHARD SAHAKARI LIMITED,CHIKODI vs. PR. COMMISSIONER OF INCOME-TAX, HUBLI

In the result, the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2017-18

condonation of delay stating that:- Page 4 of 19 i. The order of assessment was selected for revision and submissions were made and an order under section 263 came to be passed on 30.03.2022 by the PCIT, Huballi holding that the order passed under section 143(3) of the act was erroneous and prejudicial to the interest of revenue insofar

KARNATAKA POWER CORPORATION LIMITED,BENGALURU vs. ACIT, CIRCLE-4(1)(1), BENGALURU

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

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmed

144B of the Act, dated 30/09/2021, the learned assessing officer sought to amend the order of assessment passed on 30/09/2021 by initiating the proceedings under section 154 of the Act, and thereafter passed an order of rectification under section 154 r.w.s. 143[3] of the Act dated 23/01/2023 by stating that there is a short levy of interest under section

KARNATAKA POWER CORPORATION LIMITED,BENGALURU vs. ACIT, CIRCLE-4(1)(1), BENGALURU

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

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmed

144B of the Act, dated 30/09/2021, the learned assessing officer sought to amend the order of assessment passed on 30/09/2021 by initiating the proceedings under section 154 of the Act, and thereafter passed an order of rectification under section 154 r.w.s. 143[3] of the Act dated 23/01/2023 by stating that there is a short levy of interest under section

MRESULT SERVICES PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -4(1)(1), BANGALORE, BENGALURU

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2022-23 M/S. Mresult Services Pvt. Ltd., The Deputy 5Th Floor, West Wing, Commissioner Raheja Towers, Of Income Tax, M.G. Road, Circle – 4(1)(1), Bengaluru – 560 001. Vs. Bangalore. Pan: Aadcm9518M Appellant Respondent Assessee By : Shri Hasmukh Raveria, Ca Revenue By : Shri Srinath .S, Jcit-Dr

section 51 of the Limitation Act of 1963 in order to enable the courts to do substantial justice to parties by disposing of matters on de merits ". The expression “sufficient cause” employed by the Legislature is adequately elastic to enable the courts to apply the law in a meaningful manner which subserves the ends of justice that being the life

GUNDARLAHALLY RAMESH MEERA ,CHALLAKERE vs. INCOME-TAX OFFICER, WARD-1, CHALLAKERE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2018-19 Ms. Gundarlahally Ramesh Meera, Vs. Ito, #01, Pavagada Road, Ward – 1, Challakere – 577 522. Chitradurga. Pan : Afhpm 7158 K Appellant Respondent Assessee By : Shri. V. Srinivasan, Advocate Revenue By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 02.01.2024 Date Of Pronouncement : 02.01.2024

condone the delay in filing the appeal especially without issuance of any notice for hearing of Page 2 of 5 the appeal and rejecting the reasons explained for the delay in filing on slender and unsustainable grounds without appreciating that the cause of substantive justice must be preferred over technical considerations under the facts and in the circumstances

KURUHINASETTY SOUHARDA CREDIT COOPERATIVE LIMITED,BANGALORE vs. INCOME TAX OFFICER WARD-5(2)(1), BANGLORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Kuruhinasetty Souharda Credit Vs. Ito, Co-Operative Ltd., Ward – 5(2)(1), No.5, Sakamma Bhavana, Bengaluru. Vishveshwarapura, Bengaluru – 560 004. Pan : Aabak 4862 G Appellant Respondent Assessee By : Shri. Tarun Kothari, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 02.01.2024 Date Of Pronouncement : 02.01.2024

144B of the Act. In the assessment completed, the claim of deduction under section 80P was denied for the reason that assessee had not filed its return of income within the due date specified under section 139(1) of the Act (as mandated under section 80AC of the Act w.e.f. 01.04.2018). 4. Aggrieved by assessment completed, assessee preferred appeal before

MUNIYAPPA MUNIRAJU ,BENGALURU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-2, BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2017-18 Shri. Muniyappa Muniraju, Vs. Pr. Cit, No.1/3, 1St Cross, Muni Narasimhaiah Bangalore - 2. Garden, Chocolate Factory Main Road, Btm I Stage, Bangalore – 560 029, Karnataka. Pan : Anjpm 0458 N Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 04.09.2025 Date Of Pronouncement : 11.09.2025

condone the delay of about 34 days in filing the present appeal against the order of the learned Assessing Officer under section 143[3] r.w.s. 263 r.w.s. 144B