M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

153B and 153C replaced the “Post Search Block Assessment Scheme” in respect of any search under Section 132A or requisition under Section 132A made after 31.05.2003. CBDT explained these provisions through circular dated 5.9.2003, which is reported in (2003) 263 ITR (St) 62. The said circular is as under: …………. 10. Under the block assessment proceeding under Chapter XIV-B only

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, the appeals filed by the assessee for all the four A

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER\nAND\nSHRI SOUNDARARAJAN K. (Judicial Member)

Section 153D despite\nthe Learned AO's erroneous statement that the case of the\nassessee was centralized with the DCIT Central Circle-2, vide\nOrder of the Pr. CIT, Mangalore in F.No./C-13/Pr.CIT/MNG/2020-\n21 dated 28.07.2021 in all the assessment orders for AYs\n2017-18 to 2020-21. As per the department's own records, the\ncentralization was ordered

M/S SPR SPIRITS PVT. LTD.,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1 (3) , BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153B and 153C replaced the “Post Search Block Assessment Scheme” in respect of any search under Section 132A or requisition under Section 132A made after 31.05.2003. CBDT explained these provisions through circular dated 5.9.2003, which is reported in (2003) 263 ITR (St) 62. The said circular is as under: …………. 10. Under the block assessment proceeding under Chapter XIV-B only

M/S SPR SPIRITS PVT. LTD.,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1 (3) , BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153B and 153C replaced the “Post Search Block Assessment Scheme” in respect of any search under Section 132A or requisition under Section 132A made after 31.05.2003. CBDT explained these provisions through circular dated 5.9.2003, which is reported in (2003) 263 ITR (St) 62. The said circular is as under: …………. 10. Under the block assessment proceeding under Chapter XIV-B only

DEPUTY COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE- 1(3), BANGALORE vs. SHRI. T. NADAKRISHNA, BANGALORE

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153B and 153C replaced the “Post Search Block Assessment Scheme” in respect of any search under Section 132A or requisition under Section 132A made after 31.05.2003. CBDT explained these provisions through circular dated 5.9.2003, which is reported in (2003) 263 ITR (St) 62. The said circular is as under: …………. 10. Under the block assessment proceeding under Chapter XIV-B only

M/S SPR SPIRITS PVT.LTD. ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1 (3) , BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153B and 153C replaced the “Post Search Block Assessment Scheme” in respect of any search under Section 132A or requisition under Section 132A made after 31.05.2003. CBDT explained these provisions through circular dated 5.9.2003, which is reported in (2003) 263 ITR (St) 62. The said circular is as under: …………. 10. Under the block assessment proceeding under Chapter XIV-B only

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153B and 153C replaced the “Post Search Block Assessment Scheme” in respect of any search under Section 132A or requisition under Section 132A made after 31.05.2003. CBDT explained these provisions through circular dated 5.9.2003, which is reported in (2003) 263 ITR (St) 62. The said circular is as under: …………. 10. Under the block assessment proceeding under Chapter XIV-B only

M/S SPR SPIRITS PVT. LTD.,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1 (3), BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153B and 153C replaced the “Post Search Block Assessment Scheme” in respect of any search under Section 132A or requisition under Section 132A made after 31.05.2003. CBDT explained these provisions through circular dated 5.9.2003, which is reported in (2003) 263 ITR (St) 62. The said circular is as under: …………. 10. Under the block assessment proceeding under Chapter XIV-B only

M/S. CRYSTAL GRANITE AND MARBLE PRIVATE LIMITED,RAMANAGARAM vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes and Stay Petition is dismissed as infructuous

Bench: Shri George George K & Shri Laxmi Prasad Sahus.P No.29/Bang/2023 Assessment Year: 2017-18

153B thereof, expires on the 30th day of April, 2021 due to its extension by the said notifications, such time limit shall further stand extended to the 30th day of June, 2021; (b) the completion of any action, referred to in clause (a) of sub-section (1) of section 3 of the said Act, relates to passing of an order

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, all the appeals filed by the assessee are allowed

Section 153D dated 28.09.2021 is bad\nand invalid. Consequently, the assessment orders for the AYs 2018-\n19, 2019-20 and 2020-21 are bad and invalid without valid\napproval under Section 153D.\n\n5. As regards revised return filed being invalid and contrary to\nSection 139(5)\n\n5. 1. The Assessee filed the original return of income

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

Section 153D dated 28.09.2021 is bad\nand invalid. Consequently, the assessment orders for the AYs 2018-\n19, 2019-20 and 2020-21 are bad and invalid without valid\napproval under Section 153D.\n5. As regards revised return filed being invalid and contrary to\nSection 139(5)\n5.1. The Assessee filed the original return of income

KHODAY ESHWARSA AND SONS PVT LTD (FORMERLY MS KHODAY ESHWARSA AND SONS),BANGALORE vs. DCIT- CENTRAL CIRCLE 1(1) BGL, BANGALORE

In the result, the appeal filed by the assessee is hereby allowed\nfor statistical purposes

b) of section 153B in respect of the\n assessment year relevant to the previous year in which search is conducted\nunder section 132 or requisition is made under section 132A. 50.3 Applicability-These amendments will take effect from the 1st day of June,\n2007.\"\n6.2\nFrom the perusal of the section 153D of the Act read with the\nCBDT

KHODAY ESHWARSA AND SONS ( PRESENTLY KHODAY ESHWARSA AND SONS PVT LTD,BANGALORE vs. DCIT - CENTRAL CIRCLE 1(1) BANGALORE, BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

b) of section 153B in respect of the assessment year relevant to the previous year in which search is conducted under section 132 or requisition is made under section 132A. 50.3 Applicability-These amendments will take effect from the 1st day of June, 2007." 6.2 From the perusal of the section 153D of the Act read with the CBDT Circular

JOHN DEVELOPERS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

153B and 153C contemplate a merger of regular assessments with those that may be triggered by a search. On a search being undertaken in terms of Section 153A, the jurisdictional AO is enabled to initiate an assessment or reassessment, as the case may be, in respect of the six AYs' immediately preceding the AY relevant to the year of search

JOHN DISTILLERIES PVT LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

153B and 153C contemplate a merger of regular assessments with those that may be triggered by a search. On a search being undertaken in terms of Section 153A, the jurisdictional AO is enabled to initiate an assessment or reassessment, as the case may be, in respect of the six AYs' immediately preceding the AY relevant to the year of search

JOHN DEVELOPERS ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

153B and 153C contemplate a merger of regular assessments with those that may be triggered by a search. On a search being undertaken in terms of Section 153A, the jurisdictional AO is enabled to initiate an assessment or reassessment, as the case may be, in respect of the six AYs' immediately preceding the AY relevant to the year of search

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1) , BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

153B and 153C contemplate a merger of regular assessments with those that may be triggered by a search. On a search being undertaken in terms of Section 153A, the jurisdictional AO is enabled to initiate an assessment or reassessment, as the case may be, in respect of the six AYs' immediately preceding the AY relevant to the year of search

M/S. PAUL RESORTS & HOTELS PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

153B and 153C contemplate a merger of regular assessments with those that may be triggered by a search. On a search being undertaken in terms of Section 153A, the jurisdictional AO is enabled to initiate an assessment or reassessment, as the case may be, in respect of the six AYs' immediately preceding the AY relevant to the year of search