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.

4. The ld. D.R. submitted that the assessee is not vigilant in taking the legal remedies by filing appeals before the NFAC and the assessee not properly explained the delay before NFAC. Hence, the appeals are not admitted by the NFAC. 5. We have heard the rival submissions and perused the materials available on record. The assessee explained the delay

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.

4. The ld. D.R. submitted that the assessee is not vigilant in taking the legal remedies by filing appeals before the NFAC and the assessee not properly explained the delay before NFAC. Hence, the appeals are not admitted by the NFAC. 5. We have heard the rival submissions and perused the materials available on record. The assessee explained the delay

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.

4. The ld. D.R. submitted that the assessee is not vigilant in taking the legal remedies by filing appeals before the NFAC and the assessee not properly explained the delay before NFAC. Hence, the appeals are not admitted by the NFAC. 5. We have heard the rival submissions and perused the materials available on record. The assessee explained the delay

K. P. NANJUNDI VISHWAKARMA,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BENGALURU

In the result, all the appeals of the assessee are partly\nallowed for statistical purposes

4 of 30\nAY 2016-17 18-03-2021 | 18-04-2021 | 11-03-2023 | 692 days delay\nAY 2017-18 | 18-03-2021 | 18-04-2021 | 12-03-2023 693 days delay\nAY 2018-19 | 18-03-2021 | 18-04-2021 | 12-03-2023 693 days delay\n5. Penalty appeals 274 r.w.s. 271AAB\nThe Ld.CIT(A) noted that assessee

K. P. NANJUNDI VISHWAKARMA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BENGALURU

In the result, all the appeals of the assessee are partly\nallowed for statistical purposes

condoned the delay.", "result": "Partly Allowed", "sections": [ "153A", "143(3)", "153D", "274", "271(1)(c)", "271AAB", "154", "132", "246A", "139(4)", "5

M/S. SJS ENTERPRISES LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

In the result, appeal of the assessee is dismissed

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Year:2017-18

condonation of delay and therefore was unjustified in rejecting the appeal. 2. The Ld. CIT(A) was unreasonable and grossly erred by not considering the merits of the case before rejecting the appeal. 3. The Ld. CIT(A) ought to have appreciated that intimation under section 143(1) of the Act [rectification order under section 154 of the Act dated

M/S. S J S ENTERPRISES LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME, CIRCLE-6(1)(1), BANGALORE

In the result, appeal of the assessee is dismissed

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Years: 2018-19

Section 37 of the Arbitration and Conciliation Act was not condonable. 25. This Court is, however, not inclined to entertain this Special Leave Petition since the Petitioners have failed to show sufficient cause for the condonation of the inordinate delay of 337 days in filing the Appeal in the High Court. Moreover, there are no grounds for interference with

M/S. CHITRADURGA NIRMITHI KENDRA,CHITRADURGA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), DAVANGERE

In the result, appeal of the assessee is dismissed

4 days. However, in\nthe present case, the delay was inordinate which is 2006 days. That\nprinciple cannot be applied herein. In our opinion, the law assists\nthose who are vigilant, not those sleep over their rights. The delay\ncannot be condoned simply because the assessee's case calls for a\nsmooth or merely out of benevolence to the party

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

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

4 of 23\ndeficiency letter was received for appeal filed against penalty orders.\nThe assessee was under a bonafide belief that the penalty appeal will\nbe decided only after adjudication of quantum proceedings wherein\na remand report was to be obtained from the assessing officer on\nmutuality aspect and opportunity of hearing will be provided for\npenalty appeal. However

JURIMATRIX SERVICES INDIA PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 4(3)(1), BENGALURU

In the result, appeal of the assessee is dismissed

Bench: Shri Waseem Ahmed\Nand\Nshri Keshav Dubey\Nita No.92/Bang/2025\N Assessment Years:2018-19\Njurimatrix Services India Pvt. Ltd.\Ng4, Aspen Building\Nmanyata Embassy Business Park\Nhebbal\Nbangalore 560045\Npan No: Aabcj6157D\Nappellant\Nacit\Nvs. Circle 4(3)(1)\Nbangalore\Nrespondent\Nappellant By : Sri K.R. Girish, A.R.\Nrespondent By : Ms. Neha Sahay, D.R.\Ndate Of Hearing : 21.04.2025\Ndate Of Pronouncement: 15.07.2025\Norder\Nper Keshav Dubey:\Nthis Appeal At The Instance Of The Assessee Is Directed Against\Nthe Order Of The Ld. Pcit Dated 30.03.2023 Vide Din & Order No.\Nitba/Rev/F/Rev5/2022-23/1051648832(1) Passed U/S 263 Of\Nthe Income Tax Act, 1961 (In Short “The Act”) For The Assessment\Nyear 2018-19.\N2. The Assessee Has Raised The Following Grounds Of Appeal:\Ngeneral Grounds Of Appeal\N1.

4 of 6\nServices India\nBangalore\nJuriMat\nITA No.92/Bang/2025\nJurimatrix Services India Private Limited, Bangalore\nPage 9 of 19\nJURIMATRIX SERVICES INDIA PRIVATE LIMITED\nRequest for condonation of delay\nby the Ld. PCIT, and a direction to pass fresh assessment order was made to the Ld.\nAO. The Company accepted the adjustments proposed by the Ld. PCIT

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

4 of 23\nITA Nos.699 to 704/Bang/2024\nThe Karnataka Chemists & Druggists Association, Bangalore\ndeficiency letter was received for appeal filed against penalty orders.\nThe assessee was under a bonafide belief that the penalty appeal will\nbe decided only after adjudication of quantum proceedings wherein\na remand report was to be obtained from the assessing officer on\nmutuality aspect and opportunity

M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojariassessment Year: 2018-19

condone the above delay and admit the appeal for adjudication. 4. The first ground for our consideration is with regard to the disallowance of Rs.99,02,829/-, which is claimed by assessee as an interest payment. The assessee in the year under consideration advanced a sum of Rs.41 crores towards purchase of shares. The AO questioned the sources of Rs.41

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section 1 2012-13 144 2 2012-13 147* 3 2013-14 144 4 2014-15 144 5 2015-16 143(3)* (not ex- parte) 7.2 However, all the orders of CIT(A) passed for all these assessment years are ex-parte without participation of assessee, wherein he has not condoned the delay

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section 1 2012-13 144 2 2012-13 147* 3 2013-14 144 4 2014-15 144 5 2015-16 143(3)* (not ex- parte) 7.2 However, all the orders of CIT(A) passed for all these assessment years are ex-parte without participation of assessee, wherein he has not condoned the delay

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section 1 2012-13 144 2 2012-13 147* 3 2013-14 144 4 2014-15 144 5 2015-16 143(3)* (not ex- parte) 7.2 However, all the orders of CIT(A) passed for all these assessment years are ex-parte without participation of assessee, wherein he has not condoned the delay

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section 1 2012-13 144 2 2012-13 147* 3 2013-14 144 4 2014-15 144 5 2015-16 143(3)* (not ex- parte) 7.2 However, all the orders of CIT(A) passed for all these assessment years are ex-parte without participation of assessee, wherein he has not condoned the delay

SREESHARADA CREDIT CO-OPERATIVE SOCIETY LTD,UDUPI vs. ITO WARD- 1&TPS , UDUPI

In the result both the appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi

4 June 2025 the appeals were filed as per the advice of the chartered accountant through the counsel. Therefore, filing of appeals for both the years got delayed by 247 days. It was submitted that the delay is unintentional, due to circumstances beyond the control of the assessee, for sufficient cause and therefore may be condoned. 5. The learned departmental

SREESHARADA CREDIT CO-OPERATIVE SOCIETY LTD,UDUPI vs. ITO WARD- 1&TPS , UDUPI

In the result both the appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi

4 June 2025 the appeals were filed as per the advice of the chartered accountant through the counsel. Therefore, filing of appeals for both the years got delayed by 247 days. It was submitted that the delay is unintentional, due to circumstances beyond the control of the assessee, for sufficient cause and therefore may be condoned. 5. The learned departmental

SRI. SUHAS SURESH SHET,BENGALURU vs. INCOME TAX OFFICER, INTERNATIONAL TAXATION, WARD-2(1), BENGALURU

In the result, these two assessee’s appeals are treated as partly allowed for statistical purposes

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

Section 5 must receive a liberal construction so as to advance substantial justice and generally delays in preferring appeals are required to be condoned in the the interest of justice where no gross negligence or deliberate inaction or lack of bona fides is imputable to the party seeking condonation of the delay.".... (c) In this context, we may refer with