DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

section 147 of the Act.\nIn view of the aforesaid, we answer the first two substantial questions of law in\nfavour of the Revenue and against the assessee.”\n10.1 In view of the binding decision of Hon'ble Karnataka High\nCourt, we are not agreeing with the contention of ld. A.R. This\nground raised by assessee in its CO Nos.15

DEPUTY COMMISSIONER OF INCOME-TAX, , BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 147 of the Act. In view of the aforesaid, we answer the first two substantial questions of law in favour of the Revenue and against the assessee.” 10.1 In view of the binding decision of Hon’ble Karnataka High Court, we are not agreeing with the contention of ld. A.R. This ground raised by assessee in its CO Nos.15

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 147 of the Act. In view of the aforesaid, we answer the first two substantial questions of law in favour of the Revenue and against the assessee.” 10.1 In view of the binding decision of Hon’ble Karnataka High Court, we are not agreeing with the contention of ld. A.R. This ground raised by assessee in its CO Nos.15

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BANGALORE

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 147 of the Act. In view of the aforesaid, we answer the first two substantial questions of law in favour of the Revenue and against the assessee.” 10.1 In view of the binding decision of Hon’ble Karnataka High Court, we are not agreeing with the contention of ld. A.R. This ground raised by assessee in its CO Nos.15

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY ENTERPRISES, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 147 of the Act. In view of the aforesaid, we answer the first two substantial questions of law in favour of the Revenue and against the assessee.” 10.1 In view of the binding decision of Hon’ble Karnataka High Court, we are not agreeing with the contention of ld. A.R. This ground raised by assessee in its CO Nos.15

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

depreciation and the scope of section 153A in cases of search.", "result": "Allowed", "sections": [ "14A", "8D", "132", "148", "153A", "143(3)", "154", "234B", "234D", "32(1)(iia)", "2(29A)", "147

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

depreciation.", "result": "Allowed/Dismissed", "sections": ["14A", "32(1)(iia)", "143(3)", "147", "148", "153A", "234B", "234D"], "issues": "Whether disallowance under Section

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

depreciation under Section 32(1)(iia) is allowable for the process of converting raw coffee beans into liquid coffee, as it constitutes manufacturing. The reassessment proceedings under Section 153A were dismissed if no incriminating material was found and the assessment was already concluded.", "result": "Dismissed", "sections": [ "14A", "Rule 8D", "143(3)", "147

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

section 147 of the Act.\nIn view of the aforesaid, we answer the first two substantial questions of law in\nfavour of the Revenue and against the assessee.\"\n10.1 In view of the binding decision of Hon'ble Karnataka High\nCourt, we are not agreeing with the contention of ld. A.R. This\nground raised by assessee in its CO Nos.15

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY GLOBAL LIMITED, BANGALORE

In the result, all the COs by assessee in CO\nNos

section 147 of the Act.\nIn view of the aforesaid, we answer the first two substantial questions of law in\nfavour of the Revenue and against the assessee.”\n10.1 In view of the binding decision of Hon'ble Karnataka High\nCourt, we are not agreeing with the contention of ld. A.R. This\nground raised by assessee in its CO Nos.15

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

section 147 of the Act.\nIn view of the aforesaid, we answer the first two substantial questions of law in\nfavour of the Revenue and against the assessee.”\n10.1 In view of the binding decision of Hon'ble Karnataka High\nCourt, we are not agreeing with the contention of ld. A.R. This\nground raised by assessee in its CO Nos.15

M/S. TOYOTA KIRLOSKAR MOTOR PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, , BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2011-12 M/S. Toyota Kirloskar Motor Pvt. Ltd. Plot No.1, Bidadi Industrial Area So Bidadi Acit Vs. Ramanagar Ltu, Circle-1 Bengaluru 562 109 Banalore Pan No : Aaact5415B Appellant Respondent Appellant By : Sri Padam Chand Kincha, A.R. Respondent By : Smt. Kumutha D., D.R. Date Of Hearing : 24.09.2024 Date Of Pronouncement : 20.12.2024

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in Sections 148 to 153 referred to as the relevant assessment year)." 3.2 After the Amending Act, 1989, Section 147

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, appeals filed by the assessee are partly allowed in above\nterms

depreciation allowance or any other allowance\nunder this Act has been computed;]\n31[(ca) where a return of income has not been furnished by the assessee or a\nreturn of income has been furnished by him and on the basis of\ninformation or document received from the prescribed income-tax\nauthority, under sub-section (2) of section 133C

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

depreciation allowance or any other allowance under this Act has been computed;] 31[(ca) where a return of income has not been furnished by the assessee or a return of income has been furnished by him and on the basis of information or document received from the prescribed income-tax authority, under sub-section (2) of section 133C

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

depreciation allowance or any other allowance\nunder this Act has been computed;]\n31[(ca) where a return of income has not been furnished by the assessee or a\nreturn of income has been furnished by him and on the basis of\ninformation or document received from the prescribed income-tax\nauthority, under sub-section (2) of section 133C

KOGOD BASAVARAJU JAYACHANDRA ,HASSAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result the ITA No

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

depreciation allowance or any other allowance under this Act has been computed;] 31[(ca) where a return of income has not been furnished by the assessee or a return of income has been furnished by him and on the basis of information or document received from the prescribed income-tax authority, under sub-section (2) of section 133C

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 143(1) had been issued. ITA Nos.62 to 66/Bang/2023 M/s. Yashaswi Fish Meal and Oil Company, Udupi Page 6 of 85 4.4 Same view is fortified by the judgement of Hon’ble Supreme Court in the case of ACIT Vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd. reported in 291 ITR 500 (SC). 4.5 The ld. A.R. relied

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 143(1) had been issued. ITA Nos.62 to 66/Bang/2023 M/s. Yashaswi Fish Meal and Oil Company, Udupi Page 6 of 85 4.4 Same view is fortified by the judgement of Hon’ble Supreme Court in the case of ACIT Vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd. reported in 291 ITR 500 (SC). 4.5 The ld. A.R. relied