SRI SRINIVASA TRUST,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowed these expenses and added the same to the total income of the assessee. 10. Aggrieved by this decision, the assessee preferred an appeal before the Ld. CIT(A) and submitted that the definition of "income" for the purpose of section 11 differs from the definition of "total income" under Section 2(45) of the Act. The assessee argued that

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

disallowances made by the AO were deleted, and the assessee's claim for exemption under Section 11 was upheld.", "result": "Allowed", "sections": [ "Section 11", "Section 13(8)", "Section 2(15)", "Section 43B", "Section 234A", "Section 234B", "Section 143(3)", "Section 153(1)", "Section 250", "Section 11(1)(b)", "Section 11(6

DODDABALLAPUR PLANNING AUTHORITY,BANGALORE vs. ITO, EXEMPTION, WARD-3, BANGALORE

In the result appeal of the assessee is hereby dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

disallowed as the appellant assessee failed to file Form 9A within the due date. (ii) Section 11(1) explicitly mandates the filing of Form 9A for the accumulation of income for the charitable purpose to ensure transparency and accountability in the utilization of fund for charitable activities. ITA Nos.2115 & 2116/Bang/2024 Doddaballapur Planning Authority, Doddaballapur Page

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

6) without\nappreciating that the said provision is not applicable in the\npresent case.\n6.2 On facts and circumstances of the case and law\napplicable, excess application of income of earlier years\nshould be set off with the income assessable. if any, for\nthe year under consideration.\n7. Levy of interest under section 234A and 234B\n7.1 The learned AO/CIT

ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

Bench: Shri George George K & Shri Waseem Ahmed

6 of 23 be limited to the extent of excessive payments made to the specified entities. Furthermore, the learned CIT(A) deleted the addition/disallowance made by the Assessing Officer (AO), concluding that the payments made to the specified persons were neither excessive nor in violation of Section 13(1)(c) of the Act. The relevant observations of the learned

ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

Bench: Shri George George K & Shri Waseem Ahmed

6 of 23 be limited to the extent of excessive payments made to the specified entities. Furthermore, the learned CIT(A) deleted the addition/disallowance made by the Assessing Officer (AO), concluding that the payments made to the specified persons were neither excessive nor in violation of Section 13(1)(c) of the Act. The relevant observations of the learned

VAIDYA SRIKANTAPPA SADASHIVAIAH SRIKANTH,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE- 1, , BANGALORE

11 is made, then such proceedings shall continue under\nthe provisions of the Act of 1894. It contemplates that such pending\nproceedings, as on the date on which the Act of 2013 came into force shall\ncontinue, and taken to their logical end. However, the exception to Section\n24(1)(b) is provided in Section 24(2) in case

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, , BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No:Aaajk0398K\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

section 11(6) of the Act, the depreciation claimed by the assessee amounting to Rs.65,39,240/- was also disallowed

M/S INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

6. disallowance confirmed under section 40(a)(ia) to the extent of Rs. 1,45,000 is bad in law and liable to be quashed. Without prejudice, the learned CIT(A) has erred in not restricting the 7. impugned disallowance, if any, to Rs.43,500 being 30% of Rs. 1,45,000 as the amendment to section

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

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

6. disallowance confirmed under section 40(a)(ia) to the extent of Rs. 1,45,000 is bad in law and liable to be quashed. Without prejudice, the learned CIT(A) has erred in not restricting the 7. impugned disallowance, if any, to Rs.43,500 being 30% of Rs. 1,45,000 as the amendment to section

VIJAYKIRAN EDUCATIONALTRUST,BANGALORE KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BANGALORE

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

Bench: Shri Chandra Poojari & Shri Soundararajan K.Assessment Year: 2018-19

section 11 (6) of the Act but no submission/ reply was furnished by the assessee. Further, a detailed show cause notice alongwith draft assessment order was issued to the assessee by the AO on 16.04.2021 requiring the assessee to show cause as to why amount of Rs. 6,67,36,705/- may not be disallowed

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No :Aaajk0398K\Nappellant\Nrespondent\N\Nappellant By\Nrespondent By\N: Sri Padamchand Khincha, A.R.\N: Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing\N: 17.09.2025\Ndate Of Pronouncement\N: 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed\Nagainst The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide\Ndin & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For\Nthe Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With\Ndin & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For\Nthe Assessment Year 2015-16 Passed U/S 250 Of The Income Tax\Nact, 1961 (In Short “The Act”). Since The Issues In Both The Appeals\Nare Similar, These Are Clubbed Together, Heard Together And\Ndisposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025\Nfor The Assessment Year 2021-22 For Adjudication. The Assessee\Nhas Raised The Following Grounds Of Appeal:\N\N1. General Ground\N1.

11.\n9. 3. On facts and circumstances of the case and law applicable, impugned disallowance under\nsection 43B amounting to Rs.17,67,052 is bad in law and liable to be quashed.\n\n10. Disallowance under section 43B is bad in law\n11.1 The learned Assessing Officer has erred in making additions in respect of various statutory\nand contractual liabilities

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

11 of the Act.\n47.\nThe aggrieved assessee preferred an appeal before the learned\nCIT(A) and contended that there was no incriminating material found in\nrelation to the year under consideration. Therefore, the proceedings\nunder section 153A of the Act cannot be initiated for the year under\nconsideration and assessment made in the absence of incriminating\nmaterial being unearthed

SHREE SUBRAHMANYA TEMPLE ,THOKUR vs. ITO, EXEMPTIONS, WARD-2, MANGALORE

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

Bench: Shri Waseem Ahmedassessment Year: 2016-17

disallowed the bank deposit as application for charitable purposes and further denied the assessee’s claim for accumulation under section 11(1) and section 11(2) of the Act, mainly because no Form 10 was filed in time and the return was belated. In this regard, I find that under section 11(1) of the Act, the assessee is entitled

VOKKALIGARA SANGHA ,CHIKBALLAPUR vs. INCOME TAX OFFICER, EXEMPTIONS, WARD-3, , BANGALORE

6\nITA No.1210/Bang/2024", "summary": {"facts": "The assessee, a public charitable trust, claimed exemption under section 11 of the Act for an amount set apart for building construction. This claim was disallowed

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

6) of the Act.\nHence, the impugned seized material evidences receipt of capitation\nfees, considering the statement of cashier and agent and corroborative\nmaterials found. As such all these materials become a self-speaking\ndocument having bearing on the income of the assessee.\n5.1 Hence, the AO drawn inference that the assessee has received\nunaccounted capitation fees in cash. Accordingly

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)

6. The Learned AO failed to appreciate that the\nproposed addition was towards “Cash expenditure in\nviolation of provisions of section 40A(3)” in the notice under\nSection 142(1) dated 02.07.2021 which established that\nthe entire expenditure of Rs.17,92,25,000/- otherwise\nqualified for deduction under Section 28 or 37(1).\n15.7.\nThe impugned addition is bad being

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

6) of the Act.\nHence, the impugned seized material evidences receipt of capitation\nfees, considering the statement of cashier and agent and corroborative\nmaterials found. As such all these materials become a self-speaking\ndocument having bearing on the income of the assessee.\n5.1 Hence, the AO drawn inference that the assessee has received\nunaccounted capitation fees in cash. Accordingly

DCIT, CENTRAL CIRCLE-1(4), BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

6) of the Act.\nHence, the impugned seized material evidences receipt of capitation\nfees, considering the statement of cashier and agent and corroborative\nmaterials found. As such all these materials become a self-speaking\ndocument having bearing on the income of the assessee.\n5.1 Hence, the AO drawn inference that the assessee has received\nunaccounted capitation fees in cash. Accordingly