SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory

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

12A of the Act, granted vide order dated 23/05/1996. The assessee filed its return of income, declaring NIL income after claiming exemption under Section 11 of the Act. Subsequently, the case was selected for scrutiny under CASS due to payments made to persons specified under Section 13(3) of the Act. The details of such payments are as follows: Party

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

12A of the Act, granted vide order dated 23/05/1996. The assessee filed its return of income, declaring NIL income after claiming exemption under Section 11 of the Act. Subsequently, the case was selected for scrutiny under CASS due to payments made to persons specified under Section 13(3) of the Act. The details of such payments are as follows: Party

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

Section\n153D. It is not an exercise dealing with a immaterial matter which\ncould be corrected by taking recourse to Section 292B of the Act.\n16. We are not inclined to interdict the order of the Tribunal.\n17. Accordingly, the appeal is closed.\n6.5 The above view taken by the Hon’ble Delhi High Court in the case of PCIT

M/S. VIJAYANAGAR EDUCATIONAL TRUST,BENGALURU vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), BENGALURU

In the result appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2019-20

B by the appellant. The provision of section 12A(1) (ba) were introduced with effect from 1/4/2018 and therefore for the impugned assessment year., the ld CIT E could not have cancelled the registration u/s 12 A of the Truste by invoking Provision of section 12 AA (4) of the Act. Further mere delay in filing the return of income

M/S. SYNDICATE BANK,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, UDUPI

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

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year : 2013-14

b) Disallowance u/s 40(a)(ia) of the Act (c) Whether the Provision for bad and doubtful debts is not liable to be added to net profit u/s 115JB of the Act. ITA No.1884/Bang/2018 & M/s. Canara Bank, Bangalore Page 3 of 20 5. We shall first take up the appeal filed by the assessee. The first issue relates

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

12A and Exemption u/s. 11 of the Act continued. On the basis of search u/s. 132 on 6.8.2015 and on similar facts and same reasoning as in AY 2010-11, the AO determined the total income at Rs.121,63,33,681 on the following components :- i. Surplus set apart u/s. 11(1)(a) – Rs.19,21,19,133. ii. Surplus accumulated

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

12A and Exemption u/s. 11 of the Act continued. On the basis of search u/s. 132 on 6.8.2015 and on similar facts and same reasoning as in AY 2010-11, the AO determined the total income at Rs.121,63,33,681 on the following components :- i. Surplus set apart u/s. 11(1)(a) – Rs.19,21,19,133. ii. Surplus accumulated

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

12A and Exemption u/s. 11 of the Act continued. On the basis of search u/s. 132 on 6.8.2015 and on similar facts and same reasoning as in AY 2010-11, the AO determined the total income at Rs.121,63,33,681 on the following components :- i. Surplus set apart u/s. 11(1)(a) – Rs.19,21,19,133. ii. Surplus accumulated

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

12A and Exemption u/s. 11 of the Act continued. On the basis of search u/s. 132 on 6.8.2015 and on similar facts and same reasoning as in AY 2010-11, the AO determined the total income at Rs.121,63,33,681 on the following components :- i. Surplus set apart u/s. 11(1)(a) – Rs.19,21,19,133. ii. Surplus accumulated

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

12A and Exemption u/s. 11 of the Act continued. On the basis of search u/s. 132 on 6.8.2015 and on similar facts and same reasoning as in AY 2010-11, the AO determined the total income at Rs.121,63,33,681 on the following components :- i. Surplus set apart u/s. 11(1)(a) – Rs.19,21,19,133. ii. Surplus accumulated

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

12A and Exemption u/s. 11 of the Act continued. On the basis of search u/s. 132 on 6.8.2015 and on similar facts and same reasoning as in AY 2010-11, the AO determined the total income at Rs.121,63,33,681 on the following components :- i. Surplus set apart u/s. 11(1)(a) – Rs.19,21,19,133. ii. Surplus accumulated

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

12A and Exemption u/s. 11 of the Act continued. On the basis of search u/s. 132 on 6.8.2015 and on similar facts and same reasoning as in AY 2010-11, the AO determined the total income at Rs.121,63,33,681 on the following components :- i. Surplus set apart u/s. 11(1)(a) – Rs.19,21,19,133. ii. Surplus accumulated

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

12A of the Act vide order dated 22-2-2016. Against the order of Ld, CIT(Ex) assessee preferred an appeal who directed the Revenue to provide an opportunity of cross-examination to assessee. Accordingly, appeal was allowed for statistical purpose." 9.40 He also relied on the case CIT Vs. S. Khader Khan Son reported

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

12A of the Act vide order dated 22-2-2016. Against the order of Ld, CIT(Ex) assessee preferred an appeal who directed the Revenue to provide an opportunity of cross-examination to assessee. Accordingly, appeal was allowed for statistical purpose." 9.40 He also relied on the case CIT Vs. S. Khader Khan Son reported

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

12A of the Act vide order dated 22-2-2016. Against the order of Ld, CIT(Ex) assessee preferred an appeal who directed the Revenue to provide an opportunity of cross-examination to assessee. Accordingly, appeal was allowed for statistical purpose." 9.40 He also relied on the case CIT Vs. S. Khader Khan Son reported

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

12A of the Act vide order dated 22-2-2016. Against the order of Ld, CIT(Ex) assessee preferred an appeal who directed the Revenue to provide an opportunity of cross-examination to assessee. Accordingly, appeal was allowed for statistical purpose." 9.40 He also relied on the case CIT Vs. S. Khader Khan Son reported

SHRI. BHADRESHWAR EDUCATION AND SOCIAL WELFARE TRUST,BIJAPUR vs. INCOME TAX OFFICER, WARD-1 EXEMPTION , GULBARGA

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2021-22

section 12A(1)(b) of the Act, the audit report in form No.10B is required to be filed one month prior to the due date for furnishing the return of income u/s. 139(1) of the Act. Considering the facts and legal position, the Ld. ADDL/JCIT(A)-1, Gurugram held that the CPC has rightly disallowed

RAJIV GANDHI UNIVERSITY OF HEALTH SCIENCES,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CPC, BANGALORE

In the result, the appeal filed by the assessee in ITA No

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

12A and the return of income for the year under consideration was filed on 17/10/2016 declaring Nil income along with Form 10 and claimed refund of Rs.4,71,96,140/-. The assessee subsequently revised its return on 31/03/2017 with Nil income along with Form 10 claiming the refund of Rs.4,71,96,140/-. 2.2 The CPC, Bangalore issued intimation dated