M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALURU

In the result, appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Keshav Dubey

132(4) of the Act. However, this statement cannot, on a standalone basis, without reference to any other material discovered during search and seizure operations, empower the AO to frame the block assessment.” [Emphasis in bold and underline supplied] (vii) Honourable Mumbai Bench of ITAT in Arihant Universal Realty (P.) Ltd. v. DCIT( ITA NO. 4342/2017 dated 05.04.2022 ) held

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

Section 132(4) of the Act cannot be the sole basis for making additions unless corroborated by other independent evidence. The addition for AY 2014-15 on account of salary income was deleted. For AY 2018-19, the Tribunal found no corroborative material to support the disallowance

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

section 132(4) of the Act. The Tribunal has\ncommitted an error in ignoring the retraction made by the assessee.\"\n\"16.4 We have duly considered the contention of the assessee and also\nperused the documentary evidences produced by the assessee. On\nperusing the facts, it is apparent that the addition is made based on the\ngeneral practice of cash

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

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

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31

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

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31

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

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31

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

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31

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

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31

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

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31

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

4,31,496 Total Taxable Income 31,69,54,864 9. Consequently, on the basis of search u/s. 132 on 6.8.2015 and on similar facts and similar reasoning as in AY 2010-11, the AO determined the total income at Rs.46,13,25,960 on the following components:- i. Total Income as per Order u/s. 143(3) – Rs.31

DCIT, CENTRAL CIRCLE-1(3), BAENGALURU vs. LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

132(4) where in answer to Q.No. 51 dated 9/8/2019, she agreed that unaccounted cash sales of around ₹ 1.88 crores were made. (iv) Ms Kansaria also agreed in Q.No. 52, that there is an undisclosed cash sale of Rs 12.83 Crs. being unaccounted sales for 4 Financial years considering 10% of manufacturing sales. (v) On the above statement she admitted

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

132(4) where in answer to Q.No. 51 dated 9/8/2019, she agreed that unaccounted cash sales of around ₹ 1.88 crores were made. (iv) Ms Kansaria also agreed in Q.No. 52, that there is an undisclosed cash sale of Rs 12.83 Crs. being unaccounted sales for 4 Financial years considering 10% of manufacturing sales. (v) On the above statement she admitted

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3) , BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

132(4) where in answer to Q.No. 51 dated 9/8/2019, she agreed that unaccounted cash sales of around ₹ 1.88 crores were made. (iv) Ms Kansaria also agreed in Q.No. 52, that there is an undisclosed cash sale of Rs 12.83 Crs. being unaccounted sales for 4 Financial years considering 10% of manufacturing sales. (v) On the above statement she admitted

LATE SHRI MAHABIR PRASAD(LEGAL HEIR MS. PARUL KANSARIA),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3) , BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

132(4) where in answer to Q.No. 51 dated 9/8/2019, she agreed that unaccounted cash sales of around ₹ 1.88 crores were made. (iv) Ms Kansaria also agreed in Q.No. 52, that there is an undisclosed cash sale of Rs 12.83 Crs. being unaccounted sales for 4 Financial years considering 10% of manufacturing sales. (v) On the above statement she admitted

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. HARIS MARINE PRODUCTS,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, MANGALORE

In the result, both the appeals of the assessee are\nallowed

section 153C of the Act\nnamely discretionary in assets/documents in the course of search\nconducted in the case of any person that belong to the assessee and\nis relevant for computing the income of the assessee for the year\nunder appeal is totally absent.\n3. The facts of the issue are that there was a search u/s 132 of\nthe

MOHAMMED MUJEEB SIKANDER,MANGALORE vs. DCIT, CENTRAL CIRCLE (1), MANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowance of 1,24,17,338/- as under: Date Bank Account details Credit:- Remarks 06.04.2015 ICICI Bank SB 10,00,000.00 This amount is transferred No.055901501971 from NRE A/c to ICICI Bank A/c 26.06.2015 Bharat Co-Operate Bank 15,00,000.00 This amount is transferred A/c.003212100002005 through SRI, to NRE A/c No.65668 30.06.2015 ICICI Bank SB 3,00,000.00 These