M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

disallowing the purchases made by the appellant while accepting the entire sales under the facts & circumstances of the case. 5 The appellant denies itself liable to be levied to interest under 2,04,65,598/- sections 234A, B & C of the Act and further the computation of interest was not provided to the appellant as regard to the rate, period

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

disallowing the purchases made by the appellant while accepting the entire sales under the facts & circumstances of the case. 5 The appellant denies itself liable to be levied to interest under 2,04,65,598/- sections 234A, B & C of the Act and further the computation of interest was not provided to the appellant as regard to the rate, period

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

153C of the Act has not been complied with\nor having complied, copy of satisfaction note has not been\nprovided to the appellant and thus the assessment has no\nlegs to stand the test of law.\ne) The orders of the authorities below are bad in law as the\nsearch initiated in the case of the appellant is illegal

NIYAZ SEA FOODS ,MANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , MANGALORE

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

2 of section 143 of the Act was issued on 26.3.2019 calling for the details. In response thereto, assessee through his ld. A.R. appeared before the ld. AO from time to time and furnished the details called for. Finally, assessment was completed u/s 143(3) r.w.s. 153C of the Act vide order dated 17.12.2019. In the order of assessment

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

153C. Assessment of income of any other person. (1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or ITA Nos.619 to 622/Bang/2025 Page

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

153C. Assessment of income of any other person. (1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or ITA Nos.619 to 622/Bang/2025 Page

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

153C. Assessment of income of any other person. (1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or ITA Nos.619 to 622/Bang/2025 Page

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

153C. Assessment of income of any other person. (1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or ITA Nos.619 to 622/Bang/2025 Page

SHANTHA ALIAS SHANTHAMMA,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(4), BANGALORE

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

2) notice is a legal precondition for making an assessment\nunder section 143(3) of the Act, which applies to the year of search too.\nThe AO instead wrongly issued notice under section 153C r.w.s. 153A of\nthe Act for the year of search, i.e. AY 2020-21, which was contrary to\nlaw.\nPage 9 of 22\nITA No.465/Bang/2025

KASIREDDAY RANADHEER REDDY ,BENGALURU vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under

KASIREDDY RANADHEER REDDY ,BENGALURU vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under

KASIREDDY RANADHEER REDDY ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under

KASIREDDY RANADHEER REDDY,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under

KASIREDDY RANADHEER REDDY ,BENGALURU vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under

KASIREDDAY RANADHEER REDDY ,BENGALURU vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under

M/S. REGIONAL OILSEEDS GROWERS CO-OPERATIVE SOCIETIES UNION LIMITED,CHITRADURGA vs. JOINT COMMISSIONER OF INCOME TAX, DAVANGERE

In the result, the appeals filed by the assessee on this issue stands dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153C or after the completion of the assessment, whichever is earlier. (4) Subject to the provisions of sub-section (3), where an assessee calls in question the jurisdiction of an Assessing Officer, then the Assessing Officer shall, if not satisfied with the correctness of the claim, refer the matter for determination under sub-section (2) before the assessment is made

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153C of the Act. However, this statement was retracted by the assessee stating that statement was recorded at the time of search at his residence on 8.2.2018 was prepared by Income Tax Investigating Officer and on which his signature was taken forcibly as against the principles of Income Tax Act and against the principles of natural justice. Hence, return filed

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153C of the Act. However, this statement was retracted by the assessee stating that statement was recorded at the time of search at his residence on 8.2.2018 was prepared by Income Tax Investigating Officer and on which his signature was taken forcibly as against the principles of Income Tax Act and against the principles of natural justice. Hence, return filed

M/S. H. M. CONSTRUCTIONS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL RANGE - 1(4), BANGALORE

In the result, appeals being ITA Nos

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

disallowance of depreciation based on material found in the course of search conducted by the Department in the case of some other person. This judgment also supports the contention of the assessee that no addition could be made in the assessments framed under section 153A of the Act, based on materials found and seized from some other person, unless provisions