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

Bench: Shri Chandra Poojari & Shri Keshav Dubey

House, First Cross N.G. Road, Attavar Manguluru 575 001 Karnataka PAN NO: AAGCM8310E APPELLANT Appellant by Respondent by Date of Hearing Date of Pronouncement DCIT Vs. Central Circle-1 Manguluru RESPONDENT Sri Narendra Sharma, A.R. Ms. Neera Malhotra, D.R. 22.05.2024 03.07.2024 ORDER PER CHANDRA POOJARI, ACCOUNTANT MEMBER: All these appeals by assessee are for the assessment years

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

House, First Cross\nN.G. Road, Attavar\nMangalore 575 001\nKarnataka\nPAN NO : AAGCM8310E\nAPPELLANT\nAppellant by\nRespondent by\nDCIT\nVs.\nCentral Circle-1\nMangalore\nRESPONDENT\nSri Narendra Sharma, A.R.\nMs. Neera Malhotra, D.R.\nDate of Hearing\nDate of Pronouncement\n22.05.2024\n03.07.2024\nORDER\nPER CHANDRA POOJARI, ACCOUNTANT MEMBER:\nAll these appeals by assessee are for the assessment years\n2013

M/S. KHADEER AHMED KHAN,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 4(2)(1), BANGALORE

In the result, assessee’s appeal is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2012-13 Shri. Khadeer Ahmed Khan, The Assistant Commissioner Of No.42, Doddkallasandara, Income-Tax, Kankapura Main Road, Vs. Circle – 4(2)(1), Bengaluru – 560 062. Bengaluru. Pan : Aavpk 1742 Q Assessee Respondent Assessee By : Shri. H. Guruswamy, Itp Revenue By : Smt. R. Premi, Jcit (Dr)(Itat), Bengaluru Date Of Hearing : 07.04.2021 Date Of Pronouncement : 14.06.2021

house at the time of transfer of the original asset. The assessee has submitted that the finding of the AO that purchase bills were bogus was also incorrect. 24. The learned DR submitted that the assessee wrongly submitted that footage of Google map was not a conclusive evidence for showing existence or non-existence of the residential property

M/S CANARA HOUSING DEVELOPMENT COMPANY,BANGALORE vs. JCIT, BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

purchases of a sum of Rs. 6,39,124/- representing additional liability towards foreign suppliers in respect of books imported on credit up to the end of 31/05/1966. The said additional claim was based on account of devaluation of Indian currency, which had taken place on 06/06/1966 i.e. after the close of the accounting year. Such a claim was disallowed

YASH VARDHAN ARYA,BANGALORE vs. THE INCOME TAX OFFICER, (INTERNATIONAL TAXATION) WARD-1(1), BANGALORE

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

Bench: Shri George George K

purchase the property for its let out and to earn rental income. Copy of resolution of board of directors was also placed on record, where from it was evident that one of the directors was authorized to take necessary steps to let out the property in question. The assessee had also fixed the monthly rent and the security deposits

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:

purchases in his books of accounts from the said concerns." 9.54 The AO relied on certain scribblings and loose sheets to issue the assessment order. The assessing officer did not provide an opportunity to the assessee to rebut these observations. The assessee has not been provided copy of the materials relied upon to make the said analysis. A perusal

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:

purchases in his books of accounts from the said concerns." 9.54 The AO relied on certain scribblings and loose sheets to issue the assessment order. The assessing officer did not provide an opportunity to the assessee to rebut these observations. The assessee has not been provided copy of the materials relied upon to make the said analysis. A perusal

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:

purchases in his books of accounts from the said concerns." 9.54 The AO relied on certain scribblings and loose sheets to issue the assessment order. The assessing officer did not provide an opportunity to the assessee to rebut these observations. The assessee has not been provided copy of the materials relied upon to make the said analysis. A perusal

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:

purchases in his books of accounts from the said concerns." 9.54 The AO relied on certain scribblings and loose sheets to issue the assessment order. The assessing officer did not provide an opportunity to the assessee to rebut these observations. The assessee has not been provided copy of the materials relied upon to make the said analysis. A perusal

M/S SCANIA COMMERCIAL VEHICLES INDIA PVT LTFD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

The Appeal of the Assessee is allowed

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

house property. The claim of the Assessee is that it is chargeable to tax as profits and gains of business and profession. 5. Coming to the ground no. 17, with respect to the depreciation, the fact shows that Assessee has made an addition of Rs. 15,56,16,965/- and intangible assets were added

DCIT, GULBARGA vs. M/S JUPITERBIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

property runs about more than Rs.6.00 crores and it must be supported by acceptable documentary evidence which documents are not produced by the assessee before the Assessing Officer. The Assessing Officer being a fact finding authority on appreciation of facts and legal evidence on record has recorded a finding of fact holding that non production of the material documents, details

DCIT, GULBARGA vs. M/S JUPITERBIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

property runs about more than Rs.6.00 crores and it must be supported by acceptable documentary evidence which documents are not produced by the assessee before the Assessing Officer. The Assessing Officer being a fact finding authority on appreciation of facts and legal evidence on record has recorded a finding of fact holding that non production of the material documents, details

ACIT, GULBARGA vs. M/S. JUPITER BIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

property runs about more than Rs.6.00 crores and it must be supported by acceptable documentary evidence which documents are not produced by the assessee before the Assessing Officer. The Assessing Officer being a fact finding authority on appreciation of facts and legal evidence on record has recorded a finding of fact holding that non production of the material documents, details

DCIT, GULBARGA vs. M/S JUPITER BIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

property runs about more than Rs.6.00 crores and it must be supported by acceptable documentary evidence which documents are not produced by the assessee before the Assessing Officer. The Assessing Officer being a fact finding authority on appreciation of facts and legal evidence on record has recorded a finding of fact holding that non production of the material documents, details

DCIT, GULBARGA vs. M/S JUPITER BIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

property runs about more than Rs.6.00 crores and it must be supported by acceptable documentary evidence which documents are not produced by the assessee before the Assessing Officer. The Assessing Officer being a fact finding authority on appreciation of facts and legal evidence on record has recorded a finding of fact holding that non production of the material documents, details

DCIT, GULBARGA vs. M/S JUPITER BIOSCIENCE LTD.,, BIDAR

In the result, appeal by the revenue is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

property runs about more than Rs.6.00 crores and it must be supported by acceptable documentary evidence which documents are not produced by the assessee before the Assessing Officer. The Assessing Officer being a fact finding authority on appreciation of facts and legal evidence on record has recorded a finding of fact holding that non production of the material documents, details

M/S DELTA INFRALOGISTICS WORLDWIDE LIMITED,MANGALORE vs. ACIT, MANGALORE

In the result, the assessee’s appeals for Assessment Years 2003-04 to 2008-

Bench: Shri N. V. Vasudevan & Shri Jason P Boazappeal Nos. & Appellant Respondent Assessment Years

house agents at Mangalore. A search and seizure action under section 132 of the Income Tax Act, 1961 (in short ‘the Act’) was conducted at the premises of the assessee on 17.01.2008. Survey under section 133A of the Act was also conducted at the port premises of the assessee. In the course of the search, certain documents were found

DCIT, MANGALORE vs. M/S DELTA INFRALOGISTICS WORLDWIDE LTD, MANGALORE

In the result, the assessee’s appeals for Assessment Years 2003-04 to 2008-

Bench: Shri N. V. Vasudevan & Shri Jason P Boazappeal Nos. & Appellant Respondent Assessment Years

house agents at Mangalore. A search and seizure action under section 132 of the Income Tax Act, 1961 (in short ‘the Act’) was conducted at the premises of the assessee on 17.01.2008. Survey under section 133A of the Act was also conducted at the port premises of the assessee. In the course of the search, certain documents were found

DCIT, MANGALORE vs. M/S DELTA INFRALOGISTICS WORLDWIDE LTD, MANGALORE

In the result, the assessee’s appeals for Assessment Years 2003-04 to 2008-

Bench: Shri N. V. Vasudevan & Shri Jason P Boazappeal Nos. & Appellant Respondent Assessment Years

house agents at Mangalore. A search and seizure action under section 132 of the Income Tax Act, 1961 (in short ‘the Act’) was conducted at the premises of the assessee on 17.01.2008. Survey under section 133A of the Act was also conducted at the port premises of the assessee. In the course of the search, certain documents were found