DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

House Property or income under the head Other Sources, being sub leased rental income, and the subleased rental income is taxable without any Page 52 of 55 IT(TP)A No.517 & 570/Bang/2015 adjustment against the business expenditure of STPI units. Accordingly a sum of Rs.1,31,20,320/- is brought to tax under the head Other Sources." 26. The assessee

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeal filed by the Revenue is allowed for statistical purpose

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahuthe Dy. Commissioner Of Vs Shri C. Gangadhara Murthy Income-Tax, No. 322, 3Rd A Corss, 2Nd Block Circle - 6(2)(1) 3Rd Stage, Basaveshwaranagar Bangalore . Bangalore 560079. Pan – Agipg 2668 N (Appellant) (Respondent)

House property Rs.3,48,933 Income from Business Rs.3,12,000 Add: Income from Other sources Rs.5,35,221 Add: Unexplained cash credits in bank accounts Rs.1,12,02,680 Add: Unexplained capital accretion Rs.2,50,00,000 Rs.3,67,37,901 Rs.3,73,98,834 Gross total income 4. Aggrieved by the order of the AO the assessee filed

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:

House Property and Other Sources. Such income was the same as that which was declared in the original return of income filed u/s 139 of the Act on 13.09.2014 and revised return of income filed on 26.09.2016. During the course of search proceedings at the residence of Shri K M Deekshith at the office of M/s Coffee Day Global Limited

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:

House Property and Other Sources. Such income was the same as that which was declared in the original return of income filed u/s 139 of the Act on 13.09.2014 and revised return of income filed on 26.09.2016. During the course of search proceedings at the residence of Shri K M Deekshith at the office of M/s Coffee Day Global Limited

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:

House Property and Other Sources. Such income was the same as that which was declared in the original return of income filed u/s 139 of the Act on 13.09.2014 and revised return of income filed on 26.09.2016. During the course of search proceedings at the residence of Shri K M Deekshith at the office of M/s Coffee Day Global Limited

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:

House Property and Other Sources. Such income was the same as that which was declared in the original return of income filed u/s 139 of the Act on 13.09.2014 and revised return of income filed on 26.09.2016. During the course of search proceedings at the residence of Shri K M Deekshith at the office of M/s Coffee Day Global Limited

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

property as benamidar for the assessee. 89. The Hon'ble Rajasthan High Court in CIT Vs Smt. Sunitha Dhadda 406 ITR 220 held that when the department alleges the receipt of "on-money" the burden of proof is on it to prove the fact with acceptable evidence. 90. The ld. AR briefly rebutting each of the adverse presumptions drawn

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

property as benamidar for the assessee. 89. The Hon'ble Rajasthan High Court in CIT Vs Smt. Sunitha Dhadda 406 ITR 220 held that when the department alleges the receipt of "on-money" the burden of proof is on it to prove the fact with acceptable evidence. 90. The ld. AR briefly rebutting each of the adverse presumptions drawn

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

property as benamidar for the assessee. 89. The Hon'ble Rajasthan High Court in CIT Vs Smt. Sunitha Dhadda 406 ITR 220 held that when the department alleges the receipt of "on-money" the burden of proof is on it to prove the fact with acceptable evidence. 90. The ld. AR briefly rebutting each of the adverse presumptions drawn

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

property as benamidar for the assessee. 89. The Hon'ble Rajasthan High Court in CIT Vs Smt. Sunitha Dhadda 406 ITR 220 held that when the department alleges the receipt of "on-money" the burden of proof is on it to prove the fact with acceptable evidence. 90. The ld. AR briefly rebutting each of the adverse presumptions drawn

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

property as benamidar for the assessee. 89. The Hon'ble Rajasthan High Court in CIT Vs Smt. Sunitha Dhadda 406 ITR 220 held that when the department alleges the receipt of "on-money" the burden of proof is on it to prove the fact with acceptable evidence. 90. The ld. AR briefly rebutting each of the adverse presumptions drawn

SHRI JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

property as benamidar for the assessee. 89. The Hon'ble Rajasthan High Court in CIT Vs Smt. Sunitha Dhadda 406 ITR 220 held that when the department alleges the receipt of "on-money" the burden of proof is on it to prove the fact with acceptable evidence. 90. The ld. AR briefly rebutting each of the adverse presumptions drawn

SHRI. JITENDRA VIRWANI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

property as benamidar for the assessee. 89. The Hon'ble Rajasthan High Court in CIT Vs Smt. Sunitha Dhadda 406 ITR 220 held that when the department alleges the receipt of "on-money" the burden of proof is on it to prove the fact with acceptable evidence. 90. The ld. AR briefly rebutting each of the adverse presumptions drawn

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\npartly allowed and ITA No

House Property and Other Sources. Such\nincome was the same as that which was declared in the original return of income\nfiled u/s 139 of the Act on 13.09.2014 and revised return of income filed on\n26.09.2016. During the course of search proceedings at the residence of\nShri K M Deekshith at the office of M/s Coffee Day Global Limited

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

109 Taxman 403 (Delhi) • Gwalior Rayon Silk Co. Ltd. v. CIT (1983) 14 Taxman 99 (MP) • ITO v G. D. Goenka Public School (No. 2) (2008) 23 SOT 77 (Delhi) • Usha Martin Industries Ltd. v. Asstt. CIT (2004) 86 TTJ 574 (Kol.) • Nestle India Ltd. v. Asstt. CIT (1997) 61 ITD 444 (Delhi) • Indian Airlines Ltd. v Asstt

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

109 Taxman 403 (Delhi) • Gwalior Rayon Silk Co. Ltd. v. CIT (1983) 14 Taxman 99 (MP) • ITO v G. D. Goenka Public School (No. 2) (2008) 23 SOT 77 (Delhi) • Usha Martin Industries Ltd. v. Asstt. CIT (2004) 86 TTJ 574 (Kol.) • Nestle India Ltd. v. Asstt. CIT (1997) 61 ITD 444 (Delhi) • Indian Airlines Ltd. v Asstt

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

109 Taxman 403 (Delhi) • Gwalior Rayon Silk Co. Ltd. v. CIT (1983) 14 Taxman 99 (MP) • ITO v G. D. Goenka Public School (No. 2) (2008) 23 SOT 77 (Delhi) • Usha Martin Industries Ltd. v. Asstt. CIT (2004) 86 TTJ 574 (Kol.) • Nestle India Ltd. v. Asstt. CIT (1997) 61 ITD 444 (Delhi) • Indian Airlines Ltd. v Asstt

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

109 Taxman 403 (Delhi) • Gwalior Rayon Silk Co. Ltd. v. CIT (1983) 14 Taxman 99 (MP) • ITO v G. D. Goenka Public School (No. 2) (2008) 23 SOT 77 (Delhi) • Usha Martin Industries Ltd. v. Asstt. CIT (2004) 86 TTJ 574 (Kol.) • Nestle India Ltd. v. Asstt. CIT (1997) 61 ITD 444 (Delhi) • Indian Airlines Ltd. v Asstt