AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

144(3) r.w.s. 144C(3) or section 144C(13) of the Act. Therefore, the non-signing of the draft Assessment Order forwarded to the assessee would not invalidate the final Assessment Order passed IT(IT)A No.66/Bang/2024 Page 11 of 31 under section 143(3) r.w.s. 144C(13) of the Act. Here in the case on hand, assessee

THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU vs. M/S. BLUELINE FOODS (INDIA) PVT. LTD.,, MANGALURU

144 to show cause why the assessment should\nnot be completed to the best of the judgment of the Assessing\nOfficer, whichever is earlier.\"\nThus, section 124 of the Act pertains to territorial jurisdiction of an\nAssessing Officer vested under sub-section (1) or (2) of section 120.\nAn objection to such jurisdiction can be raised in terms of section

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing Board would be denied the benefit of section 32 because in spite of its being the legal owner it was not using the building for its business or profession. We do not think such a benefit-to-none situation could have been intended by the Legislature.” 8.16 In light of the above decision, it is the rightful owner

HANCHIPURA CHANNAIAH NANDAKISHORE,MAHALKSHMIPURAM vs. INCOME TAX OFFICER WARD INTL, TAXATION 1(2) BANGALORE, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.258/Bang/2025 Assessment Year : 2018-19 Hanchipura Channaiah Nandakishore 87, 2Nd Stage & Phase Mahalakshmipuram 2Nd Stage, 14Th Main, West Of Chord Ito Road Vs. Ward International Taxation 1(2) Mahalakshmipuram Bangalore Bangalore 560 086 Pan No :Blrpn0428A Appellant Respondent Appellant By : Sri Siddesh N Gaddi, A.R. Respondent By : Dr. Divya K.J., D.R. Date Of Hearing : 07.08.2025 Date Of Pronouncement : 04.11.2025

144 of the Income Tax Act, 1961 (in short “The Act”) for the assessment year 2018-19. 2. The assessee has raised the following grounds of appeal: IT(IT)A No.258/Bang/2025 HanchipuraChannaiah Nandakishore, Bangalore Page 2 of 16 3. The brief facts are that the case of the assessee was reopened u/s. 147 of the Act after following

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

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

HOUSE PROPERTY 7986790 8716072 9586870 9676227 PGBP 269570718 1237670552 493696985 325550587 STCG 136372 222312 655065 10021 CAPITAL GAIN 12563022 IOS 101974790 51714335 152804718 57852150 TOTAL INCOME 367996150 1286588270 669502500 387279160 RETURN FILED ON139(1) 29.09.2013 28.0902014 30.09.2015 17.10.2016 143 (1) 31.10.2014 1,20,62,015 17.01.2017 80602017 143(3) ( RETURNED INCOME ACCEPTED 29.03.2016 29.12.2016 153C NOTICE

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

HOUSE PROPERTY 7986790 8716072 9586870 9676227 PGBP 269570718 1237670552 493696985 325550587 STCG 136372 222312 655065 10021 CAPITAL GAIN 12563022 IOS 101974790 51714335 152804718 57852150 TOTAL INCOME 367996150 1286588270 669502500 387279160 RETURN FILED ON139(1) 29.09.2013 28.0902014 30.09.2015 17.10.2016 143 (1) 31.10.2014 1,20,62,015 17.01.2017 80602017 143(3) ( RETURNED INCOME ACCEPTED 29.03.2016 29.12.2016 153C NOTICE

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

HOUSE PROPERTY 7986790 8716072 9586870 9676227 PGBP 269570718 1237670552 493696985 325550587 STCG 136372 222312 655065 10021 CAPITAL GAIN 12563022 IOS 101974790 51714335 152804718 57852150 TOTAL INCOME 367996150 1286588270 669502500 387279160 RETURN FILED ON139(1) 29.09.2013 28.0902014 30.09.2015 17.10.2016 143 (1) 31.10.2014 1,20,62,015 17.01.2017 80602017 143(3) ( RETURNED INCOME ACCEPTED 29.03.2016 29.12.2016 153C NOTICE

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

HOUSE PROPERTY 7986790 8716072 9586870 9676227 PGBP 269570718 1237670552 493696985 325550587 STCG 136372 222312 655065 10021 CAPITAL GAIN 12563022 IOS 101974790 51714335 152804718 57852150 TOTAL INCOME 367996150 1286588270 669502500 387279160 RETURN FILED ON139(1) 29.09.2013 28.0902014 30.09.2015 17.10.2016 143 (1) 31.10.2014 1,20,62,015 17.01.2017 80602017 143(3) ( RETURNED INCOME ACCEPTED 29.03.2016 29.12.2016 153C NOTICE

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

144(B) of the Income Tax Act, 1961 wherein the returned income of the Assessee at Rs. Nil/- is assessed at a loss of Rs. 161,63,03,274/-. The Assessee is aggrieved with that and is in appeal before us. ITA Nos. 261 & 777/Bang/2022 Page 2 of 18 2. In the Assessment Order, there is an issue

SMT. CHANDRA MOOLCHAND JAIN,BANGALORE vs. INCOME TAX OFFICER, WARD-6(2)(4), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2015-16

section 40 A (3) should have not been revoked. 15. That the Interest u/s 234 (B) and u/s 234 (C) shall be waived off as Tax itself is not payable. 16. That penalty u/s 271 (1) (c) shall not be applicable as there is no concealment of Income. In the light of the above facts the Assessee prays the Honorable

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page