M/S. ABB LTD.,,BANGALORE vs. THE ADDL. CIT, BANGALORE

In the result appeal by the Assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz Assessment Year : 1997-98

house by the Assessee and that it was not purchased. The Tribunal while deciding the appeal never expressed any doubt as to what was transferred was “Technical Know- how”. The Tribunal only observed that if the costs incurred to develop technical know-how were already claimed as revenue expenses than the gains arising as a result of sale thereof will

SRI. B.V. RAVIKUMAR,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-6(3)(1), BENGALURU

Bench: Smt. Beena Pillai & Ms. Padmavathy S

220 1500000.00 Ch. No. :503397 06-03-2015 To Axis Bank Payment 221 1000000.00 Ch. No. :503372 28-03-2015 By Hdfc Bank Receipt 152 900000.00 30-03-2015 By Janatha Seva Co-Op Bank SB/5928 Receipt 155 2000000.00 Ch. No. :226895 31-03-2015 By Civil Works Incurred at Residential Property Journal 93 21240821.00 Expenses incurred at Residential house

SMT. K.R. GEETHA,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 6(3)(1), BENGALURU

Bench: Smt. Beena Pillai & Ms. Padmavathy S

220 1500000.00 Ch. No. :503397 06-03-2015 To Axis Bank Payment 221 1000000.00 Ch. No. :503372 28-03-2015 By Hdfc Bank Receipt 152 900000.00 30-03-2015 By Janatha Seva Co-Op Bank SB/5928 Receipt 155 2000000.00 Ch. No. :226895 31-03-2015 By Civil Works Incurred at Residential Property Journal 93 21240821.00 Expenses incurred at Residential house

SMT. K.R. GEETHA,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 6(3)(1), BENGALURU

Bench: Smt. Beena Pillai & Ms. Padmavathy S

220 1500000.00 Ch. No. :503397 06-03-2015 To Axis Bank Payment 221 1000000.00 Ch. No. :503372 28-03-2015 By Hdfc Bank Receipt 152 900000.00 30-03-2015 By Janatha Seva Co-Op Bank SB/5928 Receipt 155 2000000.00 Ch. No. :226895 31-03-2015 By Civil Works Incurred at Residential Property Journal 93 21240821.00 Expenses incurred at Residential house

SRI. B.V. RAVIKUMAR,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-6(3)(1), BANGALORE

Bench: Smt. Beena Pillai & Ms. Padmavathy S

220 1500000.00 Ch. No. :503397 06-03-2015 To Axis Bank Payment 221 1000000.00 Ch. No. :503372 28-03-2015 By Hdfc Bank Receipt 152 900000.00 30-03-2015 By Janatha Seva Co-Op Bank SB/5928 Receipt 155 2000000.00 Ch. No. :226895 31-03-2015 By Civil Works Incurred at Residential Property Journal 93 21240821.00 Expenses incurred at Residential house

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

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

220/- for the\nAY 2020-21. Likewise, the AO completed the assessment for AY 2021-22\nvide order dated 28th November 2023 assessing the total income at\nRs.138,43,73,474/- as against the returned income of Rs.6,95,140/-.\n\n6. The aggrieved assessee preferred an appeal before the learned\nCIT(A), raising various grounds of appeal challenging

NEKKUNDI SRINIVASA REDDY KESHAVA REDDY,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(4), BENGALURU

In the result, appeals of the assessee are dismissed

Bench: Shri Prashant Maharishi, Hon’Ble & Shri Soundararajan K, Hon’Ble

220/- was assessed. For the A.Y. 2015-16 as per order under section 153C r.w.s. 144 of the Act dated 24.12.2021 the assessment to the extent of Rs.10,03,66,918/- was made taxing the above sum of Long Term Capital Gains. 7. For the A.Y. 2016-17, the assessment order under section 153C r.w.s

NEKKUNDI SRINIVASA REDDY KESHAVA REDDY,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(4), BENGALURU

In the result, appeals of the assessee are dismissed

Bench: Shri Prashant Maharishi, Hon’Ble & Shri Soundararajan K, Hon’Ble

220/- was assessed. For the A.Y. 2015-16 as per order under section 153C r.w.s. 144 of the Act dated 24.12.2021 the assessment to the extent of Rs.10,03,66,918/- was made taxing the above sum of Long Term Capital Gains. 7. For the A.Y. 2016-17, the assessment order under section 153C r.w.s

NEKKUNDI SRINIVASA REDDY KESHAVA REDDY,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(4), BENGALURU

In the result, appeals of the assessee are dismissed

Bench: Shri Prashant Maharishi, Hon’Ble & Shri Soundararajan K, Hon’Ble

220/- was assessed. For the A.Y. 2015-16 as per order under section 153C r.w.s. 144 of the Act dated 24.12.2021 the assessment to the extent of Rs.10,03,66,918/- was made taxing the above sum of Long Term Capital Gains. 7. For the A.Y. 2016-17, the assessment order under section 153C r.w.s

NEKKUNDI SRINIVASA REDDY KESHAVA REDDY,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(4), BENGALURU

In the result, appeals of the assessee are dismissed

Bench: Shri Prashant Maharishi, Hon’Ble & Shri Soundararajan K, Hon’Ble

220/- was assessed. For the A.Y. 2015-16 as per order under section 153C r.w.s. 144 of the Act dated 24.12.2021 the assessment to the extent of Rs.10,03,66,918/- was made taxing the above sum of Long Term Capital Gains. 7. For the A.Y. 2016-17, the assessment order under section 153C r.w.s

GEORGE JOSEPH FERNANDEZ,RAICHUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAICHUR

In the result, appeals of the assessee are partly allowed for statistical purpose

Bench: Shri. A. K. Garodia

house property. It was submitted that the addition should be restricted to the difference in the amount i.e., Rs.1,80,000 with the statutory deduction of 30% under section 24 (a) of the Act. Our attention was drawn to the balance sheet at page 91 to 93. 15. The Ld. DR relies upon the order of the lower authorities

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