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105 results for “house property”+ Section 251(2)clear

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Key Topics

Addition to Income58Disallowance45Section 143(3)44Section 14344Section 153C39Section 153A27Deduction27Section 54F26Depreciation25

DCIT CIRCLE-3(1)91), BENGALURU vs. G CORP PRIVATE LIMITED, BANGALORE

In the result is filed by the learned assessing officer is allowed

ITA 2484/BANG/2025[2014-15]Status: DisposedITAT Bangalore01 Apr 2026AY 2014-15

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubeyassessment Year : 2014-15

For Appellant: None
Section 143Section 143(2)Section 143(3)Section 263

house property of ₹ 100,251,681/–. In the original assessment order, notice under section 143 (2) of the act was undisputedly

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

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

Showing 1–20 of 105 · Page 1 of 6

Section 234B20
Section 14A19
Section 13217
ITA 544/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

251 ITR IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 24 of 56 9, wherein the Supreme Court has upheld the decision of the Madhya Pradesh High Court CITv. Suresh Chandra Mittal [2000] 241 ITR 124 , where in similar circumstances it was held that the initial burden lies on the revenue

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

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

ITA 499/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

251 ITR IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 24 of 56 9, wherein the Supreme Court has upheld the decision of the Madhya Pradesh High Court CITv. Suresh Chandra Mittal [2000] 241 ITR 124 , where in similar circumstances it was held that the initial burden lies on the revenue

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

ITA 497/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

251 ITR IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 24 of 56 9, wherein the Supreme Court has upheld the decision of the Madhya Pradesh High Court CITv. Suresh Chandra Mittal [2000] 241 ITR 124 , where in similar circumstances it was held that the initial burden lies on the revenue

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

ITA 496/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

251 ITR IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 24 of 56 9, wherein the Supreme Court has upheld the decision of the Madhya Pradesh High Court CITv. Suresh Chandra Mittal [2000] 241 ITR 124 , where in similar circumstances it was held that the initial burden lies on the revenue

THE CHITRADURGA CITY MULTI PURPOSE CO-OP SOCIETY,CHITRADURGA vs. CIT, DAVANGERE

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 302/BANG/2014[2010-11]Status: DisposedITAT Bangalore04 Sept 2015AY 2010-11

Bench: Shri. N. V. Vasudevan & Shri. Abraham P. George

For Appellant: Shri. Dinesh P, AdvocateFor Respondent: Shri. Anurag Sahay, CIT - III
Section 143(3)Section 263Section 6Section 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)Section 80P(4)

property and rights of the company, also should be treated as a banking business. No doubt, it is true, as contended by Sri Sesachala that the businesses referred to in clauses (a) to (o) of sub-section (1) of section 6 of the Regulation Act cannot be treated as a banking business within the meaning of clause (b) of section

SRI. K. RAJANNA,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2008-09 is partly allowed

ITA 928/BANG/2014[2008-09]Status: DisposedITAT Bangalore04 Sept 2015AY 2008-09

Bench: Smt. P. Madhavi Devi & Shri Jason P. Boazi.T. A. No.928/Bang/2014 (Assessment Year : 2008-09) Sri K. Rajanna, Hoovadigara Beedhi, Hosuru Bagilu, Anekal Town, Anekal Taluk, Bangalore Dist. …. Appellant. Vs. Dy. Commissioner Of Income Tax, Circle 9(1), Bangalore. ….. Respondent. Appellant By : Shri H. Guruswamy, Itp. Respondent By : Shri P. Dhivahar, Jcit. Date Of Hearing : 21.07.2015. Date Of Pronouncement : 4.9.2015. O R D E R Per Shri Jason P. Boaz, A.M. : This Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-V, Bangalore Dt.24.12.2013 For Assessment Year 2008-09. 2. The Facts Of The Case, Briefly, Are As Under :- 2.1 The Assessee Filed Its Return Of Income For Assessment Year 2008-09 On 2.4.2009 Declaring Income Of Rs.13,43,590 From Business & Long Term Capital Gains (‘Ltcg’). The Return Was Processed Under Section 143(1) Of The Income Tax Act, 1961 (In Short 'The Act'). The Assessing Officer Observed That On Verification Of The Return Of Income, It Was Seen That The Assessee Was In Receipt Of Sale Consideration Of Rs.3,38,00,000 From Sale Of 12 Flats Received From The Developer Consequent To A Joint Development Agreement (‘Jda’)

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Shri P. Dhivahar, JCIT
Section 133ASection 143(1)Section 143(3)Section 147Section 148Section 54

house and claimed exemption in this regard under Section 54 of the Act. 2.2 The Assessing Officer observed that in order to verify the claims of the assessee, a survey under Section 133A of the Act was conducted on 20.1.2010, in the course of which it was found that the assessee has not made investments of the sale proceeds

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

ITA 1344/BANG/2019[2016-17]Status: DisposedITAT Bangalore31 May 2022AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

For Appellant: Shri Ajay Rotti, CA
Section 195Section 201(1)

251 ITR 53 (Mad) and;  decision of Hon’ble Delhi High Court in CIT &Ors. vs Bharti Cellular And Others reported in (2008) 175 Taxman 573 13. He submitted that, in these decisions it was held that, provision of cellular services cannot be treated as technical services. Without prejudice, to the above, the Ld.AR placed reliance on Article

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

ITA 1345/BANG/2019[2017-18]Status: DisposedITAT Bangalore31 May 2022AY 2017-18

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

For Appellant: Shri Ajay Rotti, CA
Section 195Section 201(1)

251 ITR 53 (Mad) and;  decision of Hon’ble Delhi High Court in CIT &Ors. vs Bharti Cellular And Others reported in (2008) 175 Taxman 573 13. He submitted that, in these decisions it was held that, provision of cellular services cannot be treated as technical services. Without prejudice, to the above, the Ld.AR placed reliance on Article

ACIT, BANGALORE vs. SHRI. PRASHANTH PRAKASH, BANGALORE

In the result, the appeal by the Revenue is dismissed, while the Cross Objection by assessee is treated as allowed for statistical purposes

ITA 864/BANG/2014[2009-10]Status: DisposedITAT Bangalore11 Jun 2015AY 2009-10

Bench: Shri N.V. Vasudevan & Shri Abraham P. Georgeassessment Year : 2009-10

For Appellant: Shri H.N. Khincha, CAFor Respondent: Shri P. Dhivahar, Jt. CIT(DR)
Section 143(3)Section 54F

251 CTR 317, had taken a view that under the provisions of section 54F of the Act, the condition precedent was that the capital gain realized from sale of capital asset should have been parted by the assessee and invested in constructing a residential house. If the money is invested in constructing the residential house, merely because the construction

M/S MYSORE INTERCONTINENTAL HOTELS PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2006-07 is allowed

ITA 729/BANG/2014[2006-07]Status: DisposedITAT Bangalore07 Oct 2015AY 2006-07

Bench: Shri Vijaypal Rao & Shri Jason P. Boaz

For Appellant: Shri C. Ramesh, C.AFor Respondent: Shri G. Ramesha, JCIT (D.R)
Section 143(1)Section 143(3)Section 28

2. The learned CIT (Appeals) erred in holding that the gross receipt accounted for by the appellant under the head business represents partly towards the building, assessable under the head ‘House Property’, and the balance under the head business. 3. The learned CIT (Appeals) erred in directing that the income be computed on the same lines as directed

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE vs. M/S INFOSYS LIMITED , BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 809/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R
Section 11Section 14ASection 194JSection 234BSection 40Section 80J

property rights which are not goods. 'vase of any other service being rendered the same falls directly under the ambit of the term services and hence it does not meet its own definition of production. The definition provided by the Hon'ble Apex Court relied upon by the assessee for the term "Things" would also show that a total intangible

M/S INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 735/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R
Section 11Section 14ASection 194JSection 234BSection 40Section 80J

property rights which are not goods. 'vase of any other service being rendered the same falls directly under the ambit of the term services and hence it does not meet its own definition of production. The definition provided by the Hon'ble Apex Court relied upon by the assessee for the term "Things" would also show that a total intangible

SMT. S.M.SHOBA,BENGALURU vs. INCOME TAX OFFICER, WARD - 7(2)(1), BANGALORE

In the result, the appeal filed by assessee stands allowed

ITA 1955/BANG/2019[2016-17]Status: DisposedITAT Bangalore30 Mar 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2016-17 Smt. S.M. Shoba, No. 1489, First Floor, The Income Tax 40Th Cross, 4Th T Block, Officer, Jayanagar, Ward 7 (2)(1), Bangalore – 560 041. Bangalore. Vs. Pan: Cxkps1454H Appellant Respondent Assessee By : Shri Ramasubramanian, Ca : Shri Priyadarshi Mishra, Addl. Revenue By Cit (Dr) Date Of Hearing : 09-02-2022 Date Of Pronouncement : 30-03-2022 Order Per Beena Pillaipresent Appeal Has Been Filed By Assessee Against The Order Dated 05.07.2019 Passed By The Ld.Cit(A)-7, Bangalore For Assessment Year 2016-17 On Following Grounds Of Appeal. “1. That The Order Of The Learned Commissioner Of Income- Tax (Appeals) In So Far It Is Prejudicial To The Interests Of The Appellant Is Bad & Erroneous In Law & Against The Facts & Circumstances Of The Case. 2. That The Learned Commissioner Of Income-Tax (Appeals) Erred In Law & On Facts In Denying The Cost Of The Land For Claiming Exemption U/S. 54F Of The Act On The Ground That Such Land Was Purchased Four Years Prior To The Date Of Sale Of Original Asset. 3. That The Learned Commissioner Of Income Tax (Appeals) Erred In Law & On Facts In Making An Enhancing The Assessment By Making A Of Disallowance From Rs.

For Appellant: Shri Ramasubramanian, CA
Section 54F

251 CTR 371 took the view that, under provisions of section 54F of the Act, the condition preceded is that, capital gains realised from sale of capital asset should have been parted by assessee and invested or constructed a residential house, as the case may be. Hon’ble court also observed that, the essence of the purpose of section

BMM ISPAT LIMITED,HOSPET vs. DCIT, BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 779/BANG/2015[2008-09]Status: DisposedITAT Bangalore10 Apr 2018AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri K.R. Pradeep, C.AFor Respondent: Shri K.V.Arvind, Standing Counsel for Dept
Section 132Section 143(3)Section 153ASection 153DSection 234BSection 234DSection 68

Housing, though the material found in the possession of the other person, the Assessing Officer was justified in considering the same in the proceedings under section 153A of the Act. Further the Act does not contemplate parallel proceedings under section 153A and 153C of the Act. The acceptance of the contention of the assessee would be contrary to the scheme

THE NARAGUND TALUKA PRATHAMIKA SHIKSAK SHIKSAKIYAR CO OP CREDIT S LIMITED ,NARGUND vs. INCOME TAX OFFICER, WARD-1, GADAG

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

ITA 1288/BANG/2024[2018-19]Status: DisposedITAT Bangalore04 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri Siddesh .N. Gaddi, CA
Section 139(1)Section 250Section 63Section 80ASection 80PSection 80P(1)(a)Section 80P(2)(a)Section 80P(2)(i)Section 9

house property owned by the assessee and therefore the disallowance made by the AO is not correct. The assessee also pointed out the mistake in the computation sheet and contended that in the assessment order, the total income has been determined at Rs. 3,09,103/- whereas by mistakenly in the computation sheet, the other interest income was taken

JCIT, BANGALORE vs. M/S BIOCON LTD.,, BANGALORE

In the result, Revenue’s appeal for Assessment Year 2008-09 is dismissed

ITA 1251/BANG/2015[2008-09]Status: DisposedITAT Bangalore25 Apr 2018AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri C. H. Sundar Rao, CIT-1 (D.R)
Section 143(1)Section 143(3)Section 195Section 40

2. Briefly stated, the facts of the case are as under :- 2.1 The assessee, a company in the business of manufacture of enzymes and pharmaceutical ingredients, filed its return of income for Assessment Year 2008-09 on 30.9.2008 declaring income of Rs.336,54,93,391 and Book Profits at Rs.37,84,02,814. The return was processed under Section

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

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

ITA 345/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Aug 2023AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

House [1986] 157 ITR 86 were under the Income Tax Act and the observations made and the test indicated therein were in the context of the wide definition of the word plant given in that Act and, therefore, not of universal application. Obviously, if plant is defined differently under a different provision or if the context so requires

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

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

ITA 308/BANG/2023[2017-18]Status: DisposedITAT Bangalore29 Aug 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

House [1986] 157 ITR 86 were under the Income Tax Act and the observations made and the test indicated therein were in the context of the wide definition of the word plant given in that Act and, therefore, not of universal application. Obviously, if plant is defined differently under a different provision or if the context so requires

SRI. M N SHESHAGIRI,MYSURU vs. INCOME TAX OFFICER, WARD- 2(3), MYSORE

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2203/BANG/2019[2012-13]Status: DisposedITAT Bangalore27 Jan 2020AY 2012-13

Bench: Shri Chandra Poojari

For Appellant: Sri.Ravi Shankar, AdvocateFor Respondent: Sri.Ganesh R.Ghale, Standing Council for DR
Section 139(1)Section 139(5)Section 142(1)Section 234BSection 251(1)Section 54

251(1) of the Act in so far as it is against the Appellant is opposed to law weight of evidence, probabilities, facts and circumstances of the Appellant's case. 2. The appellant denies himself liable to be assessed to total income or Rs.38,22,410/- as against the returned income of Rs. 3,64,610/- on the facts