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

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

378 (Delhi), Hon’ble [TAT Delhi held where the assessee had three STP units that since profits of each of the STP units of the assessee company could not be evaluated independently of one another, and they could not be segregated for the purpose of determining the ALP relating to assessee's international transactions, where the assessee was being remunerated

K S HANUMANTHA RAO,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-2, BANGALORE

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

Bench: Shri George George K

378, Jamadagni, 16A Main Income-tax – 2 v. 36A Cross, 4th T Block, Jayanagar Bangalore. Bangalore – 560 041 PAN : AACPH3083Q. (Appellant) (Respondent) Appellant by : Sri.K.S.Hanumantha Rao, Advocate Respondent by : Sri.Ganesh B.Ghale, Standing Counsel Date of Date of Hearing : 16.03.2021 Pronouncement : 19.03.2021 O R D E R This appeal at the instance of the assessee is directed against CIT’s order

MR.ASLAM ZACKRIA SAIT,BANGALORE vs. INCOME TAX OFFICER, BANGALORE

In the result, appeal filed by the appellant is dismissed

Bench: Shri. Vijay Pal Rao & Shri. Inturi Rama Raoassessment Year : 2012-13

property could not be registered in favour of the appellant only for the reasons which are beyond the control of the appellant. The residential house could not be registered in favour of the appellant on account of delay in the completion of the project by the developer and since the entire consideration had been paid, the deduction should be allowed

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

M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojariassessment Year: 2018-19

378 wherein it was held as follows:- “..... But we are in agreement with the High Court on the other two grounds. As mentioned earlier, the impugned assessments were made in 1949. The writ petition was filed in 1956. The explanation M/s. RMZ Hotels Private Limited, Bangalore Page 9 of 79 given by the petitioner for this long delay is that

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE, BALLARI vs. SHRI. SRIPAL DEVICHAND JAIN, KALABURAGI

In the result, the appeal by the revenue is dismissed and CO by the assessee is partly allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2021-22

house property and other sources. 7. During the impugned assessment year, the Deputy Superintendent of Police, City Division, Davangere had intercepted a vehicle bearing registration No. KA-39/P-8055 at Jagalur bus stand, Davangere on 05.02.2021 and on inspection of the vehicle they found that three persons were carrying cash of Rs. 1,48,00,000/- from Gulbarga to Davangere

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

DCIT, BANGALORE vs. M/S PEOPLE'S EDUCATATION SOCIETY, BANGALORE

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

Bench: Shri. A. K. Garodia & Shri. Lalit Kumari.T.A No.1074/Bang/2016 (Assessment Year : 2011-12) Deputy Commissioner Of Income-Tax (E), Circle -1, Bengaluru .. Appellant V. M/S. Peoples Education Society, 50 Feet Road, Hanumanthanagar, Bsk 1St Stage, Bengaluru 560 050 .. Respondent Pan : Aaatp3955H Assessee By : Shri. Prashanth, C, Ca Revenue By : Shri. Sanjay Kumar, Cit-Iii Heard On : 31.05.2017 Pronounced On : 09.06.2017 O R D E R Per Lalit Kumar:

section 2(45). This proposition is laid down by various judgements of Hon’ble High Courts, namely, (i) CIT v Trustee of H.E.H. Nizam's Supplemental Religious Endowment Trust 127 ITR 378 (AP); (ii) CIT v Rao Bahadur Calavala Cunnan Chetty Charities 135 ITR 485 (Mad.) & (iii) CIT v Estate of V.L.Ethiraj 136 ITR 12 (Mad.). d) The Hon7ble Karnataka

SRI.RATAN BABULAL LATH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

House Property Income of the assessee for the said A. Y. under consideration. The interest allowable was worked out by the AO at Rs. 88,04,65,352 (Rs.112,16,08,065 – Rs.88,04,65,352) as follows: 112,16,08,065x 2226979521 = 24,11,42,713. 10358174018 Rs.22,69,79,521 is the sum total of the three advances

M/S.GOLFLINKS SOFTWARE PARK (P) LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

House Property Income of the assessee for the said A. Y. under consideration. The interest allowable was worked out by the AO at Rs. 88,04,65,352 (Rs.112,16,08,065 – Rs.88,04,65,352) as follows: 112,16,08,065x 2226979521 = 24,11,42,713. 10358174018 Rs.22,69,79,521 is the sum total of the three advances

M/S.GOLFLINKS SOFTWARE PARK (P) LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

House Property Income of the assessee for the said A. Y. under consideration. The interest allowable was worked out by the AO at Rs. 88,04,65,352 (Rs.112,16,08,065 – Rs.88,04,65,352) as follows: 112,16,08,065x 2226979521 = 24,11,42,713. 10358174018 Rs.22,69,79,521 is the sum total of the three advances

M/S.GOLFLINKS SOFTWARE PARK (P) LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

House Property Income of the assessee for the said A. Y. under consideration. The interest allowable was worked out by the AO at Rs. 88,04,65,352 (Rs.112,16,08,065 – Rs.88,04,65,352) as follows: 112,16,08,065x 2226979521 = 24,11,42,713. 10358174018 Rs.22,69,79,521 is the sum total of the three advances

M/S.GOLFLINKS SOFTWARE PARK (P) LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

House Property Income of the assessee for the said A. Y. under consideration. The interest allowable was worked out by the AO at Rs. 88,04,65,352 (Rs.112,16,08,065 – Rs.88,04,65,352) as follows: 112,16,08,065x 2226979521 = 24,11,42,713. 10358174018 Rs.22,69,79,521 is the sum total of the three advances

M/S.GOLFLINKS SOFTWARE PARK (P) LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

House Property Income of the assessee for the said A. Y. under consideration. The interest allowable was worked out by the AO at Rs. 88,04,65,352 (Rs.112,16,08,065 – Rs.88,04,65,352) as follows: 112,16,08,065x 2226979521 = 24,11,42,713. 10358174018 Rs.22,69,79,521 is the sum total of the three advances