YASH VARDHAN ARYA,BANGALORE vs. THE INCOME TAX OFFICER, (INTERNATIONAL TAXATION) WARD-1(1), BANGALORE

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

Bench: Shri George George K

8 ITA No.203/Bang/2022. Sri.Yash Vardhan Arya. that meaning and interpretation of the words 'property is let' cannot be 'property actually let out'. Thus, if a property is held with an intention to let out in the relevant year coupled with efforts made for letting it out, it could be said that such a property is a let out property

M/S. EMBASSY KNOWLEDGE INFRASTRUCTURE PROJECTS PRIVATE LIMITED,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2(1)(2), BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

house property even though it cannot be added as per the provisions of the Act. 7. The assessee also raised following additional grounds:- (i) The interest cost is Rs.7.03 crore and not Rs.4.34 crore as raised in original grounds of appeal. (ii) Depreciation on the asset leased has to be allowed. (iii) Deduction on section 80G of Rs.5 lakh

SMT. REHANA ABDUL JABBAR,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (INTERNATIONAL TAXATION), MANGALURU

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

house as per the conditions stipulated in section 54F of the Act. Since both grounds are inter- related, we consider these two grounds collectively. 8. Facts of the issue are that during the year under appeal, the assessee had sold the property

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

8 of\nthe Act provides that all property and all other assets\nvesting in the assessee shall be held and applied by it,\nsubject to the provisions and for the purposes of this Act.\nThe purpose of application is outlined. The funds cannot be\ndistributed or appropriated to any person unless the same\nis in accordance with the assessee

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

8 of\nthe Act provides that all property and all other assets\nvesting in the assessee shall be held and applied by it,\nsubject to the provisions and for the purposes of this Act.\nThe purpose of application is outlined. The funds cannot be\ndistributed or appropriated to any person unless the same\nis in accordance with the assessee

LATE JAGJIT SINGH BAJWA LEAGAL HEIR HARLEEN BAJWA ,BANGALORE vs. INCOME TAX OFFICER, WARD-4(2)(3), BANGALORE

In the result, appeal of the assessee is allowed

8 of 13\nITA No.825/Bang/2024\nJagajit Singh Bajwa, Bangalore\nsaid section meant complete residential house and would\nnot include shared interest in residential house.\n6.5 On revenue's appeal to Hon'ble Karnataka High Court, it was\nheld as under:\n\"Section 54F provides that if the assessee has a residential\nhouse he cannot seek the benefit of long term

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

Section would make it explicitly clear that proceeds of sale of the property is to be reinvested within a period of two years, which would IT(IT)A No.258/Bang/2025 HanchipuraChannaiah Nandakishore, Bangalore Page 8 of 16 not be chargeable to tax. The intention of Legislature was to encourage the investment in the acquisition of residential house

BHAGYA MAHANTESH KHODANPUR ,HUBBALLI vs. INCOME TAX OFFICER, WARD-2(1), HUBBALLI

In the result, appeal of the assessee is partly allowed

Bench: Dr. Dipak P. Ripote & Shri Prakash Chand Yadavassessment Year: 2015-16 Bhagya Mahantesh Khodanpur, Income Tax Officer, Indu Arcade, Vithoba Galli, Ward-2(1), Durgadbail, Vs. Hubballi. Hubballi-580020. Pan No : Apxpk0150P Appellant Respondent Appellant By : Sri Sudheendra B.R, Advocate Respondent By : Sri Ganesh R Ghale, Advocate-Standing Counsel For Revenue Date Of Hearing : 20.08.2025 Date Of Pronouncement : 21.08.2025 O R D E R Per Dr. Dipak P. Ripote: This Is An Appeal Filed By Bhagya Mahantesh Khodanpur Against The Order Of The Learned Commissioner Of Income Tax (Appeals) (Nfac) (In Short “Ld. Cit(A)”) Passed U/S. 250 Of The Income Tax Act, 1961 (In Short “The Act”) For Asst Year 2015-16 On 28/03/2025 Emanating From Assessment Order Dated 29/12/2017 Passed U/S. 143(3) Of The Act. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Order Passed By The Ld. Addl / Joint Commissioner Of Income Tax (Appeals)-2, Gurugram U/S. 250 Of The Act Dated 28/03/2025 Is Bad In Law & Liable To Be Quashed. Addition Of Rs. 4,42,500/- Is Bad In Law & 2. Liable To Be Deleted.

house property" shall be computed after making the following deductions, namely:— (a) ……… (b) where the property has been acquired, constructed, repaired, renewed or reconstructed with borrowed capital, the amount of any interest payable on such capital: 10. Thus, section 24(b) clearly states that where the property has been acquired or constructed with borrowed capital, the amount of Page

DR. SHEELA PUTTABUDDI,BANGALORE vs. INCOME TAX OFFICER, WARD- 3(3)(5), BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

house and got the said property registered in the name of the assessee. It was stated that the said Developer Sri. B. Suresh made the payment directly to the vendors for and on behalf of the assessee. Thus, the same fortifies the fact that Sri. B. Suresh 8 ITA No.293/Bang/2020. Dr.Sheela Puttabuddi. was in agreement with the assessee for reinvesting

M/S. DEEPALI COMPANY PRIVAE LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD- 2(1)(2), BANGALORE

In the result, the appeal filed by assessee stands dismissed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2016-17 M/S. C. Krishniah Chetty & Co. Pvt. Ltd., The Income Tax (Earlier Known As :Deepali Co. Officer, Pvt. Ltd.) Ward – 2 (1)(2), 35, Commercial Street, Bangalore. Bangalore – 560 001. Vs. Pan: Aaacd5120H Appellant Respondent : Shri Narendra Sharma, Assessee By Advocate : Smt. Priyadarshini Revenue By Basaganni, Addl. Cit (Dr) Date Of Hearing : 01-06-2022 Date Of Pronouncement : 21-06-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 03.0.2020 Passed By Ld.Cit(A)-2, Bangalore For A.Y. 2016-17 On The Following Grounds Of Appeal: “1.1 On The Facts & Circumstances Of The Case, The Learned Commissioner Of Income Tax Erred In Not Allowing Business Loss For The Year Of Rs. 114,66.766/- On The Ground That The Business Of The Assessee Company Is Closed & There Are No Receipts From Operation Of Business.

sections 30 to 36. b) Expenditure should not be of capital nature c) The expenditure should be incurred during the previous year. d) The expenditure should not be of personal nature. e) The expenditure should have been incurred wholly or exclusively for the purpose of the business or profession. f) The business should be commenced or continuing. Page

SHARADA MOHAN SHETTY,KARWAR vs. ITO, WARD-2, KARWAR

In the result, appeal of the assessee is partly allowed

Bench: Or During The Courses Of Appeal Hearing.” 2. The Brief Facts Of The Case Are That The Assessee Filed Return Of Income On 30/09/2015 For The Assessment Year 2015-16 Declaring Page 2 Of 16

8 of 16 Assessee not appropriated the balance sale consideration either in investment in .in'iion of residential house or deposit into account notified by Central Govt. Assessee claimed exemption under section 54 for having invested the capital gains fa Aw 'w residential house which was denied by AO on the ground that capital gains arising out of sale

NAVJYOTI SHARMA,BANGALORE vs. DCIT ASMNT, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

property. In this view of the matter, we have no doubt in our mind that the learned Tribunal went wrong in holding that for the purpose of applicability of section 54, registration of document is imperative. We, therefore, answer the question in the negative, i.e., the assessee is entitled to exemption in terms of section 54.” 7.5 Further

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

In the result, the appeal filed by assessee stands allowed

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.

property for the purpose of construction of residential house on the land jointly owned by her and her husband at BDA Site No. 839/21, 37th F Cross, 4th T Block, Jayanagar, Bangalore – 560 011. 8. The authorities below alleges that, deduction under section

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

house property. The claim of the Assessee is that it is chargeable to tax as profits and gains of business and profession. 5. Coming to the ground no. 17, with respect to the depreciation, the fact shows that Assessee has made an addition of Rs. 15,56,16,965/- and intangible assets were added

SRI. G.S. SHIVANNA(HUF),BANGALORE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-4, BENGALURU

In the result, appeal of the assessee is partly allowed

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariassessment Year : 2015-16 Shri. G. S. Shivanna (Huf), Pcit, Vs. No.3, Basaveshwara Nilaya, Bengaluru – 4, Yelachenahalli, Kanakapura Road, Bengaluru. Bengaluru – 560 078. Pan : Aaahg 7097 K Appellant Respondent Assessee By : Shri. Satish S, Advocate Revenue By : Shri. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 25.08.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per N. V. Vasudevan

8 of 10 scrutiny proceedings, it is observed that the assessee holds two residential house properties”, is itself an incorrect observation. The PCIT has in the impugned order further observed that from the submission made by the assessee it appears that the assessee owned two houses and the nature of the two properties owned by the assessee has not been

M/S. WIPRO LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(2), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

8 of 85 2.16 Section 35 relates to allowance of expenditure towards scientific Research. The Act permits the claim of expenditure of scientific research for both inhouse R&D and institutional R&D. For inhouse R&D by the assessee the provisions of 35(1)(i) and 35(1)(iv) provide for revenue expenditure and capital expenditure respectively. Where

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, , BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No:Aaajk0398K\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

8) are inapplicable and consequently exemption under section 11 is to be allowed as claimed by the appellant.\n\n3. Levy of interest under section 234A and 234B\n\n6.1 The learned CIT(A), NFAC erred in confirming the levy of interest under section 234A and 234B of the Act. On facts and circumstances of the case and law applicable

AMANDA JOY PURAVANKARA ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee is allowed

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2015-16

Section 23(1)(c) to the present case. Amanda Joy Puravankara, Bengaluru Page 2 of 7 i. The Ld. Officers below erred failed to appreciate that the first house was continuously let out ever since it was acquired in 2011 and it could not be let out from October 2013 to May 2015 despite best of the efforts