TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

housing projects or a ship in Nava Sheva. Ownership of a ship per se will not attract Section 80-/B (6). It is the profits arising from the business of a ship which attracts sub-section (6). In other words, deduction under sub-section (6) at the specified rate has linkage to the profits derived from the shipping operations. This

M/S. TATA ELXSI LIMITED., ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri George George K. & Shri Chandra Poojari

housing projects or a ship in Nava Sheva. Ownership of a ship per se will not attract Section 80-/B (6). It is the profits arising from the business of a ship which attracts sub-section (6). In other words, deduction under sub-section (6) at the specified rate has linkage to the profits derived from the shipping operations. This

DCIT, BANGALORE vs. SRI. RAJEEV CHANDRASEKHAR, BANGALORE

In the result, the appeal by the Revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Abraham P. Georgeassessment Year : 2008-09

801 2003-04 408 1,70,38,249 2004-05 409 2,21,18,288 Total 5,42,36,338 6. The CIT(A) held that as per the decision of Hon’ble Gujarat High Court in Bipinbhai Vadilal Family Trust (No.1) v. CIT (1994) 208 ITR 1005, the fair rent of the property would be Rs.46

M/S. SILICON ESTATES,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal fails and is hereby dismissed

Bench: Shri Chandra Poojari & Ms. Madhumita Royassessment Year : 2013-14 M/S. Silicon Estates, The Deputy # 14, 6Th Floor, Commissioner Of Geneva House, Income Tax, Cunningham Road, Central Circle Bengaluru – 560 001. 1(4), Vs. Pan: Abefs6150N Bengaluru. Appellant Respondent Assessee By : Shri Tata Krishna, Advocate Revenue By : Shri D.K. Mishra, Cit Dr Date Of Hearing : 11-09-2023 Date Of Pronouncement : 04-12-2023 Order Per Madhumita Roythe Instant Appeal Filed By The Assessee Is Directed Against The Order Dated 24.11.2020 Passed By The Ld.Cit(A)-11, Bangalore Arising Out Of The Order Dated 30.12.2015 Passed By The Ld.Dcit, Central Circle – 1(4), Bangalore U/S. 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For A.Y. 2013-14 Whereby & Whereunder The Rejection Of The Claim U/S. 80Ib(10) Of Rs.4,03,40,492/- For A.Y. 2013-14 Has Been Confirmed.

Properties (P.) Ltd. 's case (supra), referred to supra, whereunder it came to be held that distinction drawn to be put forward by the Revenue with regard to completion certificate vis-a-vis occupancy certificate would not dilute the legal position, we dismiss these appeals.” Page 12 of 17 9. In the above matter, it was found that the certificate

DCIT, BANGALORE vs. DR. RAJAN PAI, BANGALORE

In the result, appeal of the Revenue stands dismissed

Bench: Shri. Abraham P. George & Shri. George George Ki.T.A No.1290/Bang/2015 (Assessment Year : 2012-13) Deputy Commissioner Of Income-Tax, Central Circle -2(2), Bengaluru .. Appellant V. Dr. Rajan Pai, Block No.1B, Jakkur Plantation Village, Yelahanka Main Road, Bengaluru .. Respondent Pan : Agbpp2795G Assessee By : Shri. Sajjan Kumar Tulsiyan, Advocate Revenue By : Shri. Sanjay Kumar, Cit -Iii Heard On : 12.04.2016 Pronounced On : 29.04.2016 O R D E R Per Abraham P. George:

house. As per the AO, fair market value of the bonus shares issued by MEMG was required to be computed in accordance with Rule 11U and 11UA of the Income-tax Rules, 1962 (‘the Rules’ in ITA.1290/Bang/2015 Page - 3 short). He applied Rule 11UA and determined the fair market value of the 1,00,00,000 number of bonus shares

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

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

housed in sections 28 to 44DB. Under section 28(i) the profits and gains of any business or profession carried on by the assessee at any time during the previous year is chargeable to tax. As per section 29, the income referred to in section 28 should be computed in accordance with the provisions contained in sections

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

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

housed in sections 28 to 44DB. Under section 28(i) the profits and gains of any business or profession carried on by the assessee at any time during the previous year is chargeable to tax. As per section 29, the income referred to in section 28 should be computed in accordance with the provisions contained in sections

M/S. TATA ELXSI LIMITED,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

Bench: Shri George George K. & Shri Chandra Poojari

housing projects or a ship in Nava Sheva. Ownership of a ship per se will not attract Section 80-/B (6). It is the profits arising from the business of a ship which attracts sub-section (6). In other words, deduction under sub-section (6) at the specified rate has linkage to the profits derived from the shipping operations. This

SHRI. DEV KUMAR ROY,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), BANGALORE

In the result, appeal of the Assessee is treated as allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri A K Garodiaassessment Year: 2016-17

801 Cost 6000000*1081/1024 2014-15 60,00,000 63,33,984 Cost 4000000*1081/1024 2014-15 40,00,000 42,22,656 Cost 12500000*1081/1024 2014-15 1,00,00,000 1,05,56,641 Total 20,00,000 6,91,39,249 Taxable Capital gain 35,00,000 1,16,160 8. According to the AO, the Assessee

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE vs. SHRI C J VISHWANATH , CHIKKAMAGALURU

In the result, all the appeals filed by the Revenue are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Property Rs. 67,200 /- ii) Business Income Rs. 1,42,860/- iii) Income from other Sources Rs. 5,042/- --------------------- ITA Nos.1891 to 1896/Bang/2018 Page 12 of 30 Rs. 2,15,102/- Less: Deduction u/s. 80C Rs. 80,354/- ---------------------- Net Income Rs. 1,34,748/- Rounded Off to Rs. 1,34,750/- --------------------- 16. The Ld. AO has completed an Assessment

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE vs. SHRI C J VISHWANTH , CHIKKAMAGALURU

In the result, all the appeals filed by the Revenue are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Property Rs. 67,200 /- ii) Business Income Rs. 1,42,860/- iii) Income from other Sources Rs. 5,042/- --------------------- ITA Nos.1891 to 1896/Bang/2018 Page 12 of 30 Rs. 2,15,102/- Less: Deduction u/s. 80C Rs. 80,354/- ---------------------- Net Income Rs. 1,34,748/- Rounded Off to Rs. 1,34,750/- --------------------- 16. The Ld. AO has completed an Assessment

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE vs. SHRI C J VISHWANTH , CHIKKAMANGALURU

In the result, all the appeals filed by the Revenue are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Property Rs. 67,200 /- ii) Business Income Rs. 1,42,860/- iii) Income from other Sources Rs. 5,042/- --------------------- ITA Nos.1891 to 1896/Bang/2018 Page 12 of 30 Rs. 2,15,102/- Less: Deduction u/s. 80C Rs. 80,354/- ---------------------- Net Income Rs. 1,34,748/- Rounded Off to Rs. 1,34,750/- --------------------- 16. The Ld. AO has completed an Assessment

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE vs. SHRI C J VISHWANTH , CHICKAMANGALUR

In the result, all the appeals filed by the Revenue are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Property Rs. 67,200 /- ii) Business Income Rs. 1,42,860/- iii) Income from other Sources Rs. 5,042/- --------------------- ITA Nos.1891 to 1896/Bang/2018 Page 12 of 30 Rs. 2,15,102/- Less: Deduction u/s. 80C Rs. 80,354/- ---------------------- Net Income Rs. 1,34,748/- Rounded Off to Rs. 1,34,750/- --------------------- 16. The Ld. AO has completed an Assessment

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE vs. SHRI C J VISHWANTH , CHIKKAMAGALURU

In the result, all the appeals filed by the Revenue are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Property Rs. 67,200 /- ii) Business Income Rs. 1,42,860/- iii) Income from other Sources Rs. 5,042/- --------------------- ITA Nos.1891 to 1896/Bang/2018 Page 12 of 30 Rs. 2,15,102/- Less: Deduction u/s. 80C Rs. 80,354/- ---------------------- Net Income Rs. 1,34,748/- Rounded Off to Rs. 1,34,750/- --------------------- 16. The Ld. AO has completed an Assessment

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2 (3), BENGALURU vs. SHRI C J VISHWANTHA, CHICKAMANGALURU

In the result, all the appeals filed by the Revenue are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

House Property Rs. 67,200 /- ii) Business Income Rs. 1,42,860/- iii) Income from other Sources Rs. 5,042/- --------------------- ITA Nos.1891 to 1896/Bang/2018 Page 12 of 30 Rs. 2,15,102/- Less: Deduction u/s. 80C Rs. 80,354/- ---------------------- Net Income Rs. 1,34,748/- Rounded Off to Rs. 1,34,750/- --------------------- 16. The Ld. AO has completed an Assessment

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:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore

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:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore

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:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore