THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(1), BANGALORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K.

u/s 20.09.2022 20.10.2022 01.10.2023 346 271(1)(c) 3.2 He submitted that the assessee has filed condonation petition for quantum proceedings upon receiving deficiency letter and no ITA Nos.699 to 704/Bang/2024 The Karnataka Chemists & Druggists Association, Bangalore Page 4 of 23 deficiency letter was received for appeal filed against penalty orders. The assessee was under a bonafide belief that

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(2), BANGALORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K.

u/s 20.09.2022 20.10.2022 01.10.2023 346 271(1)(c) 3.2 He submitted that the assessee has filed condonation petition for quantum proceedings upon receiving deficiency letter and no ITA Nos.699 to 704/Bang/2024 The Karnataka Chemists & Druggists Association, Bangalore Page 4 of 23 deficiency letter was received for appeal filed against penalty orders. The assessee was under a bonafide belief that

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K.

u/s 20.09.2022 20.10.2022 01.10.2023 346 271(1)(c) 3.2 He submitted that the assessee has filed condonation petition for quantum proceedings upon receiving deficiency letter and no ITA Nos.699 to 704/Bang/2024 The Karnataka Chemists & Druggists Association, Bangalore Page 4 of 23 deficiency letter was received for appeal filed against penalty orders. The assessee was under a bonafide belief that

DCIT-CIRCLE-1(1), HUBLI, C.R. BUILDING , NAVANAGAR HUBLI vs. SHRI CHANDRASHEKHAR KOMMI, HUBLI

In the result, the appeal of the revenue is dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2015-16

section 271 are given would not satisfy the requirement of law. The Court has also held that initiating penalty proceedings on one limb and finding the assessee guilty in another limb is bad in law. It was submitted that in the present case, the aforesaid decision will squarely apply and the orders imposing penalty have to be held

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(2) , BANGALORE

In the result, all the appeals of the assessee are dismissed

penalty levied u/s 271(1)(c) of\nthe Act. There was a delay of 346 days in filing the appeal before\nNFAC. The assessee filed a condonation petition before NFAC\nexplaining the reasons for the inordinate delay in filing the appeal\nbefore NFAC and the NFAC has observed as follows:\n"5............. .The appellant has stated that this inordinate delay

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, all the appeals of the assessee are dismissed

penalty levied u/s 271(1)(c) of\nthe Act. There was a delay of 346 days in filing the appeal before\nNFAC. The assessee filed a condonation petition before NFAC\nexplaining the reasons for the inordinate delay in filing the appeal\nbefore NFAC and the NFAC has observed as follows:\n"5............. .The appellant has stated that this inordinate delay

KASIREDDY RANADHEER REDDY,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

259 of the Income Tax Act, 1961 (hereafter- the Act), were heard together. First, we take up ITA No. 882/Bang/2025 pertaining to AY 2010-11 ITA No.882 to 887/Bang/2025 Page 2 of 27 2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 7 and sub-grounds thereunder, which we, for the sake of brevity

KASIREDDAY RANADHEER REDDY ,BENGALURU vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

259 of the Income Tax Act, 1961 (hereafter- the Act), were heard together. First, we take up ITA No. 882/Bang/2025 pertaining to AY 2010-11 ITA No.882 to 887/Bang/2025 Page 2 of 27 2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 7 and sub-grounds thereunder, which we, for the sake of brevity

KASIREDDAY RANADHEER REDDY ,BENGALURU vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

259 of the Income Tax Act, 1961 (hereafter- the Act), were heard together. First, we take up ITA No. 882/Bang/2025 pertaining to AY 2010-11 ITA No.882 to 887/Bang/2025 Page 2 of 27 2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 7 and sub-grounds thereunder, which we, for the sake of brevity

KASIREDDY RANADHEER REDDY ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

259 of the Income Tax Act, 1961 (hereafter- the Act), were heard together. First, we take up ITA No. 882/Bang/2025 pertaining to AY 2010-11 ITA No.882 to 887/Bang/2025 Page 2 of 27 2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 7 and sub-grounds thereunder, which we, for the sake of brevity

KASIREDDY RANADHEER REDDY ,BENGALURU vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

259 of the Income Tax Act, 1961 (hereafter- the Act), were heard together. First, we take up ITA No. 882/Bang/2025 pertaining to AY 2010-11 ITA No.882 to 887/Bang/2025 Page 2 of 27 2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 7 and sub-grounds thereunder, which we, for the sake of brevity

KASIREDDY RANADHEER REDDY ,BENGALURU vs. ACIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

259 of the Income Tax Act, 1961 (hereafter- the Act), were heard together. First, we take up ITA No. 882/Bang/2025 pertaining to AY 2010-11 ITA No.882 to 887/Bang/2025 Page 2 of 27 2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 7 and sub-grounds thereunder, which we, for the sake of brevity

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

259 (Bangalore - Trib.)); and (ii) NXP India Pvt. Ltd. v. DCIT (reported in [2020] 116 taxmann.com 421 (Bangalore - Trib.)) and the decision of the Hyderabad Bench of this Tribunal in EPAM Systems India (P.) Ltd. v. ACIT (reported in [2018] 100 taxmann.com 335 (Hyd-Trib), where in the cases of similarly placed assessees, this company was directed to be excluded

INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU, BENGALURU vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED, BENGALURU

In the result both the appeals of the Revenue as well as\nCos of the Assessee for the Asst

259\n30,61,669\n1,00,80,256\n32,44,650\n35,59,584\n11,39,067\n2,50,000\n7,12,500\n5,62,500\n7,58,319\n40,313\n484554\n2,86,24,671\n\n9.4 The AO relying on the decision of the Hon'ble Karnataka\nHigh Court in the case of Totgar's Co-operatiye Sale

YOKOGAWA INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX LARGE TAXPAYERS UNIT , BANGALORE

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

penalty proceedings under Section 274 read with Section .271(1)(c) of the Act, without appreciating the fact that the Appellant has not concealed or furnished any inaccurate particulars of income. Page 5 of 40 The Appellant submits that each of the above grounds is independent and without prejudice to one another. The Appellant craves leave to add, alter, amend

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:

259 (Mad) relied on” 15. The assessee relied upon the decision of Hon’ble A.P. High Court, in the case of K. Lakshmi Savitri Devi in ITA No.563 of 2011. The Hon’ble A.P. High Court, while upheld the order of ITAT ‘A’ Bench, in the case of K. Lakshmi Savitri Devi, observed as under. “We are of the view

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:

259 (Mad) relied on” 15. The assessee relied upon the decision of Hon’ble A.P. High Court, in the case of K. Lakshmi Savitri Devi in ITA No.563 of 2011. The Hon’ble A.P. High Court, while upheld the order of ITAT ‘A’ Bench, in the case of K. Lakshmi Savitri Devi, observed as under. “We are of the view

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:

259 (Mad) relied on” 15. The assessee relied upon the decision of Hon’ble A.P. High Court, in the case of K. Lakshmi Savitri Devi in ITA No.563 of 2011. The Hon’ble A.P. High Court, while upheld the order of ITAT ‘A’ Bench, in the case of K. Lakshmi Savitri Devi, observed as under. “We are of the view