DALAVAI AUDIKESAVULU SRINIVAS L/H OF LATE SMT D A SATHYAPRABHA,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

penalty proceedings u/s 271(1)(c) of the Act. 5. The learned AO erred in levying interest u/s 234A, 234B and 234C of the Act. 6. The Appellant craves leave to add or delete or modify or revise any ground at the time of hearing before the Hon'ble ITAT. Page 3 of 14 ITA Nos. 1049 & 1050/Bang/2025 For these

MURMU PANKAJ KUMAR,BENGALURU vs. ITO, WARD-3(3)(1), BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2016-17

unexplained investment u/s 69 of the Act & taxed u/s 115BBE of the Act. The AO completed the assessment on 22/01/2024 on a Total Income of Rs. 43,73,435/- and raised total demand of Rs.5,43,487/- u/s 156 of the Act. The AO also initiated the penalty proceedings u/s 271

SHREE SHARANAVASACESHWAR CREDIT SOUHARD SAHAKARI NI HALINGALI,HALINGALI vs. INCOME TAX OFFICER, WARD-1, BAGALKOT

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17 Shree Sharanabasaveshwar Credit Souhard Sahakari Ni Halingali Ito Tq Jamkhandi, Dt Bagalkot Vs. Ward-1 Halingali, Karnataka 587315 Bagalkot Pan No :Aaeas6699C Appellant Respondent Appellant By : Sri Sandeep Chalapathy, A.R. Respondent By : Sri Subramanian S., D.R. Date Of Hearing : 14.05.2025 Date Of Pronouncement : 12.08.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Cit(A)/Nfac Dated 07.11.2024 Vide Din & Order No. Itba/Nfac/S/250/2024-25/1070176573(1) Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”) For The Assessment Year 2016-17. 2. The Assessee Has Raised The Following Ground Of Appeal: -

271(1)(c) of the Act. Shree Sharanabasaveshwar Credit Souhard Sahakari Ni Halingali Page 4 of 7 8. Ld. DR on the other hand heavily relied on the order of the ld. CIT(A)/NFAC. 9. We have heard rival submissions perused the material available on record. It is an undisputed fact that the claim of deduction under section

MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeal of the assessee in ITA\nNo

Unexplained investment u/s 69B\nTotal\nRs.80 lakhs\nRs.4 lakhs\nRs.84 lakhs.\n3.1\nAccording to the ld. A.R, these additions are based on loose\nslips and not on any supporting documents. She submitted that\nthe said loose slips reads as follows:\nITBA/AST/M/153A/2019-20/1023248118(1)\nRabs: 125,000/ Cong.\n(Paid 95,00,000/-\nBclamce Dmart\nmoth\n68\n3.2 The ld. A.R. submitted

MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , MANGALORE

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Unexplained investment u/s 69B - Rs.4 lakhs Total - Rs.84 lakhs. 3.1 According to the ld. A.R, these additions are based on loose slips and not on any supporting documents. She submitted that the said loose slips reads as follows: ITA Nos.463 to 466, 485 & 486/Bang/2024 Mohammed Ibrahim Mohideen, Kasargod, Kerala Page 6 of 62 3.2 The ld. A.R. submitted that basis

MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, MANGALORE

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Unexplained investment u/s 69B - Rs.4 lakhs Total - Rs.84 lakhs. 3.1 According to the ld. A.R, these additions are based on loose slips and not on any supporting documents. She submitted that the said loose slips reads as follows: ITA Nos.463 to 466, 485 & 486/Bang/2024 Mohammed Ibrahim Mohideen, Kasargod, Kerala Page 6 of 62 3.2 The ld. A.R. submitted that basis

MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , MANGALORE

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Unexplained investment u/s 69B - Rs.4 lakhs Total - Rs.84 lakhs. 3.1 According to the ld. A.R, these additions are based on loose slips and not on any supporting documents. She submitted that the said loose slips reads as follows: ITA Nos.463 to 466, 485 & 486/Bang/2024 Mohammed Ibrahim Mohideen, Kasargod, Kerala Page 6 of 62 3.2 The ld. A.R. submitted that basis

MOHAMMED IBRABIM MOHIDEEN ,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MANGALURU

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Unexplained investment u/s 69B - Rs.4 lakhs Total - Rs.84 lakhs. 3.1 According to the ld. A.R, these additions are based on loose slips and not on any supporting documents. She submitted that the said loose slips reads as follows: ITA Nos.463 to 466, 485 & 486/Bang/2024 Mohammed Ibrahim Mohideen, Kasargod, Kerala Page 6 of 62 3.2 The ld. A.R. submitted that basis

M/S. EMIRATES HINDUSTAN BUILDERS AND DEVELOPERS,KERALA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Keshav Dubey

unexplained cash credits u/s. 68 of the Act for A/Y 2017-18 and 2018-19 respectively. 5.9 No explanation was offered by the appellant in respect of the above additions during this proceeding despite several notices and opportunities provided. Therefore, the additions made i.e. Rs.5 Lakh and Rs.3 1,32,000/-for A/Y 2017-18 and 2018-19 respectively were

MKH INFRASTRUCTURE,KERALA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Keshav Dubey

unexplained cash credits u/s. 68 of the Act for A/Y 2017-18 and 2018-19 respectively. 5.9 No explanation was offered by the appellant in respect of the above additions during this proceeding despite several notices and opportunities provided. Therefore, the additions made i.e. Rs.5 Lakh and Rs.3 1,32,000/-for A/Y 2017-18 and 2018-19 respectively were

ACIT, CENTRAL CIRCLE-2(4), BANGALORE vs. RAMCHANDRA NAVEEN, BANGALORE

In the result, we do not find any infirmity in the Order of the learned\nCIT(A)

penalty u/s 271(1)(c) is initiated separately.\n19. On the basis of above observation of the assessee, AO made addition\nunder section 69C of the Act as unexplained expenditure for the Assessment\nYears as under\n Assessment Year\nAmount\n2016-17\n19,65,000/-\n2017-18\n16,04,500/-\n20. During the course of appellate proceedings, assessee had raised

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

u/s. 12A of\nthe Act vide order dated 22-2-2016. Against the order of Ld, CIT(Ex) assessee preferred an\nappeal who directed the Revenue to provide an opportunity of cross-examination to\nassessee. Accordingly, appeal was allowed for statistical purpose.\"\n9.40 He also relied on the case CIT Vs. S. Khader Khan Son reported in 352\nITR

GOPALIYENGAR MADABUSHI MURALIDHAR, ,BENGALURU vs. INCOME-TAX OFFICER, WARD-7(2)(4), BENGALURU

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

Bench: Shri Chandra Poojari (Accountant Member), Shri Keshav Dubey (Judicial Member)

unexplained investment and therefore the addition is liable to be deleted. 2.4 The Learned AO has failed to appreciate that no addition can be made on the basis of ITS information. The addition made merely on the basis of ITS information being bad in law and on fact is required to be deleted. 3. Denial of carry forward of losses

ACIT, CENTRAL CIRCLE-2(4), BANGALORE vs. RAMCHANDRA NAVEEN, BANGALORE

In the result, we do not find any infirmity in the Order of the learned\nCIT(A)

penalty u/s 271(1)(c) is initiated separately.\n\n19. On the basis of above observation of the assessee, AO made addition\nunder section 69C of the Act as unexplained expenditure for the Assessment\nYears as under\n\n Assessment Year\nAmount\n2016-17\n2017-18\n19,65,000/-\n16,04,500/-\n\n20. During the course of appellate proceedings

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:

u/s 132(4) of the Income-tax Act, 1961 recorded from Mr. K M Deekshith during the course of search operation u/s 132 dt: 27.11.2017 he was asked about his role and responsibilities in M/s Coffee Day Global Limited. From the above statement of Mr. K M Deekshith it cannot be inferred that the assessee has advance loan in cash

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:

u/s 132(4) of the Income-tax Act, 1961 recorded from Mr. K M Deekshith during the course of search operation u/s 132 dt: 27.11.2017 he was asked about his role and responsibilities in M/s Coffee Day Global Limited. From the above statement of Mr. K M Deekshith it cannot be inferred that the assessee has advance loan in cash

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:

u/s 132(4) of the Income-tax Act, 1961 recorded from Mr. K M Deekshith during the course of search operation u/s 132 dt: 27.11.2017 he was asked about his role and responsibilities in M/s Coffee Day Global Limited. From the above statement of Mr. K M Deekshith it cannot be inferred that the assessee has advance loan in cash

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:

u/s 132(4) of the Income-tax Act, 1961 recorded from Mr. K M Deekshith during the course of search operation u/s 132 dt: 27.11.2017 he was asked about his role and responsibilities in M/s Coffee Day Global Limited. From the above statement of Mr. K M Deekshith it cannot be inferred that the assessee has advance loan in cash