M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

Appeal of the assessee is dismissed\nas infructuous

reassessment.\n62.1 At the outset, we note that the issue raised by the assessee on\nmerit of the case has been decided in its favour. Accordingly, we do not\nfind any reason to adjudicate the impugned issue on hand. As such, we\nkeep the issue open. Both the Id. AR and the DR did not raise any\nobjection

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

11 of the Act.\n47.\nThe aggrieved assessee preferred an appeal before the learned\nCIT(A) and contended that there was no incriminating material found in\nrelation to the year under consideration. Therefore, the proceedings\nunder section 153A of the Act cannot be initiated for the year under\nconsideration and assessment made in the absence of incriminating\nmaterial being unearthed

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

11 of the Act.\n47.\nThe aggrieved assessee preferred an appeal before the learned\nCIT(A) and contended that there was no incriminating material found in\nrelation to the year under consideration. Therefore, the proceedings\nunder section 153A of the Act cannot be initiated for the year under\nconsideration and assessment made in the absence of incriminating\nmaterial being unearthed

KARNATAKA CHINMAYA SEVA TRUST,BENGALURU vs. DCIT-(EXEMPTIONS) CIRCLE-1, BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessmentyear:2016-17

11 shall inter-alia file its return of income within the due dates. Further it is specifically mentioned that the amendment will take effect from 01/04/2018 and will accordingly apply from assessment Karnataka Chinmaya Seva Trust, Bangalore Page 19 of 25 year 2018-19 and subsequent years. Hence the Bench is of the view that on the application of general

DCIT, CENTRAL CIRCLE-1(4), BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

11 of the Act.\n47.\nThe aggrieved assessee preferred an appeal before the learned\nCIT(A) and contended that there was no incriminating material found in\nrelation to the year under consideration. Therefore, the proceedings\nunder section 153A of the Act cannot be initiated for the year under\nconsideration and assessment made in the absence of incriminating\nmaterial being unearthed

M/S. SRI. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES(REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

11 of the Act.\n47.\nThe aggrieved assessee preferred an appeal before the learned\nCIT(A) and contended that there was no incriminating material found in\nrelation to the year under consideration. Therefore, the proceedings\nunder section 153A of the Act cannot be initiated for the year under\nconsideration and assessment made in the absence of incriminating\nmaterial being unearthed

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

11 of the Act.\n47.\nThe aggrieved assessee preferred an appeal before the learned\nCIT(A) and contended that there was no incriminating material found in\nrelation to the year under consideration. Therefore, the proceedings\nunder section 153A of the Act cannot be initiated for the year under\nconsideration and assessment made in the absence of incriminating\nmaterial being unearthed

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1(4), BENGALURU, BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD), KOLAR

11 of the Act.\n47.\nThe aggrieved assessee preferred an appeal before the learned\nCIT(A) and contended that there was no incriminating material found in\nrelation to the year under consideration. Therefore, the proceedings\nunder section 153A of the Act cannot be initiated for the year under\nconsideration and assessment made in the absence of incriminating\nmaterial being unearthed

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST ,KOLAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

11 of the Act.\n47. The aggrieved assessee preferred an appeal before the learned\nCIT(A) and contended that there was no incriminating material found in\nrelation to the year under consideration. Therefore, the proceedings\nunder section 153A of the Act cannot be initiated for the year under\nconsideration and assessment made in the absence of incriminating\nmaterial being unearthed

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

section 143 or total income assessed, reassessed or recomputed in a preceding order. (11)No addition or disallowance of an amount

INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

INCOME TAX OFFICER, W-1, VIJAYANAGAR vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter contended that the Assessee has not availed any of the safeguards and basis

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter contended that the Assessee has not availed any of the safeguards and basis

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter contended that the Assessee has not availed any of the safeguards and basis

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter contended that the Assessee has not availed any of the safeguards and basis