M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, the appeals filed by the assessee for all the four A

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER\nAND\nSHRI SOUNDARARAJAN K. (Judicial Member)

14A on a wrong notion that\nthe disallowance is presumptive in nature even when the\nexpenditure is not actually incurred.\n6. 6. It is submitted that the Learned DR has not brought anything contrary\nto the above submissions in his objections dated 30.01.2025.\nTherefore, the disallowance made by the Learned AO under Section\n14A without recording the satisfaction

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

14A on a wrong notion that\nthe disallowance is presumptive in nature even when the\nexpenditure is not actually incurred.\n6.6. It is submitted that the Learned DR has not brought anything contrary\nto the above submissions in his objections dated 30.01.2025.\nTherefore, the disallowance made by the Learned AO under Section\n14A without recording the satisfaction

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, all the appeals filed by the assessee are allowed

14A on a wrong notion that\nthe disallowance is presumptive in nature even when the\nexpenditure is not actually incurred.\n\n6. 6. It is submitted that the Learned DR has not brought anything contrary\nto the above submissions in his objections dated 30.01.2025.\nTherefore, the disallowance made by the Learned AO under Section\n14A without recording the satisfaction

MANIPAL HOSPITALS PVT. LTD (FORMERLY KNOWN AS COLUMBIA ASIA HOSPITALS PVT. LTD),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

MANIPAL GLOBAL EDUCATION SERVICES PVT LTD., ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(2), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD. ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD.,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.] 73 [Explanation.-For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

reassess any other\nincome which has escaped assessment and which comes to his notice during the\ncourse of the proceedings. However, if after issuing a notice under section 148, he\naccepted the contention of the assessee and holds that the income which he has\ninitially formed a reason to believe had escaped assessment, has as a matter of fact\nnot

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

reassess any other\nincome which has escaped assessment and which comes to his notice during the\ncourse of the proceedings. However, if after issuing a notice under section 148, he\naccepted the contention of the assessee and holds that the income which he has\ninitially formed a reason to believe had escaped assessment, has as a matter of fact\nnot

CENTURY REAL ESTATE HOLDINGS PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), BANGALORE

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

section 14A states "Expenditure 4 ITA No.1590/Bang/2017 & Ors. M/s.Century Real Estate Holdings Pvt.Ltd. incurred in relation to income not includible in total income." 10. In respect of the question of validity of the proceedings u/s 153A, the Hon'ble CIT[A) in his order has taken cognisance of the decision of the Hon'ble Karnataka High Court in an earlier

CENTURY REAL ESTATE HOLDINGS PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), BANGALORE

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

section 14A states "Expenditure 4 ITA No.1590/Bang/2017 & Ors. M/s.Century Real Estate Holdings Pvt.Ltd. incurred in relation to income not includible in total income." 10. In respect of the question of validity of the proceedings u/s 153A, the Hon'ble CIT[A) in his order has taken cognisance of the decision of the Hon'ble Karnataka High Court in an earlier

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE vs. M/S CENTURY REAL ESTATE HOLDINGS PVT LTD, BANGALORE

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

section 14A states "Expenditure 4 ITA No.1590/Bang/2017 & Ors. M/s.Century Real Estate Holdings Pvt.Ltd. incurred in relation to income not includible in total income." 10. In respect of the question of validity of the proceedings u/s 153A, the Hon'ble CIT[A) in his order has taken cognisance of the decision of the Hon'ble Karnataka High Court in an earlier

CANARA BANK (ERSTWHILE SYNDICATE BANK),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

In the result, appeals of the assessee are partly allowed

reassess under Section 147 or pass an order\nenhancing the assessment or reducing a refund already made or\notherwise increasing the liability of the assessee under Section 154, for\nany assessment year beginning on or before the 1st day of April 2001.\n9.\nFrom perusal of Section 14A

M/S MFAR DEVELOPERS PVT LTD ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(3) , BANGALORE

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2017-18

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. Explanation.—For the removal of doubts, it is hereby clarified that notwithstanding anything to the contrary contained

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

section 14A is justified when voluntary disallowance is made or no exempt income is earned. Whether additional depreciation is allowable for the process of converting raw coffee beans into liquid coffee. The validity of reassessment