M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

153C as it stood before the amendment vide Finance Act, 2015 read as:— 153-C. Assessment of income of any other person.—(1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and Section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

153C as it stood before the amendment vide Finance Act, 2015 read as:— 153-C. Assessment of income of any other person.—(1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and Section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

153C as it stood before the amendment vide Finance Act, 2015 read\nas:-\n153-C. Assessment of income of any other person. (1) Notwithstanding\nanything contained in section 139, section 147, section 148, section 149,\nsection 151 and Section 153, where the Assessing Officer is satisfied that any money,\nbullion, jewellery or other valuable article or thing or books

MR. D K SHIVAKUMAR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

In the result, we allow appeal filed by the assessee

reassess income of such other person in accordance with the provisions of\nsection 153A...\n10.\nIt is seen from the above that Section 153C starts with a non obstante clause, which actually\nprohibits initiation of proceedings under any section other than Section 153C under the facts and\ncircumstances as prevalent in the present case. The AO mentions in the assessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE vs. MR. D K SHIVAKUMAR, BANGALORE

In the result, we allow appeal filed by the assessee

reassess income of such other person in accordance with the provisions of\nsection 153A...\n10.\nIt is seen from the above that Section 153C starts with a non obstante clause, which actually\nprohibits initiation of proceedings under any section other than Section 153C under the facts and\ncircumstances as prevalent in the present case. The AO mentions in the assessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE vs. MR. D K SHIVAKUMAR, BANGALORE

reassess income of such other person in accordance with the provisions of\nsection 153A...\n10. It is seen from the above that Section 153C starts with a non obstante clause, which actually\nprohibits initiation of proceedings under any section other than Section 153C under the facts and\ncircumstances as prevalent in the present case. The AO mentions in the assessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE vs. MR. D K SHIVAKUMAR, BANGALORE

In the result, we allow appeal filed by the assessee

reassess income of such other person in accordance with the provisions of\nsection 153A...\n10.\nIt is seen from the above that Section 153C starts with a non obstante clause, which actually\nprohibits initiation of proceedings under any section other than Section 153C under the facts and\ncircumstances as prevalent in the present case. The AO mentions in the assessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE vs. MR. D K SHIVAKUMAR, BANGALORE

reassess income of such other person in accordance with the provisions of\nsection 153A...'\n\n10. It is seen from the above that Section 153C starts with a non obstante clause, which actually\nprohibits initiation of proceedings under any section other than Section 153C under the facts and\ncircumstances as prevalent in the present case. The AO mentions

NIYAZ SEA FOODS ,MANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , MANGALORE

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

2) of the Act on the pretext of the statements of the Directors of the respondent-assessee companies recorded under Section 132(4) of the Act and material seized from the search conducted on Jain group of companies. The assessment order was also passed under Section 143(3) read with Section 153C of the Act making additions under Section

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

153C. Assessment of income of any other person. (1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or ITA Nos.619 to 622/Bang/2025 Page

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

153C. Assessment of income of any other person. (1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or ITA Nos.619 to 622/Bang/2025 Page

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

153C. Assessment of income of any other person. (1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or ITA Nos.619 to 622/Bang/2025 Page

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

153C. Assessment of income of any other person. (1)Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a)any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or ITA Nos.619 to 622/Bang/2025 Page

MOHAMMED MUJEEB SIKANDER,MANGALORE vs. DCIT, CENTRAL CIRCLE (1), MANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153C of the Act and the assessment was ought to have framed u/s 153A of the Act. Now we take provisions of section 153A of the Act, which reads as follows:- “153A. Assessment in case of search or requisition. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case

MOHAMMED MUJEEB SIKANDER,MANGALORE vs. DCIT, CENTRAL CIRCLE (1), MANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

153C of the Act and the assessment was ought to have framed u/s 153A of the Act. Now we take provisions of section 153A of the Act, which reads as follows:- “153A. Assessment in case of search or requisition. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case

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

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under

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

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under

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

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under

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

2 and sub grounds thereunder is that the year under consideration does not fall ITA No.882 to 887/Bang/2025 Page 7 of 27 under the period of 6 assessment years as envisaged under section 153C of the Act, hence assessment made under section 153C r.w.s. 143(3) is void ab initio. 17. The relevant facts are that a search under