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 completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 6 of 104 of any incriminating material found during the course of search under section 132 or requisition under

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 completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 6 of 104 of any incriminating material found during the course of search under section 132 or requisition under

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 completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 6 of 104 of any incriminating material found during the course of search under section 132 or requisition under

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeal filed by the Revenue is allowed for statistical purpose

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahuthe Dy. Commissioner Of Vs Shri C. Gangadhara Murthy Income-Tax, No. 322, 3Rd A Corss, 2Nd Block Circle - 6(2)(1) 3Rd Stage, Basaveshwaranagar Bangalore . Bangalore 560079. Pan – Agipg 2668 N (Appellant) (Respondent)

156. Jurisdiction to make adjustment under the provisions of section 143(1)(a) is co-extensive and coterminous with the jurisdiction vested in the Assessing Officer under section 154 for making obvious corrections, as no item of debatable nature can be corrected under section 154 of the Act. Similarly, the Assessing Officer cannot enter into any controversial item to make

IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

reassessment, referred to in clause (a) of sub-section (1), in a case where an order under sub-section (4) has been made accepting the application.” 5.3 Before leaping to section 270A of the Act, we first consider section 270AA of the Act in order to find out whether the Form 68 filed by the Assessee Company on 06/10/2022

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income. If the commissioner has come across any income that the assessing authority has not taken note of while

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income. If the commissioner has come across any income that the assessing authority has not taken note of while

SURETEX PROPHYLACTICS (INDIA) LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result appeal filed by assessee stands allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.430/Bang/2016 Assessment Year : 2011-12

reassessment order passed by the Assessing Officer with the prior approval of the Commissioner as provided in sub-section (12) of section 144BA. Page 9 of 16 IT(TP)A No.430/Bang/2016 (15) For the purposes of this section, — (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board54 for this purpose

M/S. CISCO SYSTEMS SERVICES B.V. INDIA BRANCH,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE- 1(1), BANGALORE

In the result, the appeal by the assessee is allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(It)A No. 2572/Bang/2019 Assessment Year : 2011-12 M/S. Cisco Systems Services B.V. – India The Deputy Branch, Commissioner Of Brigade South Parade, Income Tax, No. 10, Mahatma Gandhi International Taxation, Road, Circle – 1(1), Vs. Bangalore – 560 001. Bangalore. Pan: Aaccc4836D Appellant Respondent Assessee By : Shri Rajan Vora, Ca Revenue By : Shri Pradeep Kumar, Cit (Dr) Date Of Hearing : 04-01-2022 Date Of Pronouncement : 12-01-2022 Order Per Beena Pillaithis Appeal By Assessee Is Directed Against The Order Of The Ld.Ao Dated 31.12.2015 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 [The Act] On The Following Grounds: “Based On The Facts & Circumstances Of The Case & In Law, Cisco Systems Services B.V. —India Branch (Hereinafter Referred To As 'The Appellant'), Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Learned Assessing Officer (Hereinafter Referred To As The 'Learned Ao') Dated October 15, 2019 Under Section 147 Read With Section 143(3) Read With Section 144C Of The Income-Tax Act, 1961 (`The Act') Pursuant To The Directions Dated September 23, 2019 Issued By The Drp U/S 144C(5) Of The Act ('The Impugned Order') Inter-Alia On The Following Grounds:

reassessment order passed by the Assessing Officer with the prior approval of the Commissioner as provided in sub-section (12) of section 144BA. Page 10 of 16 IT(IT)A No. 2572/Bang/2019 (15) For the purposes of this section, -- (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board54 for this purpose

CISCO SYSTEMS SERVICES B V INDIA BRANCH,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(1), BENGALURU

In the result, the appeal by the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment order passed by the Assessing Officer with the prior approval of the Commissioner as provided in sub-section (12) of section 144BA. (15) For the purposes of this section, -- (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board54 for this purpose; (b) "eligible assessee" means,-- (i) any person in whose

CISCO SYSTEMS SERVICES B.V,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-1(1), BANGALORE

In the result, the appeal by the assessee is allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(It)A No. 961/Bang/2017 Assessment Year : 2012-13 M/S. Cisco Systems Services B.V. – India The Deputy Branch, Commissioner Of Brigade South Parade, Income Tax, No. 10, International Taxation, Mahatma Gandhi Road, Circle – 1(1), Vs. Bangalore – 560 001. Bangalore. Pan: Aaccc4836D Appellant Respondent Assessee By : Shri Rajan Vora, Ca : Dr. Manjunath Karkaihalli, Revenue By Cit Dr Date Of Hearing : 19-01-2022 Date Of Pronouncement : 19-01-2022 Order Per Beena Pillaithis Appeal By Assessee Is Directed Against The Order Of The Ld.Ao Dated 27.02.2017 Passed U/S. 143(3) R.W.S. 144C(14) Of The Income- Tax Act, 1961 [The Act] On The Following Grounds: “Based On The Facts & Circumstances Of The Case & In Law, Cisco Systems Services B.V. - India Branch (Hereinafter Referred To As The 'Appellant.) Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Deputy Commissioner Of Income-Tax (International Taxation) - Circle 1(1) ('Assessing Officer' Or 'Ao') Dated February 27, 2017 In Pursuance Of The Directions & The Revised Directions Issued By The Dispute Resolution Panel ('Drp'), Bangalore Dated December 29, 2016 & January 16. 2017 Respectively, Under Section 253 Of The Income-Tax Act, 1961 ('Act) On The Following Grounds:

reassessment order passed by the Assessing Officer with the prior approval of the Commissioner as provided in sub-section (12) of section 144BA. (15) For the purposes of this section, -- (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board54 for this purpose; Page 11 of 17 IT(IT)A No. 961/Bang/2017

SHRI E M V M VISHWANATHAN,COORG vs. INCOME TAX OFFICER WARD-1 , MADIKERE

In the result, the assessee's appeal for Assessment Year 2008-09 is

Bench: Shri Jason P Boaz

reassessment proceedings under Section 147 of the Act and issued notice under Section 148 of the Act to the assessee on 23.3.2015 in order to bring to tax the assessee's income from Capital Gains on sale of properties at Thanjavur that had escaped assessment. The assessment was completed under Section 143(3) r.w.s. 147 of the Act vide order

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

156 of the Act does not create three times more than the actual liability as alleged by the assessee. Since, only one demand notice has been issued in the name of the three legal heirs collectively, and not separately for each individual, there is no duplication of tax demand. The AO has sought to ensure that the outstanding tax liability

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

156 of the Act does not create three times more than the actual liability as alleged by the assessee. Since, only one demand notice has been issued in the name of the three legal heirs collectively, and not separately for each individual, there is no duplication of tax demand. The AO has sought to ensure that the outstanding tax liability

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

156 of the Act does not create three times more than the actual liability as alleged by the assessee. Since, only one demand notice has been issued in the name of the three legal heirs collectively, and not separately for each individual, there is no duplication of tax demand. The AO has sought to ensure that the outstanding tax liability

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

156 of the Act does not create three times more than the actual liability as alleged by the assessee. Since, only one demand notice has been issued in the name of the three legal heirs collectively, and not separately for each individual, there is no duplication of tax demand. The AO has sought to ensure that the outstanding tax liability

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

156 of the Act does not create three times more than the actual liability as alleged by the assessee. Since, only one demand notice has been issued in the name of the three legal heirs collectively, and not separately for each individual, there is no duplication of tax demand. The AO has sought to ensure that the outstanding tax liability

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

156 of the Act does not create three times more than the actual liability as alleged by the assessee. Since, only one demand notice has been issued in the name of the three legal heirs collectively, and not separately for each individual, there is no duplication of tax demand. The AO has sought to ensure that the outstanding tax liability