AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

reassessment. Accordingly, the AO prepared draft Assessment Order under section 144C of the Act vide Order dated 31.03.2022 and issued to the assessee. Since assessee is a non- resident, therefore, the case was taken up by the International Taxation Department. The assessee did not challenge the draft Assessment Order passed under section 144C of the Act before

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 of the Act, it is evident that for the\npurposes of computing

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

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

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

reassessment proceeding had to be completed. Accordingly, the AO IT(IT)A Nos.191 to 194/Bang/2024 Page 4 of 43 passed the draft assessment order making additions towards royalty income as under:- Asst. Year Amount

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

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

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

reassessment proceeding had to be completed. Accordingly, the AO IT(IT)A Nos.191 to 194/Bang/2024 Page 4 of 43 passed the draft assessment order making additions towards royalty income as under:- Asst. Year Amount

VINOD KUMAR SINGHAL ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-3, BENGALURU

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

Bench: Shri. Laxmi Prasad Sahuandshri. Soundararajan Kassessment Year : 2014-15

section 147 of the Act, there is only one issue raised on the basis of the reasons recorded is regarding accommodation entries received by the assessee from shelle company and the ld. Pr.CIT has also directed the AO to examine the sale tax penalty of Rs.28,165/- and employees’ contribution to PF and ESI of Rs.8,159/- is not correct

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals of the assessee are partly allowed

2) of the Income-tax Act, read with explanation 4\nthereof has not been properly appreciated\n117. The conclusions that can be derived on a reading of\nthe aforesaid judgments are as follows:\n(i) Copyright is an exclusive right, which is negative in\nnature, being a right to restrict others from doing certain\nacts.\n(ii) Copyright

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

reassessment passed under\nclause (b) of section 153A in respect of each assessment year falling\nwithin six assessment years immediately preceding the assessment\nyear relevant to the previous year in which search is conducted under\nsection 132 or requisition is made under section 132A. The provision\nhas also been made applicable to orders of assessment passed under\nclause

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

reassessment passed under\nclause (b) of section 153A in respect of each assessment year falling\nwithin six assessment years immediately preceding the assessment\nyear relevant to the previous year in which search is conducted under\nsection 132 or requisition is made under section 132A. The provision\nhas also been made applicable to orders of assessment passed under\nclause

M/S. CRYSTAL GRANITE AND MARBLE PRIVATE LIMITED,RAMANAGARAM vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes and Stay Petition is dismissed as infructuous

Bench: Shri George George K & Shri Laxmi Prasad Sahus.P No.29/Bang/2023 Assessment Year: 2017-18

2 to 88 of the Finance Act 2021, as enforced w.e.f. 1-4-2021, are not conflicted. Insofar as the Explanation appended to clause A(a), A(b), and the impugned Notifications dated 31-3-2021 and 27-4-2021 (respectively) are concerned, we declare that the said Explanations must be read, as applicable to reassessment proceedings as may have

LAXMI MEMORIAL EDUCATION TRUST ,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, MANGALORE

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri Soundararajan K.Assessment Year: 2021-22

2 Lekha Bhat 2017-18 Affidavit Shashank D Assessee’s Paper book Page No 118 of 08 Raghavan No.1 (Page No. 89) Paper book No 1 3 2017-18 Affidavit Laxmi Memorial Education Trust, Mangalore Page 69 of 108 Akshara Assessee’s Paper book Page No 118-119 Shetty No.1 (Page No. 37 & 38) 09-10 of Paper book

B S SOMASEKHAR,BENGALURU vs. INCOME TAX OFFICER, WARD-5(1)(1), BANGALORE

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

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2013-14 Mr. Bommanayakanahalli Siddaiah Somashekhar, Vs. Ito, #51/4 21St Main, 22Nd Cross, Behind Maruthi Ward – 5(1)(1), Mandira, Vijaynagar, Bangalore. Bangalore – 560 040, Karnataka. Pan : Ainps 4894 D Appellant Respondent Assessee By : Shri. Adarsh, Ca Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 06.10.2025 Date Of Pronouncement : 15.10.2025

164. In this regard, assessee has filed reason for delay in filing the appeal. On going through the above reasons, we noted that there is reasonable cause for delay and reasons have been explained. On going through the explanation submitted by the learned Counsel and by relying on the judgment of the Hon’ble Supreme Court in the case

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

reassess in the light of the provision of the section 153C of the Act. 7.3.4 During the course of hearing the Learned AR has relied on the Judgement of the Division Bench of The Jurisdictional Karnataka High Court in Writ Appeal No. 830 to 834 of 2022 , order dated 22/01/2014, which we have dealt with in detail in the later

M/S. GLOBAL STAR REALTORS PRIVATE LIMITED ,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU

In the result, all the appeals of the assessee are partly\nallowed

reassessment\nproceedings based\non\nmaterial already\non\nrecord is bad in law\nRs.56,66,666/-\n\n3.\nThe assessee has also raised common additional ground in all\nthese appeals, which is as follows:\n\n“The learned Assessing Officer is right in making the assessment u/s 147\ninstead of invoking the jurisdiction u/s 153C/153A in the instant case in view

MRS. IBRAHIM KALEEL,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MANGALURU

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceeding was not sustainable Where Assessing Officer, on basis of search conducted at premises of A seized a diary which contained details of payment made by A to assessee, made addition in hands of assessee under section 69B as unexplained investment, in view of fact that author of diary had passed away prior to date of search and relevant

EMKAY HINDUSTAN INFRASTRUCTURE,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceeding was not sustainable Where Assessing Officer, on basis of search conducted at premises of A seized a diary which contained details of payment made by A to assessee, made addition in hands of assessee under section 69B as unexplained investment, in view of fact that author of diary had passed away prior to date of search and relevant

EMKAY HINDUSTAN INFRASTRUCTURE,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceeding was not sustainable Where Assessing Officer, on basis of search conducted at premises of A seized a diary which contained details of payment made by A to assessee, made addition in hands of assessee under section 69B as unexplained investment, in view of fact that author of diary had passed away prior to date of search and relevant

EMKAY HINDUSTAN INFRASTRUCTURE,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceeding was not sustainable Where Assessing Officer, on basis of search conducted at premises of A seized a diary which contained details of payment made by A to assessee, made addition in hands of assessee under section 69B as unexplained investment, in view of fact that author of diary had passed away prior to date of search and relevant

EMKAY HINDUSTAN INFRASTRUCTURE,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceeding was not sustainable Where Assessing Officer, on basis of search conducted at premises of A seized a diary which contained details of payment made by A to assessee, made addition in hands of assessee under section 69B as unexplained investment, in view of fact that author of diary had passed away prior to date of search and relevant