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 of the Act, it is evident that for the purposes of computing

SHRI. VARADARAJAN NARAYAN AIYAR,BENGALURU vs. INCOME-TAX OFFICER, WARD-1(2)(1), BANGALORE

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

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am

194-IA of the Act. Out of the consideration received of Rs.2,12,07,936, Rs.2 crore was received by way of RTGS and balance Rs.12,07,936 was accepted in cash. Taking note of this cash transaction in respect of the transfer of the property, the Assessing Officer invoked the provisions of section 269SS

DCIT, CENTRAL CIRCLE, BELLARI vs. M/S. NAVODAYA EDUCATION TRUST, RAICHUR

In the result, the appeal of the revenue is partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2009-10

reassessment proceedings by holding that first proviso to section 143(3) of the Act is applicable and he exceeded his jurisdiction in admitting the additional grounds of appeal. 6.4 Further, the ld. A.R. relied on the judgement of jurisdictional High Court in the case of Shri D.M. Purnesh cited (supra) for the proposition that the AO has accepted that

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

194 12 18,88,223 1,65,21,953 11.4 Further, even as per the seized document itself, a substantial portion represents opening balance of earlier year, which cannot be brought to tax in the present assessment year. Thus, we find that the addition has been made purely on assumptions and presumptions, without any supporting evidence. Such an addition cannot

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

194 12 18,88,223 1,65,21,953 11.4 Further, even as per the seized document itself, a substantial portion represents opening balance of earlier year, which cannot be brought to tax in the present assessment year. Thus, we find that the addition has been made purely on assumptions and presumptions, without any supporting evidence. Such an addition cannot

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

194 12 18,88,223 1,65,21,953 11.4 Further, even as per the seized document itself, a substantial portion represents opening balance of earlier year, which cannot be brought to tax in the present assessment year. Thus, we find that the addition has been made purely on assumptions and presumptions, without any supporting evidence. Such an addition cannot

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

194 12 18,88,223 1,65,21,953 11.4 Further, even as per the seized document itself, a substantial portion represents opening balance of earlier year, which cannot be brought to tax in the present assessment year. Thus, we find that the addition has been made purely on assumptions and presumptions, without any supporting evidence. Such an addition cannot

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

194 12 18,88,223 1,65,21,953 11.4 Further, even as per the seized document itself, a substantial portion represents opening balance of earlier year, which cannot be brought to tax in the present assessment year. Thus, we find that the addition has been made purely on assumptions and presumptions, without any supporting evidence. Such an addition cannot

KASIREDDY RANADHEER REDDY,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

194 12 18,88,223 1,65,21,953 11.4 Further, even as per the seized document itself, a substantial portion represents opening balance of earlier year, which cannot be brought to tax in the present assessment year. Thus, we find that the addition has been made purely on assumptions and presumptions, without any supporting evidence. Such an addition cannot

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S TRISHUL DEVELOPERS, BENGALURU

reassessment proceedings on ground that notice not\nvalid u/s 148 of the Act which could not be issued against a dead\nperson, SLP filed against the said order was dismissed.”\n7.11\nThe Hon'ble Gujarat High court in the case of Bhupendra Bhikalal\nDesai cited (supra) held as under:\n\"Notice issued under section 153C against dead person is unenforceable

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BANGALORE vs. M/S TRISHUL DEVELOPERS, BANGALORE

In the result, appeals filed by the Revenue are dismissed

reassessment proceedings on ground that notice not\nvalid u/s 148 of the Act which could not be issued against a dead\nperson, SLP filed against the said order was dismissed.”\n7.11\nThe Hon'ble Gujarat High court in the case of Bhupendra Bhikalal\nDesai cited (supra) held as under:\n\"Notice issued under section 153C against dead person is unenforceable

EXPAT ENGINEERING INDIA LIMITED,BENGALURU vs. ACIT, CIRCLE-2(1)(2), BENGALURU

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

reassessment proceedings u/s.147 of the Act. The Court found that material on the record before the Court showed that in the statement of total income the assessee had disclosed an interest income of Rs.50.14 lacs as income from other sources. In the note appended to the statement of computation, under the heading 'interest income' the assessee stated that this represented

EXPAT ENGINEERING INDIA LIMITED,BENGALURU vs. ACIT, CIRCLE-2(1)(2), BENGALURU

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

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am

reassessment proceedings u/s.147 of the Act. The 9 ITA No.1139/Bang/2022. M/s.Expat Engineering India Limited. Court found that material on the record before the Court showed that in the statement of total income the assessee had disclosed an interest income of Rs.50.14 lacs as income from other sources. In the note appended to the statement of computation, under the heading 'interest