M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

reassess the income of the appellant and consequently the notice issued under section 153A of the Act is invalid and the entire assessment proceedings is bad in law and void ab initio on the facts and circumstances of the case. ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore Page 8 of 115 4. The appellant craves leave

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

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

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

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

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

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

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

250 of the Income Tax Act, 1961 (the Act) for the Assessment Year (AY) 2020-21. 2. The assessee has raised the following grounds of appeal: “1. a) The Ld. Commissioner of Income Tax (Appeals), erred in law and facts by confirming the order passed by the Ld. Assessing Officer levying a penalty of 50 percent of tax under

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 148 of the Act was issued, initiating the reassessment proceedings. - The CIT(A) has distinguished the facts of the case from Karnataka HC’s ruling in Manjunatha Cotton & Ginning Factory [2013] 35 Taxmann.com 250

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 148 of the Act was issued, initiating the reassessment proceedings. - The CIT(A) has distinguished the facts of the case from Karnataka HC’s ruling in Manjunatha Cotton & Ginning Factory [2013] 35 Taxmann.com 250

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 148 of the Act was issued, initiating the reassessment proceedings. - The CIT(A) has distinguished the facts of the case from Karnataka HC’s ruling in Manjunatha Cotton & Ginning Factory [2013] 35 Taxmann.com 250

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 148 of the Act was issued, initiating the reassessment proceedings. - The CIT(A) has distinguished the facts of the case from Karnataka HC’s ruling in Manjunatha Cotton & Ginning Factory [2013] 35 Taxmann.com 250

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, MANGALORE vs. L JAVERCHAND JEWELLERS PRIVATE LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20 L. Javerchand Jewellers Pvt. Ltd. No.1, 2Nd Floor & 3Rd Floor, Choksi Chamber Dcit 1Stagyari Lane Vs. Central Circle-1 Zaveri Bazar Mangaluru Mumbai 400 002

250 of the Income Tax Act, 1961 ( in short “The Act”) for the assessment year ( in short “AY”) 2019-20. 2. The Revenue has raised the following grounds of appeal: L. Javerchand Jewellers Pvt. Ltd., Mumbai Page 2 of 17 3. Before leaping straightway to the penalty proceedings, it is very much pertinent here to discuss with regard

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

In the result, the appeal filed by the Revenue is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

250 of the Income Tax Act, 1961 (in short “the Act”) for the Assessment Year (AY) 2017-18. The assessee has not filed any cross objections (CO) against this appeal filed by the Revenue. 2. The Revenue has raised the following grounds of appeal: - Dcit(E), Circle-1, Bengaluru Page 2 of 24 Dcit(E), Circle-1, Bengaluru Page

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)

reassessment proceedings even when intimation under section 143(1) had been issued. A similar view has been taken in A. Pusa Lal v. CIT[1988] 169 ITR 215 (AP) ; Jorawar Singh Baid v. Asstt. CIT [1992] 198 ITR 47 (Cal.) and Pradeep Kumar Har Saran Lal v. Assessing Officer [1998] 229 ITR 46 (All.)." 34. The decision

SHRI.J M VRUSHABENDRAIAH ,HOSPET vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1 , BELLARY

The appeal of the assessee is partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

250 of the Act in so far as it is against the Appellant is opposed to law, equity, weight of evidence, probabilities and the facts and circumstances in the Appellant’s case. 2. The Commissioner of Income-tax (Appeals) failed to appreciate that the notice issued under section 148 of the Act is not in accordance with

MR. NATESHAN SAMPATH,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

250 of the Income Tax Act, 1961 (in short “The Act”) for the AY 2018-19. 2. The assessee has raised following grounds of appeal: Mr. Nateshan Sampath, Bangalore Page 2 of 12 3. Brief facts of the case are that assessee being an individual had not filed his return of income for the assessment year 2018-19. The case

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

reassessment proceedings. The learned CIT(A) without considering this, continued to issue hearing notices to the Appellant and had passed an order under section 250

JCIT vs. STATE BANK OF MYSORE,

In the result, appeal of the Revenue is dismissed

Bench: Smt. P. Madhavi Devi & Shri Jason P. Boaz

250 is filed before us and on perusal of the same, we find that the contentions of the Ld. Counsel for the assessee are correct. Therefore, these two grounds raised by the Revenue are dismissed/rejected as infructuous. 3. As regards ground No.4, brief facts are that the assessee is a PSU Banking company and filed its return of income