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

viii) -Page 38 of his order and observed that the view taken by him in earlier years has been clarified in Explanation-2. Thus, according to Ld CIT(A) as well as by the revenue that the decision rendered by Hon’ble Supreme Court in the case of Catholic Syrian Bank (2012)( 343 ITR 270) has been undone

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, revenue’s appeal in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment 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

CANARA BANK,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

In the result, revenue’s appeal in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment 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

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2(1)(1), BANGALORE vs. CANARA BANK, BANGALORE

In the result, appeals filed by assessee and revenue stands partly allowed for statistical purposes

Bench: Chandra Poojari & Smt. Beena Pillai

36(1)(vii) iii-iv CSR Expenditure Revenue appeal vii-viii RBI penalty Revenue appeal ix Club Expenses Revenue appeal 5. At the outset, the Ld. DR submitted that there is a delay of 109 days in filing the revenue’s appeal before this Tribunal. The revenue has filed condonation petition dated 04.09.2023 seeking the delay to be condoned

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, appeals filed by assessee and revenue stands partly allowed for statistical purposes

Bench: Chandra Poojari & Smt. Beena Pillai

36(1)(vii) iii-iv CSR Expenditure Revenue appeal vii-viii RBI penalty Revenue appeal ix Club Expenses Revenue appeal 5. At the outset, the Ld. DR submitted that there is a delay of 109 days in filing the revenue’s appeal before this Tribunal. The revenue has filed condonation petition dated 04.09.2023 seeking the delay to be condoned

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, appeals filed by assessee and revenue stands partly allowed for statistical purposes

Bench: Chandra Poojari & Smt. Beena Pillai

36(1)(vii) iii-iv CSR Expenditure Revenue appeal vii-viii RBI penalty Revenue appeal ix Club Expenses Revenue appeal 5. At the outset, the Ld. DR submitted that there is a delay of 109 days in filing the revenue’s appeal before this Tribunal. The revenue has filed condonation petition dated 04.09.2023 seeking the delay to be condoned

SRI. ANNESH,UDUPI vs. INCOME-TAX OFFICER, WARD-1, CHIKMANGALUR

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojari

viii) The Income-tax Officer Ward No.1 (1), Noida, had then issued notice under Section 142(1) of the Act dated 27th April, 2016 requiring the petitioner to comply with the directions contained therein including filing of return. (ix) The petitioner thereafter responded and wrote to the Income- Tax Officer Ward No.1 (1), Noida for the first time on 19th

M/S. CONCORDE HOUSING CORPORATION PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

reassess the income in absence of any incriminating material found and seized during the course of search or post search enquiry. In the case in hand, we find that the entire basis of the additional income assessed to tax in the proceedings U/s 153A of the Act is the statement of the assessee

NABHIRAJ RATNA BALRAJ BY LEGAL HEIR B.R.RAKESH,BANGALORE vs. INCOME-TAX OFFICER, WARD-7(2)(1), BANGALORE

In the result the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

reassessment proceeding also makes the order bad in law and such order is liable to be quashed. 3.1 In any case and without prejudice, the learned Commissioner of Income tax (Appeals) has erred in holding that the provisions of Section 50C of the Act are applicable in the instant case and thus confirming the additions made by Assessing officer

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

viii). CIT Vs. Abhyudhaya Builders (P) Ltd [2012] 20 taxmann.com\n851(Allahabad) The learned Standing Council for the Revenue\n\nPage 26 of 77\nITA Nos.45, 46, 47, 48/Bang/2020\nITA No.205/Bang/2022\nsubmitted that in this case the Allahabad High Court upheld the action\nof the AO in resorting to reopening under section 147 of the Act as the\ntime limit

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

viii). CIT Vs. Abhyudhaya Builders (P) Ltd [2012] 20 taxmann.com\n851(Allahabad) The learned Standing Council for the Revenue\n\nPage 26 of 77\nITA Nos.45, 46, 47, 48/Bang/2020\nITA No.205/Bang/2022\nsubmitted that in this case the Allahabad High Court upheld the action\nof the AO in resorting to reopening under section 147 of the Act as the\ntime limit

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

reassessment or recomputation or fresh assessment, as the case may be, expires'. Since the time limit for passing of the order by the TPO is not direct but is linked with the time limit as per section 153, the legislature did not insert any sunset clause in section 153, which would have otherwise made the provision of sub-section

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

viii). CIT Vs. Abhyudhaya Builders (P) Ltd [2012] 20 taxmann.com\n851(Allahabad) The learned Standing Council for the Revenue\n\nPage 26 of 77\nsubmitted that in this case the Allahabad High Court upheld the action\nof the AO in resorting to reopening under section 147 of the Act as the\ntime limit to initiate proceedings under section 158BD

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

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

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

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

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

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

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

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

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

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall