M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALURU

In the result, appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reassessment proceedings for the year 2003-04, it was found that purchases worth Rs.61.40 lakhs were not supported by sufficient evidence. Purchase of such goods from various suppliers was verified, but it was found that such parties had not supplied the goods as named by the assessee. The Assessing Officer made an addition of the entire amount of purchase

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BENGALURU

Section 12AB(4) of the IT\nAct, have occurred in the previous year 2015-16 relevant to A.Y. 2016-17.\nAccordingly, the registration of the assessee trust, granted u/s 12AA of the Act, vide\ncertificate DIT[E]/12A/Vol I/B-706/W-01/02-03 dated 19.03.2003 and subsequently\nu/s 12AB r.w.s 12A(1)(ac) (i) in Form No. 10AC dated 24.09.2021 is hereby cancelled\nfor

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BANGALORE

section\n12 AA (3) nor in section 12 AA (4) it has been provided or is\nseen to have explicitly provided to have retrospective\ncharacter or intent.\nITA Nos.2106 to 2109/Bang/2024\nPage 54 of 81\n(ii) In Global Health Research and Management Institute versus\nthe PCIT Jaipur in ITA No. 397/Jodh/2019 dated 25 January\n2023 wherein in paragraph

M/S. KESAR MARBLE AND GRANITES LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3) , BANGALORE

reassessment\nunder Section 153C follows lines pari materia with Section\n153A.\nD. The First Proviso to Section 153C introduces a legal fiction\non the basis of which the commencement date for computation\nof the six year or the ten year block is deemed to be the date of\nreceipt of books of accounts by the jurisdictional AO. The\nidentification

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL, BENGALURU

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

section 12AB(4) issued a show-cause notice for cancellation of the registration as under :- ITA Nos.2106 to 2109/Bang/2024 Page 22 of 81 ITA Nos.2106 to 2109/Bang/2024 Page 23 of 81 ITA Nos.2106 to 2109/Bang/2024 Page 24 of 81 ITA Nos.2106 to 2109/Bang/2024 Page 25 of 81 ITA Nos.2106 to 2109/Bang/2024 Page 26 of 81 ITA Nos.2106 to 2109/Bang/2024 Page

M/S. KESAR MARBLE AND GRANITES LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3) , BANGALORE

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

reassessment\nunder Section 153C follows lines pari materia with Section\n153A.\nD. The First Proviso to Section 153C introduces a legal fiction\non the basis of which the commencement date for computation\nof the six year or the ten year block is deemed to be the date of\nreceipt of books of accounts by the jurisdictional AO. The\nidentification

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BENGALURU

Section 12AB(4) of the IT\nAct, have occurred in the previous year 2015-16 relevant to A.Y. 2016-17.\nAccordingly, the registration of the assessee trust, granted u/s 12AA of the Act, vide\nPage 43 of 81\nITA Nos.2106 to 2109/Bang/2024\ncertificate DIT[E]/12A/Vol I/B-706/W-01/02-03 dated 19.03.2003 and subsequently\nu/s 12AB r.w.s 12A(1)(ac) (i) in Form

M/S. KESAR MARBLE AND GRANITES LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

reassessment\nunder Section 153C follows lines pari materia with Section\n153A.\nD. The First Proviso to Section 153C introduces a legal fiction\non the basis of which the commencement date for computation\nof the six year or the ten year block is deemed to be the date of\nreceipt of books of accounts by the jurisdictional AO. The\nidentification

M/S. HARIS MARINE PRODUCTS,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, MANGALORE

In the result, both the appeals of the assessee are\nallowed

reassessment under Section 153C follows lines pari materia\nwith Section 153A.\nD. The First Proviso to Section 153C introduces a legal\nfiction on the basis of which the commencement date for\ncomputation of the six year or the ten year block is deemed to\nbe the date of receipt of books of accounts by the\njurisdictional AO. The identification

TABESCO HINDUSTAN INFRA DEVELOPERS PVT LTD., ,KERALA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , MANGALORE

In the result, appeals of the assessee in ITA Nos

reassessment under Section 153C follows lines pari materia\nwith Section 153A.\nD. The First Proviso to Section 153C introduces a legal\nfiction on the basis of which the commencement date for\ncomputation of the six year or the ten year block is deemed to\nbe the date of receipt of books of accounts by the\njurisdictional AO. The identification

M/S. KESAR MARBLE AND GRANITES LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

reassessment\nunder Section 153C follows lines pari materia with Section\n153A.\nD. The First Proviso to Section 153C introduces a legal fiction\non the basis of which the commencement date for computation\nof the six year or the ten year block is deemed to be the date of\nreceipt of books of accounts by the jurisdictional AO. The\nidentification

M/S. KESAR MARBLE AND GRANITES LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

reassessment\nunder Section 153C follows lines pari materia with Section\n153A.\nD. The First Proviso to Section 153C introduces a legal fiction\non the basis of which the commencement date for computation\nof the six year or the ten year block is deemed to be the date of\nreceipt of books of accounts by the jurisdictional AO. The\nidentification

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

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

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 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

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

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

M/S. HARIS MARINE PRODUCTS,MANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALORE

In the result, both the appeals of the assessee are\nallowed

reassessment under Section 153C follows lines pari materia\nwith Section 153A.\nD. The First Proviso to Section 153C introduces a legal\nfiction on the basis of which the commencement date for\ncomputation of the six year or the ten year block is deemed to\nbe the date of receipt of books of accounts by the\njurisdictional AO. The identification