DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

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

3,16,71,211 21 of page 24 ITA No.405/Bang/2023 S.P No.29/Bang/2023 Addition made as per computation sheet to Profits and gains 25,53,097 from business b. No explanation regarding the impugned additional addition of Rs. 25,53,097/- has been provided anywhere in the order passed u/s 147. Moreover, there was no discussions held with regards to said

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 for the Assessment Year 2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1 54 on 29.07.2021, for the same AY, enhancing interest u./s 234B by Rs.1,68,14,539/and charged interest u/s 234D of Rs. 87,89,415/- since the interest initially undercharged under Section 234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BANGALORE

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 for the Assessment Year 2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1 54 on 29.07.2021, for the same AY, enhancing interest u./s 234B by Rs.1,68,14,539/and charged interest u/s 234D of Rs. 87,89,415/- since the interest initially undercharged under Section 234B(3). The appellant challenged this rectification order

DEPUTY COMMISSIONER OF INCOME-TAX, , BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 for the Assessment Year 2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1 54 on 29.07.2021, for the same AY, enhancing interest u./s 234B by Rs.1,68,14,539/and charged interest u/s 234D of Rs. 87,89,415/- since the interest initially undercharged under Section 234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY ENTERPRISES, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 for the Assessment Year 2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1 54 on 29.07.2021, for the same AY, enhancing interest u./s 234B by Rs.1,68,14,539/and charged interest u/s 234D of Rs. 87,89,415/- since the interest initially undercharged under Section 234B(3). The appellant challenged this rectification order

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceedings because the Assessing Officer failed to make out a case within the four corners of the provisions of section 147 of the Income-tax Act.” 69. The Hon’ble Delhi High Court in Commissioner of Income-tax v. SPL'S Siddhartha Ltd. [2012] 345 ITR 223 (DELHI) held as under:- “8. Thus, if authority is given expressly

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceedings because the Assessing Officer failed to make out a case within the four corners of the provisions of section 147 of the Income-tax Act.” 69. The Hon’ble Delhi High Court in Commissioner of Income-tax v. SPL'S Siddhartha Ltd. [2012] 345 ITR 223 (DELHI) held as under:- “8. Thus, if authority is given expressly

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/ and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/- and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY GLOBAL LIMITED, BANGALORE

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

147 for the Assessment Year\n2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1\n54 on 29.07.2021, for the same AY, enhancing interest u./s 234B\nby Rs.1,68,14,539/ and charged interest u/s 234D of Rs.\n87,89,415/- since the interest initially undercharged under Section\n234B(3). The appellant challenged this rectification order

LOKESH TALANKI ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(3)(1), BANGALORE

In the result, appeals of the assessee are allowed

Bench: Shri Beena Pillai & Ms. Padmavathy Sassessment Year : 2013-14

234B at the time of passing the impugned assessment order Page 3 of 23 g. The learned Commissioner appeals has not considered the valid explanation given by your appellant in this regard 3. The assessee is an individual and has filed the return of income on 30.09.2013. The case was selected for scrutiny and notice u/s. 143(2) dated

M/S VVD CONSTRUCTIONS PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234B and 234C also on the Post Survey Statements recorded on oath u/s. 131 of the Act without amounting to Rs.1,02,83,852 and appreciating the fact that the Appellant had declared 8% Margin of Profit Rs.5,64,490 subject to deductions and depreciation which was neither considered by the AO respectively. nor by the Ld. CIT(A). Same

M/S VVD CONSTRUCTIONS PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234B and 234C also on the Post Survey Statements recorded on oath u/s. 131 of the Act without amounting to Rs.1,02,83,852 and appreciating the fact that the Appellant had declared 8% Margin of Profit Rs.5,64,490 subject to deductions and depreciation which was neither considered by the AO respectively. nor by the Ld. CIT(A). Same

M/S VVD CONSTRUCTIONS PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

Bench: Shri Chandra Poojari & Smt. Beena Pillai

234B and 234C also on the Post Survey Statements recorded on oath u/s. 131 of the Act without amounting to Rs.1,02,83,852 and appreciating the fact that the Appellant had declared 8% Margin of Profit Rs.5,64,490 subject to deductions and depreciation which was neither considered by the AO respectively. nor by the Ld. CIT(A). Same