SRI SRINIVASA TRUST,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3,26,29,956.56 Balance 5 Net Bank 63,49,03,157.20 28,74,34,369.84 34,74,68,787.36 Balance 23.9 Thus, the question arises whether such an increase in the bank balance maintained with the scheduled bank can be treated as an investment as per the provisions of section 11

SRI SRINIVASA TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3,26,29,956.56 Balance 5 Net Bank 63,49,03,157.20 28,74,34,369.84 34,74,68,787.36 Balance 23.9 Thus, the question arises whether such an increase in the bank balance maintained with the scheduled bank can be treated as an investment as per the provisions of section 11

ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

Bench: Shri George George K & Shri Waseem Ahmed

11 was allowed by the Revenue in assessments framed under Section 143(3) of the Act. The first issue that arises is whether the Revenue can take a different stand in the assessee’s own case for the current year as compared to the stance adopted in the earlier years or subsequent years. While the principle of res judicata

ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

Bench: Shri George George K & Shri Waseem Ahmed

11 was allowed by the Revenue in assessments framed under Section 143(3) of the Act. The first issue that arises is whether the Revenue can take a different stand in the assessee’s own case for the current year as compared to the stance adopted in the earlier years or subsequent years. While the principle of res judicata

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

68\ntaxmann.com 368 (SC) and Anil Minda v. CIT [2023] 148 taxmann.com\n407 (SC), which are directly on the point and binding.\n11.8 In VLS Finance Ltd. (supra), the authorisation for search was\nissued on 19nd June 1998 based on which the search was commenced\non 22nd June 1998 which went up to morning hour of 23rd June

SHRI HINGULAMBIKA EDUCATION SOCIETY,GULBARGA vs. ITO (EXEMPTIONS), WARD-1, KALBURGI

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2020-21

11, 12 & 13 of the Income Tax Act, 1961, without prejudice to the fact of granting merely in principle registration by DIT(E). (ii) With effect from the Assessment Year 2009-10, the advancement of any object of general public utility other than relief of the poor, education and medical relief as defined in section

CHANDRASHEKAR HEMANTH ,BENGALURU vs. INCOME TAX OFFICER WARD 7(2)(4) BANGALORE, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

68,022/- were available for brought forward and set off against any profits arose in the subsequent years. The assessee in the assessment year 2014-15 had earned an income of Rs. 12,41,729/- and for the A.Y. 2015-16, a sum of Rs. 3

SHRI. BANGALORE NARAYAN DAS,BENGALURU vs. INCOME-TAX OFFICER, (INTERNATIONAL TAXATION-1(1), BENGALURU

In the result the appeal filed by the assessee for assessment year 2014-15 & 2017-18 stands allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos. 120 & 121/Bang/2022 (Assessment Years: 2014-15 & 2017-18)

11 IT(IT)A Nos. 120 & 121/Bang/2022 Bangalore Narayan Das 6.3. The assessee filed application for admission of additional grounds which reads as under:- 1. The learned Assessing officer, Income Tax Officer, Ward- International Taxation 1(1), BLR, being the jurisdictional Assessing officer, has failed to issue a notice under section 143(2) of the Act, and consequently

SHRI. BANGALORE NARAYAN DAS,BENGALURU vs. INCOME-TAX OFFICER, (INTERNATIONAL TAXATION-1(1), BENGALURU

In the result the appeal filed by the assessee for assessment year 2014-15 & 2017-18 stands allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos. 120 & 121/Bang/2022 (Assessment Years: 2014-15 & 2017-18)

11 IT(IT)A Nos. 120 & 121/Bang/2022 Bangalore Narayan Das 6.3. The assessee filed application for admission of additional grounds which reads as under:- 1. The learned Assessing officer, Income Tax Officer, Ward- International Taxation 1(1), BLR, being the jurisdictional Assessing officer, has failed to issue a notice under section 143(2) of the Act, and consequently

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, , BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No:Aaajk0398K\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

68,052 representing unpaid pension and leave contribution is to be added back to income, the same is bad in law and liable to be deleted in its entirety.\n9. 2. The learned Assessing officer has erred in invoking section 43B as the appellant is governed by provisions of section 11.\n9. 3

ACIT, CIRCLE-2(2)(1), BANGALORE vs. VASTIMAL BHIM RAJ SANCHETI, BANGALORE

In the result, the appeals of the Revenue are dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K

3) of the Act for the Assessment Year 2016-17 on 13.12.2018, it was noticed that the assessee has received cash credit of Rs.8.31 Crores from the entity M/s. Mangal trading and clothing LLP during the relevant previous year and listed the entity as sundry creditors. However, on the basis of detailed enquiry carried out, the AO established that

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER, (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest

M/S. LIFE INSURANCE CORPORATION OF INDIA ,SHIVAMOGGA vs. THE INCOME TAX OFFICER (TDS) -WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest

M/S. LIFE INSURANCE CORPORATION OF INDIA,SHIVAMOGGA vs. THE INCOME TAX OFFICER (TDS) -WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest

M/S. LIFE INSURANCE CORPORATION OF INDIA,SHIVAMOGGA vs. THE INCOME TAX OFFICER (TDS) -WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest