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

Section 1 53A of the Act, the appellant filed returns of\nincome as under:\nA.Y. Amount (Rs.) Date\n2013-14 4,00,50,020/- 27.07.2019\n2014-15 3,61,21,170/- 27.07.2019\n2015-16 3,88,52,740/- 27.07.2019\n2016-17 5,71,59,860/- 27.07.2019\n2017-18 5,86,04,920/- 27.07.2019\n2.3 The Assessing Officer completed

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

Section 1 53A of the Act, the appellant filed returns of\nincome as under:\nΑ.Υ.\nAmount (Rs.)\nDate\n2013-14\n4,00,50,020/-\n27.07.2019\n2014-15\n3,61,21,170/-\n27.07.2019\n2015-16\n3,88,52,740/-\n27.07.2019\n2016-17\n5,71,59,860/-\n27.07.2019\n2017-18\n5,86,04,920/-\n27.07.2019\n2.3 The Assessing Officer completed

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

4 of section 2 or which is of the nature referred to in sub-section `4A) of section 11 tax shall be charged on so much of the relevant income as is not exempt under section 11 or section 12, as If the relevant income not so exempt were. The income of an association

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

4 of section 2 or which is of the nature referred to in sub-section `4A) of section 11 tax shall be charged on so much of the relevant income as is not exempt under section 11 or section 12, as If the relevant income not so exempt were. The income of an association

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

VAIDYA SRIKANTAPPA SADASHIVAIAH SRIKANTH,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE- 1, , BANGALORE

11 is made, then such proceedings shall continue under\nthe provisions of the Act of 1894. It contemplates that such pending\nproceedings, as on the date on which the Act of 2013 came into force shall\ncontinue, and taken to their logical end. However, the exception to Section\n24(1)(b) is provided in Section

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

4. Aggrieved from the above Order, the assessee filed appeal before the CIT(A). Before the CIT(A), assessee has filed documents that was filed ITA Nos.440, 441/Bang/2024 Page 8 of 22 before the AO and after considering the various case laws and submission of the assessee, the ld. CIT(A) allowed appeal of the assessee observing as under

M/S. ANAND DIAGNOSTIC LABORATORY,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

In the result, the appeal by the assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

11. The learned Commissioner of Income Tax (Appeals)-15, Bengaluru erred in confirming the addition of Rs.49,00,12,501/- under the provisions of section 45(4) of the act ignoring the factual position that there were no transfer of assets consequent to alleged distribution and in the absence of any such distribution there was capital gains chargeable

M/S. ANAND DIAGNOSTIC LABORATORY,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

In the result, the appeal by the assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

11. The learned Commissioner of Income Tax (Appeals)-15, Bengaluru erred in confirming the addition of Rs.49,00,12,501/- under the provisions of section 45(4) of the act ignoring the factual position that there were no transfer of assets consequent to alleged distribution and in the absence of any such distribution there was capital gains chargeable

MR. MOHAMMED HANIF MOHAMMED YUSUF DHARWADKAR,HUBLI vs. INCOME-TAX OFFICER, WARD-1(1), HUBLI

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2017-18

Section 68 of the Act. Accordingly, he added Rs. 1,25,89,399/- to the income of the assessee and completed the assessment. Against this assessee went in appeal before ld. CIT(A). 8. The ld. CIT(A) observed that the assessee had opportunity before three forums - ITO(Inv.), AO and these proceedings — to furnish requisite material to establish

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

68 of the Income Tax Act, 1961, on account of the statements made by the assessee’s Directors in the course of search under Section 132 of the Act were not justified?” (a) In the case, the learned CIT-(A) held that evidence does not mean only documentary evidence and the statement under section 132(4

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE vs. AURA JEWELS, BANGALORE

In the result, the cross objection filed by the assessee is dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Years : 2017-18

68 of the Act. . CO-9/Bang/2023 Page 3 of 25 4. The relevant facts are that the assessee, a partnership firm, is engaged in the retail trading of jewelry, gold, silver, and other ornaments. The assessee's case for the assessment year under consideration was selected for scrutiny under CASS, and accordingly, a notice under Section

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

11 of the Act has committed\nspecified violations as defined in clauses (a) and (b) of Explanation to sub-section (4) of section\n12AB r.w.s 143(3) of the Act for the AY 2022-23.\n7.3 As per the provisions of section 143(3), the Assessing Officer is required to send a reference to\nthe Principal Commissioner

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. On facts and circumstances

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

68 in the hands of the\nassessee firm by merely relying on the sworn statements of the\npartner Mr. Mohammed Ibrahim which are not binding on the\nassessee. The learned AO ought to corroborate the admission\ncontained in the statement, if any, with independent evidence. If\nAO was not satisfied with the particulars, it would have issued\nsummons

MKH INFRASTRUCTURE,KERALA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

68 in the hands of the\nassessee firm by merely relying on the sworn statements of the\npartner Mr. Mohammed Ibrahim which are not binding on the\nassessee. The learned AO ought to corroborate the admission\ncontained in the statement, if any, with independent evidence. If\nAO was not satisfied with the particulars, it would have issued\nsummons

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

4) of the Act was recorded of the directors,\ntrustees and key employees of the finance department. The search\noperation showed that there are evidence relating to violation with\nrespect to the diversion of trust funds to the trustees for purchase of\nland in their individual capacity and advances to related entities.\nThere was bogus expenditure debited by the trust

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1-(4), BENGALURU vs. M/S KANSUR DEVELOPERS INDIA PVT. LTD., BENGALURU

In the result, the revenue appeals in ITA Nos

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

section 68 of the Income-tax Act,1961 ['the Act' for short]. On appeal the Ld. C1T(A) in his order in ITA No. 355/Deputy Commissioner of Income-tax/CC- 1(4)/CIT(A)-11/2015-16 dated 10.02.2016 has deleted the addition made. The revenue is now in this appeal before the Tribunal contesting the deletion made