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

68\nof the Income Tax Act, 1961, on account of the statements made by the assessee's\nDirectors in the course of search under Section 132

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

68\nof the Income Tax Act, 1961, on account of the statements made by the assessee's\nDirectors in the course of search under Section 132

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX OFFICER, CENTRAL CIRCLE-2(2), BENGALURU

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

132(1) of the Act on 13.01.2018, the notice was issued under section 153A of the Act on the basis of seized materials found in the form of bogus revenue expenditure claimed and assessee filed return of income and total declaration was made of Rs.6,68

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

132(1) of the Act on 13.01.2018, the notice was issued under section 153A of the Act on the basis of seized materials found in the form of bogus revenue expenditure claimed and assessee filed return of income and total declaration was made of Rs.6,68

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

132(1) of the Act on 13.01.2018, the notice was issued under section 153A of the Act on the basis of seized materials found in the form of bogus revenue expenditure claimed and assessee filed return of income and total declaration was made of Rs.6,68

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

132(1) of the Act on 13.01.2018, the notice was issued under section 153A of the Act on the basis of seized materials found in the form of bogus revenue expenditure claimed and assessee filed return of income and total declaration was made of Rs.6,68

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

132 of the Act has to be related to cogent and positive materials found during search which prove conclusively that the assessee has either earned an income or made an investment which has not been recorded in his regular books of account or that his case is covered under any of the deeming provisions contained in sections 68

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

132 of the Act has to be related to cogent and positive materials found during search which prove conclusively that the assessee has either earned an income or made an investment which has not been recorded in his regular books of account or that his case is covered under any of the deeming provisions contained in sections 68

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

132 of the Act has to be related to cogent and positive materials found during search which prove conclusively that the assessee has either earned an income or made an investment which has not been recorded in his regular books of account or that his case is covered under any of the deeming provisions contained in sections 68

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

132 of the Act has to be related to cogent and positive materials found during search which prove conclusively that the assessee has either earned an income or made an investment which has not been recorded in his regular books of account or that his case is covered under any of the deeming provisions contained in sections 68

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

132 of the Act has to be related to cogent and positive materials found during search which prove conclusively that the assessee has either earned an income or made an investment which has not been recorded in his regular books of account or that his case is covered under any of the deeming provisions contained in sections 68

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

132 of the Act has to be related to cogent and positive materials found during search which prove conclusively that the assessee has either earned an income or made an investment which has not been recorded in his regular books of account or that his case is covered under any of the deeming provisions contained in sections 68

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

132 of the Act has to be related to cogent and positive materials found during search which prove conclusively that the assessee has either earned an income or made an investment which has not been recorded in his regular books of account or that his case is covered under any of the deeming provisions contained in sections 68

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

132(4) of the Act? ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore Page 49 of 115 10.6 We place reliance on the decision rendered by Hon'ble Supreme Courtin the case of Pullangode Rubber Product Co. Vs. State of Kerala (91 ITR 18) (SC), wherein it was held that the admission may be an important piece

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

132(4) of the Act? ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore Page 49 of 115 10.6 We place reliance on the decision rendered by Hon'ble Supreme Courtin the case of Pullangode Rubber Product Co. Vs. State of Kerala (91 ITR 18) (SC), wherein it was held that the admission may be an important piece

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

132(4) of the Act? ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore Page 49 of 115 10.6 We place reliance on the decision rendered by Hon'ble Supreme Courtin the case of Pullangode Rubber Product Co. Vs. State of Kerala (91 ITR 18) (SC), wherein it was held that the admission may be an important piece

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

132 of the Act was conducted in the case of assessee M/s. Barbeque-Nation Hospitality Ltd., (BNHL) at Survey No.62, Site No.13 6th Cross, NS Palya, BTM Layout, Bangalore – 560 076, on 10.01.2018 in connection with the search proceeding in the group case of M/s. MRG Hospitality Group. Assessee is in the business of operating casual dining restaurant chain

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

132 of the Act was conducted in the case of assessee M/s. Barbeque-Nation Hospitality Ltd., (BNHL) at Survey No.62, Site No.13 6th Cross, NS Palya, BTM Layout, Bangalore – 560 076, on 10.01.2018 in connection with the search proceeding in the group case of M/s. MRG Hospitality Group. Assessee is in the business of operating casual dining restaurant chain