DCIT, BANGALORE vs. SHRI. SUMIR J HINDUJA, BANGALORE

In the result, appeals filed by the revenue and COs filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2006-07 Shri Jagadish N. Hinduja Deputy Commissioner Of Income- No.7 & 12, Industrial Suburb Tax Tumkur Road Vs. Circle 11(3) Yeshwanthpur Bangalore Bangalore 560 022 Pan No.Aacph7291Q Appellant Respondent Assessment Year: 2006-07 Shri Sumir J. Hinduja Deputy Commissioner Of Income- No.7 & 12, Industrial Suburb Tax Tumkur Road Vs. Circle 11(3) Yeshwanthpur Bangalore Bangalore 560 022 Pan No.Aaeph5197H Appellant Respondent C.O. No.48/Bang/2013 (Arising Out Of Ita No.1373/Bang/2012) Assessment Year: 2006-07 Shri Jagadish N. Hinduja Vs. Dcit, Circl-11(3),Bangalore Appellant Respondent C.O. No.49/Bang/2013 (Arising Out Of Ita No.1374/Bang/2012) Assessment Year: 2006-07 Shri Sumir J. Hinduja Vs. Dcit, Circl-11(3),Bangalore Appellant Respondent Appellant By : Shri Susan Dolores George, D.R. Respondent By : Shri Ashok A Kulkarni, A.R.

2) Reshma J. Hinduja and (3) Sumir Hinduja, shareholders of M/s. GIPL and M/s. GIPL with the investors, M/s. GIPL had to essentially concentrate on export business and was required to do de-linked duties from any domestic operations and any existing/possible obligations arising from its business transactions with its group companies in pursuance of clause 3.2 of the SSSA

BHUWALKA SALES CORPORATION,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2009-10 is treated as allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri Jason P. Boazi.T. A. No.1436/Bang/2013 (Assessment Year : 2009-10) M/S. Bhuwalka Sales Corporation, No.5, Walker Lane, Bhuwalka Landmark, Langford Road, Richmond Town, Bangalore-560 025 …. Appellant. Pan Aaifb 0063G Vs. Asst. Commissioner Of Income Tax, Circle 1(1), Bangalore. ….. Respondent. Appellant By : Shri K. Seshadri, C.A. Respondent By : Shri P. Dhivahar, Jcit (D.R). Date Of Hearing : 2.2.2015. Date Of Pronouncement : 1.4.2015. O R D E R Per Shri Jason P. Boaz, A.M. : This Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-I, Bangalore Dt.12.8.2013 For Assessment Year 2009-10. 2. The Facts Of The Case, Briefly, Are As Under :- 2.1 The Assessee, In The Business Of Trading In Rolled Products, Filed The Return Of Income For Assessment Year 2009-10 On 26.9.2009 Declaring Income Of Rs.49,25,026. The Return Was Processed Under Section 143(1) Of The Income Tax Act, 1961 (In Short 'The Act') & The Case Was Taken Up For Scrutiny. The Assessment Was Completed Under Section 143(3) Of The Act Vide

22)(e) with respect to the same time, amounted to discovery of new source not permissible under Section 251(1)(a) read with several Supreme Court and High Court judgments including that of the Hon'ble Karnataka High Court. 2. SECTION 68

M/S. DEVANAM CONSTRUCTIONS PRIVATE LIMITED,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 2(1)(2), BANGALORE

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

section 2(22)(e) of the I.T.Act does not specify that payment should be received in the same financial year relevant to the assessment year under consideration. The CIT(A), however, did not adjudicate the assessee’s contention that the A.O. has erred in going beyond the scope of limited scrutiny assessment to make addition u/s 2(22)(e

M/S PRESTIGE ESTATES PROJECTS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-18(1), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri N.V.Vasudevan, Vp & Shri Chandra Poojari, Am

section 53A of the Transfer of Property Act. This agreement cannot, therefore, be said to be in the nature of a contract referred to in section 53A of the Transfer of Property Act. It cannot, therefore, be said that the provisions of section 2(47)(v) will apply in the situation before us. Considering the facts

M/S. EMBASSY PROPERTY DEVELOPMENTS PRIVATE LIMITED,BANGALORE vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX, (CENTRAL), BANGALORE

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

2 for the purposes of section 263 of the Act. The aim and object of introduction of aforesaid Explanation by Finance Act, 2015 was explained in CBDT Circular No. 19/2015 [F.NO.142I14/2015T PL], Dated 27-11-2015 which is reproduced hereunder: "53. Revision of order that is erroneous in so far as it is prejudicial to the interests

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

22 of 64 Commissioner or Chief Commissioner or Pr. Commissioner or Commissioner, as stipulated therein, to transfer any case from one or more Assessing Officer subordinate to him. In other words, under Section 127(1) the Pr. Director General or Director General or Pr. Chief Commissioner or Chief Commissioner or Pr. Commissioner or Commissioner, as stipulated therein, can transfer

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

22 of 64 Commissioner or Chief Commissioner or Pr. Commissioner or Commissioner, as stipulated therein, to transfer any case from one or more Assessing Officer subordinate to him. In other words, under Section 127(1) the Pr. Director General or Director General or Pr. Chief Commissioner or Chief Commissioner or Pr. Commissioner or Commissioner, as stipulated therein, can transfer

SHRI. SHANTHISAGAR CO OP CREDIT SOCIETY LIMITED,HUBLI vs. INCOME TAX OFFICER, WARD-2(1), HUBLI

In the result, the appeal of the assessee is hereby partly allowed for statistical purposes

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

E R PER WASEEM AHMED, ACCOUNTANT MEMBER: The present appeal has been instituted by the assessee against the order of the NFAC, Delhi passed u/s 250 of the Act dated 21.08.2025 for the assessment year 2017-18. 2. The assessee has raised extensive grounds of appeal numbered as Ground No. 1 to 17 running into multiple pages. Hence

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

E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: These appeals by the revenue are directed against orders of CIT(A)-11, Bangalore dated 28.2.2018 for the assessment years 2009-10, 2012-13 & 2008-09 in respect of above two assessees and the Cross objections filed by the assessees against the appeals of the revenue. The grounds raised by the revenue

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1(4), BENGALURU vs. M/S SNOWSHINE REALTORS 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

E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: These appeals by the revenue are directed against orders of CIT(A)-11, Bangalore dated 28.2.2018 for the assessment years 2009-10, 2012-13 & 2008-09 in respect of above two assessees and the Cross objections filed by the assessees against the appeals of the revenue. The grounds raised by the revenue

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

E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: These appeals by the revenue are directed against orders of CIT(A)-11, Bangalore dated 28.2.2018 for the assessment years 2009-10, 2012-13 & 2008-09 in respect of above two assessees and the Cross objections filed by the assessees against the appeals of the revenue. The grounds raised by the revenue

M/S. DAKSHINA KANNADA NIRMITHI KENDRA,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE -1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

E) [2013] 358 ITR 78 (Delhi); 3.20 Therefore, it is submitted the in the aforesaid background of the Assessee, the Assessee’s case does not fall within the mischief of 1st proviso to section 2 (15) of the IT Act. Hence, the exemption under section 11 of the IT Act ought not to have been denied

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

E) [2013] 358 ITR 78 (Delhi); 3.20 Therefore, it is submitted the in the aforesaid background of the Assessee, the Assessee’s case does not fall within the mischief of 1st proviso to section 2 (15) of the IT Act. Hence, the exemption under section 11 of the IT Act ought not to have been denied

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

E) [2013] 358 ITR 78 (Delhi); 3.20 Therefore, it is submitted the in the aforesaid background of the Assessee, the Assessee’s case does not fall within the mischief of 1st proviso to section 2 (15) of the IT Act. Hence, the exemption under section 11 of the IT Act ought not to have been denied

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1,, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

E) [2013] 358 ITR 78 (Delhi); 3.20 Therefore, it is submitted the in the aforesaid background of the Assessee, the Assessee’s case does not fall within the mischief of 1st proviso to section 2 (15) of the IT Act. Hence, the exemption under section 11 of the IT Act ought not to have been denied

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

E) [2013] 358 ITR 78 (Delhi); 3.20 Therefore, it is submitted the in the aforesaid background of the Assessee, the Assessee’s case does not fall within the mischief of 1st proviso to section 2 (15) of the IT Act. Hence, the exemption under section 11 of the IT Act ought not to have been denied

M/S. UDUPI NIRMITHI KEDRA,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE - 1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

E) [2013] 358 ITR 78 (Delhi); 3.20 Therefore, it is submitted the in the aforesaid background of the Assessee, the Assessee’s case does not fall within the mischief of 1st proviso to section 2 (15) of the IT Act. Hence, the exemption under section 11 of the IT Act ought not to have been denied

M/S. UDUPI NIRMITHI KENDRA,UDUPI vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS) CIRCLE-1, MANGALORE

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

E) [2013] 358 ITR 78 (Delhi); 3.20 Therefore, it is submitted the in the aforesaid background of the Assessee, the Assessee’s case does not fall within the mischief of 1st proviso to section 2 (15) of the IT Act. Hence, the exemption under section 11 of the IT Act ought not to have been denied

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)

e-assessment portal on 15.07.2019 by ITO- Ward- International Taxation-1(1), Bangalore calling for details. 7.2. The Ld.AR submitted that ITO-Ward-International Taxation never issued a notice u/s. 143(2) of the Act to the assessee, and therefore did not assume jurisdiction to pass the assessment 13 IT(IT)A Nos. 120 & 121/Bang/2022 Bangalore Narayan Das order. Referring