CHIGURUVADA DILEEP KUMAR ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(3)(1) , BANGALORE

In the result, the appeal filed by assessee in ITA No

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahu

270A.” Also as per CBDT Notification No 3/2022, dated 16.07.22, filing of Form 68 is mandatorily to be done electronically through e-filing portal. In the given case assessee has sent an email seeking immunity and no form 68 application was efiled. Moreover as discussed in para above, as the provisions of immunity itself not applicable in the assessee

VISHWANATHAREDDY CHENNAREDDY,BANGALORE vs. INCOME-TAX OFFICER, WARD-2(2)(7), BENGALURU

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

Bench: SHRI CHANDRA POOJARI (Accountant Member), SMT. BEENA PILLAI (Judicial Member)

8. Facts of the issue are that the assessee has shown unsecured loan of Rs.3,96,81,929/- as on 31/03/2017. The assessee was requested to provide the details of persons from whom he has received unsecured loan along with their ITR V, computation of income, balance sheet etc., the assessee has not submitted any details which can prove

AUGUST JEWELLERY PVT LTD,BENGALURU vs. D.C.I.T., CIRCLE 1(1)(1), BENGALURU, BENGALURU

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

270A ITBA/NFAC/S/250/2025-26/1076855927(1) 10.06.2025 NFAC/2021- 22/10406268 under section 271AAC1 ITBA/NFAC/S/250/2025-26/1077236277(1) 19/06/2025 2. The grounds raised by the assessee are as under: ITA No.1419/Bang/2025 1) That the learned CIT(A) erred in law and on facts in dismissing the appeal without granting adequate opportunity to the appellant, despite repeated requests for reasonable adjournment, thereby violating the principles of natural

JOYDEEP MUKHERJEE,PRESENTLY RESIDING AT USA vs. DCIT, INTL TAXATION CIRCLE 1(2), BANGALORE, BMTC BUILDING, KORAMANGALA

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2018-19 Joydeep Mukherjee, Vs. The Deputy Commissioner A 202, Prestige St. Johns Woods Of Income Tax Apt., 80, St. Johns Cross Road, International Taxation, Circle 1(2), Bengaluru South 560 029. Bangalore. Pan: Aawpm 7656E

270A of the Act were initiated. 6. In response to the above penalty show cause notice the assessee submitted that assessee has filed an application in form No. 68 under section 270AA(2) on 8

MR. NATESHAN SAMPATH,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

68,361/- from sale of immovable property. Thereafter, the assessment u/s 147 r.w.s. 144B of the Act was completed on 28.2.2023 on a total income of Rs.20,92,490/-. The AO on or before the completion of assessment proceedings u/s 147 r.w.s. 144B of the Act also initiated the penalty proceedings with the following observations. “Since the assessee has claimed

M/S. WINDSOR GARDENS PRIVATE LIMITED,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 7(1)(2), BANGALORE

In the result, appeal of the assessee is allowed

Bench: George George K. & Shri Laxmi Prasad Sahuassessment Year : 2017-18

68 within one month from the end of the month in which the assessment order had been received, it can not claim immunity under section 270AA of the Act. Hence, penalty u/s 270A of the Act is imposable for under-reporting of income, which is in accordance with the provisions of the section. The penalty imposed

AKSHATA VISHWAS TUDAVEKAR ,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(5), BANGALORE

In the result, all the appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Ms. Madhumita Royassessment Year: 2017-18

8 of 11 basic training. Therefore, there is absolutely nothing wrong in approaching a ITP for the preparation of the income tax returns for both the years which would definitely fall within the scope of Section 270A(6)(a) of the Act. Hence, he pleaded for exercising the power vested in terms of Section 270A

AUGUST JEWELLERY PVT LTD,BENGALURU vs. D.C.I.T., CIRCLE 1(1)(1), BANGALORE, BANGALORE

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

270A NFAC/2021- 22/10406268 under section 271AAC1 ITBA/NFAC/S/250/2025-26/1076855927(1) 10.06.2025 ITBA/NFAC/S/250/2025-26/1077155818(1) 18/06/2025 ITBA/NFAC/S/250/2025-26/1077236277(1) 19/06/2025 2. The grounds raised by the assessee are as under: ITA No.1419/Bang/2025 1) That the learned CIT(A) erred in law and on facts in dismissing the appeal without granting adequate opportunity to the appellant, despite repeated requests for reasonable adjournment, thereby violating

AUGUST JEWELLERY PRIVATE LIMITED,BENGALURU vs. D.C.I.T., CIRCLE 1(1)(1), BENGALURU, BENGALURU

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

270A ITBA/NFAC/S/250/2025-26/1077236277(1) 19/06/2025 NFAC/2021- 22/10406268 under section 271AAC1 ITBA/NFAC/S/250/2025-26/1077236277(1) 19/06/2025 2. The grounds raised by the assessee are as under: ITA No.1419/Bang/2025 1) That the learned CIT(A) erred in law and on facts in dismissing the appeal without granting adequate opportunity to the appellant, despite repeated requests for reasonable adjournment, thereby violating the principles of natural

BANGALORE HOUSING DEV AND INV, ,BANGALORE vs. DCIT, CIRCLE-1(2)(1), BANGALORE

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

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

8. The Ld.AR further submitted that the mere showing the income under the head income from house property and subsequently, claimed the same as profits and gains of business or profession, that too based on the Hon’ble Super Court order could not be treated as an underreporting of income and hence the penalty u/s. 270A need not be imposed

MEDA LAKSHMINARAYANA SETTY NAVEEN KUMAR,MYSORE vs. INCOME TAX OFFICER, CIRCLE-1(1) & TPS, MYSORE

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

Bench: Shri Prashant Maharishi & Shri Soundararajan Kassessment Year :2018-19 Mr. Meda Lakshminarayana Setty Vs. Ito, Naveen Kumar, Circle – 1(1) & Tps, Fat No.305, Bougainvilla, Sankalp Mysore. Central Park, Yadavagiri, Mysore – 570 009. Pan : Ablpn 5943 K Appellant Respondent

68 online, but due to technical reasons, the same is not filed. Accordingly, immunity was requested by letter dated 06.07.2024. 4. The learned AO held that as Form No.68 is not filed, levy of penalty is mandatory as assessee has not furnished any reply. Accordingly, penalty of Rs.2,17,158/- under section 270A of the Act was levied. Page

INCOME TAX OFFICER, WARD-1 & TPS, BAGALKOT, AAYAKAR BHAVAN vs. SHRI SHIVASHAKTI SOUHARDA PATTINA SAHAKARI SANGHA NIYAMIT, .

In the result, appeal is partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

8. The Learned CIT(A) and AO has erred in levying intere'st under section 234Aand 234B of the Act. 9. The Learned AO has erred in initiating penalty proceedings by issuing of notice under section 270A of the Act. 10. The Learned AO has erred in initiating penalty proceedings by issuing of notice under section 271AAC

SHRI SHIVASHAKTI SOUHARDA PATTINA SAHAKARI SANGHA NIYAMIT,MELLIGERI TOWERS, BAGALKOT vs. INCOME TAX OFFICER WARD 1 BAGALKOT, AAYAKAR BHAVAN

In the result, appeal is partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

8. The Learned CIT(A) and AO has erred in levying intere'st under section 234Aand 234B of the Act. 9. The Learned AO has erred in initiating penalty proceedings by issuing of notice under section 270A of the Act. 10. The Learned AO has erred in initiating penalty proceedings by issuing of notice under section 271AAC

R ARUNACHALAM P C P P LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(2), BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Keshav Dubeyassessment Year : 2017-18

270A and section 271AAC(1) of the Act even though there was there was no under-reporting of income alleged by the learned Assessing Officer and the income alleged u/s 68 is not sustainable. The appellant craves leave to add, alter, amend or vary any of the ground either at or before the hearing of the appeal

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

270A of the Income Tax Act. As this matter is premature at this stage, it is dismissed accordingly as infructuous. 5. The interconnected issue raised by the assessee in Grounds Nos. 4 to 13 of its appeal pertains to the action of the learned DRP/TPO/AO in benchmarking the payment of royalty at NIL. 6. The facts in brief are that

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act for under-reporting of income. 3. Ground No. 3: Incorrect levy of interest under section 234A, 234B and 234C of the Act The learned AO, erred in law and facts, on levying consequential interest under section 234A, 2348 and 234C of the Act. IT(TP)A No.2525/Bang/2024 Assessment Year 2021-2022 Each

NTT DATA INFORMATION PROCESSING SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal of the assessee is partly allowed

Bench: Shri N.V.Vasudevan & Shri Laxmi Prasad Sahu

270A of the Act. The Appellant submits that each of above grounds is independent and without prejudice to one another. The Appellant craves leave to add, alter, amend, vary, omit or substitute any of the aforesaid grounds of appeal at any time before or at the time of hearing of the appeal, so as to enable the Hon'ble Tribunal

SHRI. MARATE VENKATESHKUMAR ,BANGALORE vs. INCOME TAX OFFICER, WARD-1(6), HUBLI

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

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2017-18

section 68 on the sole reason that there is a time gap between the date of withdrawals from the bank account and re-deposit the same in the bank account. Unless the Assessing officer demonstrates that the amount in question has been used by the assessee for any other purpose. In my view, addition is made on inferences