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 Act by A.O. 5.1 He submitted that incidentally in one of the group companies M/s.Jaico Realtors (P) Ltd there was an investment of 'Rs.4,06,98,779/- ($ 9,99,970) for the A.Y.2008-09 and similar issue was considered by Tribunal in ITA No.1444/Bang/2018 dated 8.5.2019 and deleted addition made by AO u/s 68

GANGANAGHATTA SHANKARAPPA RANGANATHA ,BENGALURU vs. INCOME TAX OFFICER, WARD-5(3)(2), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubeyganganaghatta Shankarappa Ito, Ward - 5(3)(2) Ranganatha Bmtc Building, 80 Ft Road No. 120 Hoodi Apartments 6Th Block, Koramangala Vs. Bengaluru 560095 Cunningham Road Bengaluru 560052 Pan – Aiepg1800C (Appellant) (Respondent) Assessee By: Ms. Lakshmi, Advocate Revenue By: Shri Ganesh R. Gale, Standing Counsel Date Of Hearing: 12.06.2024 Date Of Pronouncement: 20.08.2024 O R D E R Per: Keshavdubey, J.M.

section 68 of the Act and accordingly assessed on a total income of Rs.7,33,880/-. Aggrieved by the assessment completed u/s. 143(3) of the Act dated 30.12.2016 the assessee preferred an appeal before the CIT(A). 4. The ld. CIT(A) observed that as per the provisions of s. 282

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

282. . ITA No.2081 /Bang/2025 Page 7 of 32 12.4 Going through the above stated judgment of Hon’ble Supreme Court, we note the assessee i.e. Totgars, Co-Operative Sales Society Ltd at the relevant time (A.Y. 1991-92 to 1999-2000) was engaged in two activities viz marketing of agricultural produce of its members and providing credit facilities to them

SRI SRI VAISHNAVI PATTINA SOUHARDHA SAHAKARI SANGHA NIYAMITHA,GANGAVATHI vs. ITO WARD 1, KOPPAL, KOPPAL

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

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2017-18 Sri Sri Vaishnavi Pattina Souharda Sahakari Vs. Ito, Sangha Niyamita, Ward – 1, Shop No.9 T.A.P.C.M.S Complex, Koppal. C.B.S Gunj Gangavathi Dt- Koppal 583227,Karnataka. Pan : Aalas 9104 P Appellant Respondent Assessee By : Shri. Deepak, Ca Revenue By : Shri. Ashwin D Gowda, Addl. Cit(Dr)(Itat), Bangalore. Date Of Hearing : 28.07.2025 Date Of Pronouncement : 31.07.2025

282/-. The same was processed under section 143(1) of the Act. Subsequently, the case Page 2 of 6 was selected for scrutiny and statutory notices were issued to the assessee. The assessee filed detailed written submissions / documents and registration certificate. From the registration certificate submitted by the assessee it was noticed that the assessee

BAJAJ CLOTHINGS PRIVATE LIMITED,BANGALORE vs. THE DCIT-1(1)(1), BANGALORE, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 68 of the Act. 10. The ld. D.R. relied on the order of lower authorities. 11. We have heard the rival submissions and perused the materials available on record. In the present case, the main issue is with regard to addition made u/s 68 of the Act with regard to unsecured loan standing in the name

BAJAJ CLOTHINGS PRIVATE LIMITED,BANGALORE vs. THE DCIT-1(1)(1), BANGALORE, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 68 of the Act. 10. The ld. D.R. relied on the order of lower authorities. 11. We have heard the rival submissions and perused the materials available on record. In the present case, the main issue is with regard to addition made u/s 68 of the Act with regard to unsecured loan standing in the name

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

In the result, appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Keshav Dubey

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

M/S. EMIRATES HINDUSTAN BUILDERS AND DEVELOPERS,KERALA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Keshav Dubey

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

M/S. GLOBAL TECH PARK PVT. LTD.,,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(1), BENGALURU

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

68: Where any sum is found credited in the books of an assessee maintained for any previous years and the assessee offers no explanations about nature and source thereof or the explanation offered by him is not, in the opinion of the assessing officer, satisfactory, the sum so credited may be charged to income tax as the income

M/S. GLOBAL TECH PARK PVT LTD.,,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(1), BENGALURU

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

68: Where any sum is found credited in the books of an assessee maintained for any previous years and the assessee offers no explanations about nature and source thereof or the explanation offered by him is not, in the opinion of the assessing officer, satisfactory, the sum so credited may be charged to income tax as the income

M/S. GLOBAL TECH PARK PVT LTD.,,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(1), BENGALURU

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

68: Where any sum is found credited in the books of an assessee maintained for any previous years and the assessee offers no explanations about nature and source thereof or the explanation offered by him is not, in the opinion of the assessing officer, satisfactory, the sum so credited may be charged to income tax as the income

M/S. GLOBAL TECH PARK PVT. LTD.,,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(1), BENGALURU

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

68: Where any sum is found credited in the books of an assessee maintained for any previous years and the assessee offers no explanations about nature and source thereof or the explanation offered by him is not, in the opinion of the assessing officer, satisfactory, the sum so credited may be charged to income tax as the income

M/S. GLOBAL TECH PARK PVT LTD.,,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(1), BENGALURU

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly\nallowed

68: Where any sum is found credited in\nthe books of an assessee maintained for any\nprevious years and the assessee offers no\nexplanations about nature and source thereof or\nthe explanation offered by him is not, in the\nopinion of the assessing officer, satisfactory, the\nsum so credited may be charged to income tax as\nthe income

M/S. GLOBAL TECH PARK PVT LTD.,,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(1), BENGALURU

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly\nallowed

68: Where any sum is found credited in\nthe books of an assessee maintained for any\nprevious years and the assessee offers no\nexplanations about nature and source thereof or\nthe explanation offered by him is not, in the\nopinion of the assessing officer, satisfactory, the\nsum so credited may be charged to income tax as\nthe income

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1 1, BENGALURU, BENGALURU vs. GLOBAL TECH PARK PRIVATE LIMITED, BANGALORE

In the result appeal no 2319/ Bang/2024 filed by the assessee is partly\nallowed

68: Where any sum is found credited in\nthe books of an assessee maintained for any\nprevious years and the assessee offers no\nexplanations about nature and source thereof or\nthe explanation offered by him is not, in the\nopinion of the assessing officer, satisfactory, the\nsum so credited may be charged to income tax as\nthe income

CENTURY REAL ESTATE HOLDINGS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

68.- Whether when assessee had future obligation of maintenance services-and necessary expenditure required therefor, and assessee's ITA No.580 & 740/Bang/2022 M/s. Century Real Estate Holdings Pvt. Ltd., Bangalore Page 19 of 29 calculation was made. on scientific basis, assessee was justified in treating 39 percent of total price as an amount for fulfillment of warranty conditions – Held, yes (para

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BANGALORE vs. CENTURY REAL ESTATE HOLDINGS PRIVATE LIMITED, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

68.- Whether when assessee had future obligation of maintenance services-and necessary expenditure required therefor, and assessee's ITA No.580 & 740/Bang/2022 M/s. Century Real Estate Holdings Pvt. Ltd., Bangalore Page 19 of 29 calculation was made. on scientific basis, assessee was justified in treating 39 percent of total price as an amount for fulfillment of warranty conditions – Held, yes (para

M/S CLOSURE SYSTEMS INTERNATIONAL INDIA PVT LTD ,BANGALORE vs. INCOME TAX OFFICER WARD-2(1)(1), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.680/Bang/2017 Assessment Year : 2012-13 M/S. Pact Closure Systems (India) Private Limited, Vs. The Income Tax Officer, (Formerly Known As Closure Systems International Ward – 2(1)(1), India Private Limited) Bengaluru. Survey No.35 & 36, Soukhya Road, Kacherkanahalli, Hoskote Taluk, Bengaluru – 560 067. Pan : Aadcc 7884 N Appellant Respondent Appellant By : Shri. K. R. Vasudevan, Advocate Respondent By : Shri. Muzaffar Hussain, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 09.09.2021 Date Of Pronouncement : 14.09.2021 O R D E R Per N. V. Vasudevan: This Is An Appeal By The Assessee Against The Final Order Of Assessment Dated 18.01.2017 Passed By The Ito, Ward – 2(1)(1), Bengaluru, Under Section 143(3) R.W.S. 144C Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’), In Relation To Assessment Year 2012-13. 2. Grounds 1 To 6 Raised By The Assessee Are General In Nature & Does Not Call For Any Specific Adjudication. Grounds 7 To 20 Raised By The Assessee Is In Relation To Determination Of Arm’S Length Price (Alp) In Respect Of International Transaction Entered Into By The Assessee With Its Associated Enterprise (Ae). The Assessee Is A Company Engaged In The Business Of It(Tp)A No.209/Bang/2015 Page 2 Of 12

section 92CA(3) of the Act, and also while submitting the remand report, in which he continued to protect the adjustment of Rs.6,68,29,282