SMT SUSHAMA RAJESH RAO ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-5(2)(1) , BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan Kassessment Year: 2012-13 Sushama Rajesh Rao, Vs. The Deputy Commissioner No.159, Priyadarshani, R. T. Nagar, Of Income Tax, Mla Layout, Circle – 6(2)(1), Bangalore – 560 032. Bangalore. Pan : Acypr 5251 J Appellant Respondent Appellant By : Shri. V. Chandrashekar, Advocate Respondent By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 23.07.2025 Date Of Pronouncement : 18.08.2025

2. Briefly stated, the fact of the case shows that assessee is an individual who filed her return of income on 30.08.2012 declaring total income of Rs.33,71,480/- comprising of income from capital gains, income from house property and income from other sources. This return was revised on 05.08.2013 at total income of Rs.39,70,830/-. 3. Subsequently

TYCO FIRE AND SECURITY INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariit(Tp)A No.270/Bang/2021 Assessment Year : 2016-17 Acit, M/S. Tyco Fire & Security India Private Limited, Vs. D-601, Rmz Centennial, Circle - 7(1)(1), Kundalahalli Main Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 0087 C Appellant Respondent Assessee By : Shri. Rajan Vora, Ca Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 27/11.09.2022 Date Of Pronouncement : 28.11.2022 O R D E R Per N V Vasudevan

50C Provision for full value of consideration in certain cases (1) Where the consideration received or accruing as a result of the transfer by an assessee of a capital asset, being land or building or both, is less than the value adopted or assessed or assessable by any authority of a State Government (hereafter in this section referred

APURVA SARIN,DELHI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-3(3)(1), BANGALORE

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

68,850 as per the valuation report dated 27.07.2020 issued by the\nDistrict valuation officer in respect of the Property No.D-1032 New Friends\nColony, New Delhi.\n6. That both the learned CIT(A) and Assessing Officer failed to appreciate the real\nstate of affairs of the real estate market at the time of transfer, being\ndemonetization and the defaults committed

SMT. HIREHAL RAGHAVENDRA SOUDAMANI,BANGALORE vs. THE INCOME TAX OFFICER, WARD - 6(3)(2), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariassessment Year : 2011-12 Smt. Hirehal Raghavendra Soudamini, Vs. The Income Tax Officer, No.66, ‘Shreema’ 1St Main, 5Th Cross, Ward –6[3][2], Rmv 2Nd Stage, 1St Block Aswath Nagar, Bangalore. Bangalore – 560 025. Pan : Apkps 4537 B Assessee By : Shri. V. Srinivasan, Advocate Revenue By : Shri. Priyadarshi Mishra, Jcit(Dr)(Itat), Bangalore Date Of Hearing : 15.12.2020 Date Of Pronouncement : 17.12.2020 O R D E R

section 50C(2) of the Act. The AO made reference to the DVO but since the report had not been received by that time, the assessment was completed. The AO could not take cognizance of the same. 5. In the appellate proceedings before the First Appellate Authority i.e., CIT(A), the report of the DVO was available

SRI. D. K SHIVAKUMAR ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

Section 69A of the Act.The addition is made out on basis of loose sheets of documents, which does not come under the ambit of ‘books of entry’ or as ‘evidence’ under the Indian Evidence Act. Reliance is placed on following decisions: 57  CBI Vs. V.C. Shukla (1998) 3 SCC 410  Common Cause and others Vs. Union of India

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

2. Brown folder marked as Annexure : A/CCDGLT8/1 Annexure A/CCDGLT8/1 Page No. 108, 109, 129, containing loose sheets serially 131 numbered from 1 to 134 found and seized from the office of M/s. Coffee Day Global Ltd. At No.23/2, Coffee Day Square, Vittal Mallya Road, Bangalore 6.2 Considering the above documents for recording satisfaction u/s 153C of the Act, he recorded

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

2. Brown folder marked as Annexure : A/CCDGLT8/1 Annexure A/CCDGLT8/1 Page No. 108, 109, 129, containing loose sheets serially 131 numbered from 1 to 134 found and seized from the office of M/s. Coffee Day Global Ltd. At No.23/2, Coffee Day Square, Vittal Mallya Road, Bangalore 6.2 Considering the above documents for recording satisfaction u/s 153C of the Act, he recorded

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

2. Brown folder marked as Annexure : A/CCDGLT8/1 Annexure A/CCDGLT8/1 Page No. 108, 109, 129, containing loose sheets serially 131 numbered from 1 to 134 found and seized from the office of M/s. Coffee Day Global Ltd. At No.23/2, Coffee Day Square, Vittal Mallya Road, Bangalore 6.2 Considering the above documents for recording satisfaction u/s 153C of the Act, he recorded

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are partly allowed and ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillaiita Nos.1061 To 1066/Bang/2023 Assessment Years: 2014-15, 2015-16, 2016-17, 2016-17, 2017-18 & 2018-19 Sri Prakash Bhajandas Talreja No.402, 4Th Floor, Embassy Centre No.11, Crescent Road Dcit Bengaluru 560 001 Vs. Central Circle-1(3) Karnataka Bengaluru Pan No : Abkpt1011B Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Respondent By : Shri G. Manoj Kumar, D.R. Date Of Hearing : 01.02.2024 Date Of Pronouncement : 22.03.2024 O R D E R Per Chandra Poojari: The Appeals In Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 Are Emanated From The Common Order Of Cit(A) Central Circle, Bengaluru For The Assessment Years 2014-15 To 2018-19 Dated 16.11.2023. Ita No.1064/Bang/2023 Is Emanated From The Order Of Cit(A) Dated 11.8.2023 For The Assessment Year 2016-17 With Regard To Levy Of Penalty U/S 271Aab Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issue In All These Appeals Is Common In Nature, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience. 2. First, We Will Take Up Ita Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 For Adjudication. The Common Ground In All These Appeals Except Change In Figures, Which Reads As Under:

2. Brown folder marked as Annexure : A/CCDGLT8/1 Annexure A/CCDGLT8/1 Page No. 108, 109, 129, containing loose sheets serially 131 numbered from 1 to 134 found and seized from the office of M/s. Coffee Day Global Ltd. At No.23/2, Coffee Day Square, Vittal Mallya Road, Bangalore 6.2 Considering the above documents for recording satisfaction u/s 153C of the Act, he recorded

VENUGOPAL NAIDU PUSHPARAJ ,BANGALORE vs. INCOME TAX OFFICER WARD-1(3), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2008-09

68,85,955/- 4. Capital Gains on sale of 7 Flats obtained from M/s. S.V Developers - Rs. 58,29,375/- The Assessee and his Co-owner Sri. N. Prakash had owned a land bearing Survey No. 115/2, B Narayanapura Village, K.R Puram, Hobli, Bangalore East Taluk measuring 10890 sq.ft. The Assessee and his co-owner have entered into

SRI PRAKASH BHAJANDAS TALREJA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU

In the result, ITA Nos.1061, 1062, 1063, 1065 & 1066/Bang/2023 are\npartly allowed and ITA No

2\nThe person referred to in S.No.4 (Shri. Prakash\nTalreja) who is the Chairman of Coffee Day Group.\n7.\nSatisfaction of the Assessing Officer of the\nperson referred to in section 153A and I am satisfied\nthat the documents/information contained\nin this section 153A and I am satisfied\nthat the documents/information contained\npertains or/and relates

DR.SYED RAHMATULLAH AZIZULLAH ,GULBARGA vs. THE INCOME TAX OFFICER WARD-3 , KALABURAGI

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

Bench: Shri Arun Kumar Garodia

50C(1) withoutcompiling with all the legal formalities is also bad in law and therefore the adoption of suchdeemed consideration is to be deleted. 6. In any case and without prejudice the assessing officer has erred in holding and adoptingthe cost as NIL and the CIT(A) have erred in confirming the same. Even as per law, thecost

DR.SYED RAHMATULLAH AZIZULLAH ,GULBARGA vs. THE INCOME TAX OFFICER WARD-3 , KALABURAGI

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

Bench: Shri Arun Kumar Garodia

50C(1) withoutcompiling with all the legal formalities is also bad in law and therefore the adoption of suchdeemed consideration is to be deleted. 6. In any case and without prejudice the assessing officer has erred in holding and adoptingthe cost as NIL and the CIT(A) have erred in confirming the same. Even as per law, thecost