SMT. MALAPUR MOUNIKA,CHITRADURGA vs. INCOME-TAX OFFICER, WARD-1, CHITRADURGA

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

Bench: Shri George George Kassessment Year : 2017-18 Smt. Malapur Mounika, Vs. Ito, Prop : M/S. Kaligal Poultry Services, Ward – 1, M H Road, Chitradurga. Chitradurga – 577 501. Pan : Bhypm 5247 F Appellant Respondent Assessee By : Ms. Sunaina Bhatia, Ca Revenue By : Shri. Ganesh R Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 27.10.2023 Date Of Pronouncement : 30.10.2023

transferring or receiving SBNs is only after the ‘appointed day’ which is 31.12.2016. In view of the above, there is no violation by the assessee of any law in accepting SBNs for the purpose of cash sales and considering it to be a due discharge of debt. Furthermore, even the CBDT had issued various Standard Operating Procedures (SOPs) instructing

M/S. MAHAVEERA MINORITY CREDIT CO-OPERATIVE SOCIETY LIMITED,VIJAYANAGAR vs. INCOME TAX OFFICER, WARD-1 & TPS , HOSPET

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

price in SBNs as a part of such activity,\nif accepted, would defeat the provisions of such section of RBI, 1934 and it\nleads to public policy. Therefore, the activity of society with regard to this,\nis ab-initio void as per the relevant provisions. Hence the society for having\ndeposited such SBNs in banks during such period, represents

KAMAL KOTHARI ,CHANNAPATNA vs. INCOME TAX OFFICER, WARD-1, , RAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Shri George George Kassessment Year : 2017-18 Shri. Kamal Kothari, Vs. Ito, Prop: M/S. B. L. Bankers, Ward – 1, M. G. Road, Ramnagar. Channapatna – 562 160. Pan : Bcgpk 1898 B Appellant Respondent Assessee By : Smt. Suman Lunkar, Ca Revenue By : Shri. Ganesh R Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 21.11.2023 Date Of Pronouncement : 23.11.2023

transfer, as he had done by depositing cash of Rs.20,000/-. This again goes on to prove that the assessee had no such cash on hand. f) Lastly, If the assessee had cash on hand on the day of demonetization day le.. 8.11.2016 and from 9.11.2016. one would have exchanged the old notes only through bank deposits

SHREE HANUMAN CREDIT SOUHARD SAHAKARI LIMITED,CHIKODI vs. PR. COMMISSIONER OF INCOME-TAX, HUBLI

In the result, the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2017-18

69A read with section 115BBE. 3. When the case was selected for scrutiny specifically for examining high value receipt of cash shown from third parties in response data and cash deposited during the demonetization period, apart from other issues, it was necessary for the Assessing Officer to examine the source of cash and SBNs deposited and carry out necessary investigation

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

prices remain static. It was not for the\nTribunal to have guesswork as to for what purposes the appellant\nwanted to crossexamine those dealers and what extraction the\nappellant wanted from them.\" [Emphasis supplied]\n32. Additionally, the Supreme Court in the case of State of Kerala v. K.T.\nShaduli Grocery Dealer², held that tax authorities being quasi- judicial\nauthorities

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:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore

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:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore

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:

section 153A, then such seized material is to be handed over to the assessing officer of the other person to initiate assessment or Page 39 of 121 ITA Nos.1061 to 1066/Bang/2023 Sri Prakash Bhajandas Talreja, Bangalore reassessment proceedings in case of such other person. The expression used is "belongs to or.......pertains to or.........relates to the other person." Therefore