M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojariassessment Year: 2018-19

condone the above delay and admit the appeal for adjudication. 4. The first ground for our consideration is with regard to the disallowance of Rs.99,02,829/-, which is claimed by assessee as an interest payment. The assessee in the year under consideration advanced a sum of Rs.41 crores towards purchase of shares. The AO questioned the sources of Rs.41

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

condonation\napplication for delay of 167 days without properly appreciating the facts\nof the case.\n3) That the learned CIT(A) erred in law and on facts in upholding the\naddition of ₹.56,07,00,000 under Section 68

BETHALA PETROPACKS PVT LTD., (FORMERLY KNOWN AS DEEPAK EXTRUSIONS PVT LTD.,),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4) , BENGALURU

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

68 of the Act for not proving the credit entry found in the books of accounts. 5. Against this assessee went in appeal before ld. CIT(A), challenging the various additions made by ld. AO. However, the appeals have been filed before ld. CIT(A) belatedly as below: AY Order passed Appeal No. Date of Limitation Date of Delay

BETHALA PETROPACKS PVT LTD., (FORMERLY KNOWN AS DEEPAK EXTRUSIONS PVT LTD.,),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX OFFICER, CENTRAL CIRCLE-1(4) , BENGALURU

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

68 of the Act for not proving the credit entry found in the books of accounts. 5. Against this assessee went in appeal before ld. CIT(A), challenging the various additions made by ld. AO. However, the appeals have been filed before ld. CIT(A) belatedly as below: AY Order passed Appeal No. Date of Limitation Date of Delay

BETHALA PETROPACKS PVT LTD., (FORMERLY KNOWN AS DEEPAK EXTRUSIONS PVT LTD.,),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4) , BENGALURU

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

68 of the Act for not proving the credit entry found in the books of accounts. 5. Against this assessee went in appeal before ld. CIT(A), challenging the various additions made by ld. AO. However, the appeals have been filed before ld. CIT(A) belatedly as below: AY Order passed Appeal No. Date of Limitation Date of Delay

BETHALA PETROPACKS PVT LTD., (FORMERLY KNOWN AS DEEPAK EXTRUSIONS PVT LTD.,),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

68 of the Act for not proving the credit entry found in the books of accounts. 5. Against this assessee went in appeal before ld. CIT(A), challenging the various additions made by ld. AO. However, the appeals have been filed before ld. CIT(A) belatedly as below: AY Order passed Appeal No. Date of Limitation Date of Delay

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

condonation\napplication for delay of 167 days without properly appreciating the facts\nof the case.\n3) That the learned CIT(A) erred in law and on facts in upholding the\naddition of ₹.56,07,00,000 under Section 68

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

condonation\napplication for delay of 167 days without properly appreciating the facts\nof the case.\n3) That the learned CIT(A) erred in law and on facts in upholding the\naddition of ₹.56,07,00,000 under Section 68

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 5 must receive a liberal construction so as to advance substantial justice and generally delays in preferring appeals are required $o be condoned in the the interest of justice where no gross negligence or deliberate inaction or lack of bona fides is imputable to the party seeking condonation of the delay.".... (c) In this context, we may refer with

JURIMATRIX SERVICES INDIA PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 4(3)(1), BENGALURU

In the result, appeal of the assessee is dismissed

Bench: Shri Waseem Ahmed\Nand\Nshri Keshav Dubey\Nita No.92/Bang/2025\N Assessment Years:2018-19\Njurimatrix Services India Pvt. Ltd.\Ng4, Aspen Building\Nmanyata Embassy Business Park\Nhebbal\Nbangalore 560045\Npan No: Aabcj6157D\Nappellant\Nacit\Nvs. Circle 4(3)(1)\Nbangalore\Nrespondent\Nappellant By : Sri K.R. Girish, A.R.\Nrespondent By : Ms. Neha Sahay, D.R.\Ndate Of Hearing : 21.04.2025\Ndate Of Pronouncement: 15.07.2025\Norder\Nper Keshav Dubey:\Nthis Appeal At The Instance Of The Assessee Is Directed Against\Nthe Order Of The Ld. Pcit Dated 30.03.2023 Vide Din & Order No.\Nitba/Rev/F/Rev5/2022-23/1051648832(1) Passed U/S 263 Of\Nthe Income Tax Act, 1961 (In Short “The Act”) For The Assessment\Nyear 2018-19.\N2. The Assessee Has Raised The Following Grounds Of Appeal:\Ngeneral Grounds Of Appeal\N1.

68,840 dated 23 March, 2024.\nThe Appellant craves leave to add, alter, vary, omit, substitute or amend the above grounds, at\nany time before or at the time of hearing of the appeal. Each of the above objections is\nindependent and without prejudice to the other grounds preferred by the Appellant.\n3. At the outset, there is a delay