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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
SHRI CHANDRA POOJARI, ACJ, SHRI PRAKASH CHAND YADAV, J
Sri V. Srinivasan – Appellant
Versus
Ms. Neha Sahay – Respondent
| Table of Content |
|---|
| 1. background of the appeals regarding assessment. (Para 1 , 2) |
| 2. issue of limitation concerning passed assessment orders. (Para 3 , 4) |
| 3. legal standing of the search legality. (Para 5) |
| 4. discussion on conditions for issuing notice under section 153c. (Para 6 , 7) |
| 5. assessment additions not based on incriminating materials. (Para 8 , 9 , 10) |
| 6. need for evidence and consideration of prior years' data. (Para 11 , 12 , 13) |
| 7. final determination to remit issues for fresh consideration. (Para 14 , 16) |
ORDER
PER CHANDRA POOJARI, ACCOUNTANT MEMBER:
These appeal by assessee are directed against the common order of CIT(A)-11, Bangalore for the assessment years 2014-15 to 2018-19 dated 31.12.2023. Certain issues in these appeals are common in nature, hence, these appeals are clubbed together, heard together and disposed of by this common order for the sake of convenience.
2. First, we will take the common ground in these appeals with regard to limitation of passing assessment orders. In these cases, there was search u/s 132 of the Income Tax Act, 1961 on 21.9.2017 in the case of Sri V.G. Siddartha, Coffee Day Enterprises, Ltd. at 7th Floor, No.23/2, Coffee Day Square, Vithal Ma
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