IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY, JUDICIAL MEMBER Assessment Year : 2014-15 Shri. Chowdadenahally Rangaswamy Manohar, Vs. DCIT, No.88/89, M C Halli, Chikka Tirupati Road, Central Circle – 2(1), Sarjapura, Anekal Taluk, Bangalore.

Bangalore – 562 125.

PAN : AJZPM 9900 D APPELLANT RESPONDENT Assessee by : Shri. Tirumala Naidu, AR Revenue by : Shri.Shivanand H Kalakeri, CIT(DR)(ITAT), Bangalore.

Date of hearing : 19.11.2025 Date of Pronouncement : 28.11.2025

O R D E R

Per Laxmi Prasad Sahu, Accountant Member :

This is an appeal filed by the assessee against the Order passed by the learned CIT(A) - 15, Bangalore, vide DIN : ITBA/APL/M/250/2024-

25/1073843798(1) dated 28.02.2025.

2. Briefly stated facts of the case are that assessee is an individual. Assessee is into the business of Film production, running a proprietorship concern M/s. Golden Lion Films. He is one of the partners in partnership firm M/s. Lion Estates and Properties which is engaged in the business of real estate consultancy, property development, etc. Assessee is in receipt of income from capital gain, other sources and agricultural produce, filed his return of income under section 139 of the Act on 30.11.2014 admitting total income of Rs.13,49,557/-. Assessment proceeding was completed under section 143(3) r.w.s. 153A of the Act on 29.12.2017 assessing income at Rs.5,14,90,650/-. Subsequently in 154 proceeding Order dated 06.03.2018, demand was reduced to Rs.2,60,93,360/- on account of reconciliation of TDS mismatch. A search under section 132 of the Act was conducted on 15.03.2016 at the residence Shri. C. R. Manohar at G. L. Residency, Near Sri Rama Temple, Sarjapura Ward No.1, Bengaluru District, Anekal Taluk and premise at No.385, 17th C Main, Sector – 4, HSR Layout, Bangalore. Consequent to search a notice, dated 21.11.2016 under section153Aof the Act was issued and served on the assessee on 23.11.2016. In response of notice under section153A of the Act assessee has submitted his return of income on 22.10.2017 admitting the same particulars of income as admitted in return filed under section 139(1) of the Act. During the course of search and seizure proceedings various documents were found and there was cash payments were found and 20% was accepted and 20% of admitted amount towards cash payments were offered as income. In the first search proceedings conducted on 15.03.2016 and pursuant to search on 15.03.2016, the case of the assessee was completed under section 143(3) r.w.s. 153A of the Act and raised demand of Rs.2,60,93,360/-. There was another search on 01.01.2019 under section 153A of the Act. Consequent to the search notice under section 153A of the Act was also issued to the assessee and assessment was completed under section 143(3) r.w.s. 153A of the Act and returned income filed by the assessee was accepted. During the course of assessment proceedings of first search, assessee conceded cash payment made and balance of 80% agreed to offer vide his letter dated 22.12.2017 and income was assessed at Rs.5,14,90,650/-.

3. Aggrieved from the above Order, assessee filed appeal before learned CIT(A), the learned CIT(A) dismissed appeal of the assessee.

4. Aggrieved from the above Order, assessee is in appeal before the Tribunal. The learned Counsel filed written submissions which is as under:

I. Background and Context of the Appeal The appellant, Shri C.R. Manohara, is engaged in film production under the proprietary concern Golden Lion Films and also in real estate consultancy as a partner in Lion Estates and Properties. For AY 2014-15, the appellant initially filed a return under section 139 declaring an income of ₹13,49,560/-. Pursuant to a search conducted on 15.03.2016, an assessment came to be completed under section 143(3) r.w.s. 153A on 29.12.2017, wherein additions were made towards agricultural income, self-made vouchers, and disallowance under section 37.