IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K, JUDICIAL MEMBER ITA No. 1223 & 1224/Bang/2025 Assessment Year: 2019-20 & 2020-21 SNN Spiritua Developer, Vs. The Dy. Commissioner of No.4, SNN Mind’s Eye, 2^nd Floor, Income Tax, Diagonal Road, 3^rd Block, Central Circle – 2(1), Jayanagar, Bangalore.

Bangalore – 560 011.

PAN – ACLFS 1959 B APPELLANT RESPONDENT Assessee by : Shri Ramakrishna Kamat, CA Revenue by : Shri Muthu Shankar, CIT (DR)

Date of hearing : 20.01.2026 Date of Pronouncement : 21.01.2026

O R D E R

PER WASEEM AHMED, ACCOUNTANT MEMBER:

These two appeals instituted by the assessee against the separate order of the Ld. CIT(A) passed u/s 250 of the Act dt. 27.02.2025 were heard together.

First, we take up ITA No. 1223/Bang/2025 pertaining to AY

2019-20

2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 9 and sub-grounds thereunder, which we, for the sake of brevity and convenience, are not inclined to reproduce here.

3. Ground Nos. 1,4,8 and 9 were not pressed by the assessee and are accordingly dismissed as not pressed.

4. The inter-connected limited issue before us pertains to th