High Court of Karnataka at Bengaluru · Judgments and reasoned final orders
The Commissioner of Income Tax, CIT(A) Exemption & Anr. v. M/s. Ananda Social and Education Trust
ITA No. 167 of 2022 c/w ITA No. 107 of 2022 ·
Following lead judgment in ITA Nos. 112/2022 & 168/2022, Revenue's appeals for AY 2014-15 challenging deletion of alleged unaccounted UG/PG/COMED-K fee additions dismissed.
1. FACTS OF THE CASE
The Revenue preferred ITA No. 167 of 2022 and ITA No. 107 of 2022 under section 260A for AY 2014-15 challenging the common ITAT Bengaluru order dated 29.05.2020 (in ITA No. 2660/Bang/2017 and ITA No. 2548/Bang/2017) deleting search additions for alleged unaccounted medical college fees.
2. DISCUSSION BY THE COURT
The Division Bench noted that in ITA No. 112/2022 and ITA No. 168/2022 between the same parties (which specifically examined the seized materials for AYs 2009-10 and 2014-15), identical substantial questions of law had been answered in favour of the assessee and against the Revenue.
3. JUDICIAL DECISION
Following the judgment in ITA Nos. 112/2022 and 168/2022, the Court answered Substantial Questions of Law Nos. 1 and 2 in favour of the assessee and against the Revenue, left Question No. 3 open, and dismissed both appeals.
4. OUTCOME
In favour of the assessee (M/s. Ananda Social and Education Trust); Questions 1 & 2 answered for assessee, Question 3 left open, and Revenue appeals dismissed.
5. AKHB REVIEW POINT
AKHB analysis: Even for the search year (AY 2014-15) to which the PA's diary entries related, failure by the AO to examine students or parents or corroborate loose-sheet negotiations renders capitation-fee additions unsustainable.
Source and verification
Reviewed from the complete 5-page official High Court judgment PDF (20260730_KAHC010120142021.pdf, SHA-256: 8360f8e242ca8bbfdee4dd7a4dce32fa2665bf1aa34f4a5108d0c293b1150c3c).
Original PDF: 5 pages · SHA-256: 8360f8e242ca8bbfdee4dd7a4dce32fa2665bf1aa34f4a5108d0c293b1150c3c
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Refers to the Income-tax Act, 1961 and allied statutory rules/circulars as applicable to the relevant assessment years.
No subsequent Supreme Court reversal or stay is recorded in the source judgment text.
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