CIT v. Jet Airways

DCIT, Central Circle-1(3), Bengaluru vs. Coffee Day Global Limited, Bengaluru

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: Page 12 of 26 “The question which first arises is with regard to the validity of the reopening proceedings, which is by issuance of notice under section 148, reasons for which are…

DCIT, Central Circle-1(3), Bengaluru vs. Coffee Day Global Limited, Bengaluru

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon’ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: ITA Nos.780 to 785/Bang/2024 & CO Nos.15 to 18/Bang/2024 M/s. Coffee Day Enterprises Ltd., Bangalore ITA Nos.786 to 791/Bang/2024 & CO Nos.19 to 23/Bang/2024 M/s. Coffee Day Globa…

DCIT, Central Circle-1(3), Bengaluru vs. Coffee Day Global Limited, Bengaluru

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: “The question which first arises is with regard to the validity of the reopening proceedings, which is by issuance of notice under section 148, reasons for which are to be recorded…

DCIT, Central Circle-1(3), Bengaluru, Bangalore vs. Coffee Day Global Limited, Bangalore

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: “The question which first arises is with regard to the validity of the reopening proceedings, which is by issuance of notice under section 148, reasons for which are to be recorded…

DCIT, Central Circle-1(3), Bengaluru vs. Coffee Day Global Limited, Bengaluru

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: “The question which first arises is with regard to the validity of the reopening proceedings, which is by issuance of notice under section 148, reasons for which are to be recorded…

DCIT, Central Circle-1(3), Bengaluru vs. Coffee Day Global Limited, Bengaluru

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: “The question which first arises is with regard to the validity of the reopening proceedings, which is by issuance of notice under section 148, reasons for which are to be recorded…

DCIT, Central Circle-1(3), Bengaluru vs. Coffee Day Enterprises Limited, Bangalore

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon’ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: ITA Nos.780 to 785/Bang/2024 & CO Nos.15 to 18/Bang/2024 M/s. Coffee Day Enterprises Ltd., Bangalore ITA Nos.786 to 791/Bang/2024 & CO Nos.19 to 23/Bang/2024 M/s. Coffee Day Globa…

DCIT, Central Circle-1(3), Bengaluru vs. Coffee Day Enterprises Limited, Bengaluru

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: “The question which first arises is with regard to the validity of the reopening proceedings, which is by issuance of notice under section 148, reasons for which are to be recorded…

Deputy Commissioner of Income-Tax, Bengaluru vs. Coffee Day Enterprises Limited, Bengaluru

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon’ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: ITA Nos.780 to 785/Bang/2024 & CO Nos.15 to 18/Bang/2024 M/s. Coffee Day Enterprises Ltd., Bangalore ITA Nos.786 to 791/Bang/2024 & CO Nos.19 to 23/Bang/2024 M/s. Coffee Day Globa…

DCIT, Central Circle-1(3), Bengaluru, Bangalore vs. Coffee Day Enterprises, Bengaluru

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon’ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: ITA Nos.780 to 785/Bang/2024 & CO Nos.15 to 18/Bang/2024 M/s. Coffee Day Enterprises Ltd., Bangalore ITA Nos.786 to 791/Bang/2024 & CO Nos.19 to 23/Bang/2024 M/s. Coffee Day Globa…

Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru vs. Coffee Day Enterprises Limited, Bengaluru

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: “The question which first arises is with regard to the validity of the reopening proceedings, which is by issuance of notice under section 148, reasons for which are to be recorded…

DCIT, Central Circle-1(3), Bengaluru vs. Coffee Day Enterprises Limited, Bengaluru

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…of the ld. A.R. is that the ld. AO made disallowance u/s 14A of the Act, which was not the reason for assessment at all as such, reopening therefore is not sustainable. He relied on the judgement of Hon'ble Bombay High Court in the case of CIT Vs. Jet Airways 331 ITR 230. However, we find that there is a binding decision of jurisdictional High Court in the case of N. Govindaraju Vs. ITO & Anr. 93 CCH 488 (Karn.), wherein held as under: Page 12 of 26 “The question which first arises is with regard to the validity of the reopening proceedings, which is by issuance of notice under section 148, reasons for which are…