Ganga Saran and Sons P. Ltd. v. ITO

130 ITR 1Supreme Court of India1981#378 most cited

What is Ganga Saran and Sons P. Ltd. v. ITO authority for?

A mere charge of bogus expenses, without a specific finding that the assessee failed to disclose material facts, is insufficient to justify reassessment beyond four years under the first proviso to Section 147. Courts can examine the materiality and relevance of facts forming the 'reason to believe' for initiating reassessment, ensuring it is based on reasonable grounds.

234

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2007 to 2026.

Also referred to as

Ganga Saran and Sons P. Ltd. v. ITO · Section 147 · Section 148 · first proviso to section 147 · reason to believe · income escaping assessment · material facts disclosure · bogus expenses · reassessment beyond four years · judicial review of reasons

Sections most often in play

Section 147Section 148Section 143(3)Section 151Section 139(1)Section 142(1)Section 133ASection 144

Issues it is cited on

true and full disclosurefirst proviso to section 147material facts necessary for assessmentsection 148(2)kelvinatorlive linkmere change of opinionfresh tangible materialsection 151(1)sanctioning authoritybeyond four yearsincome escaping assessment

Judgments citing Ganga Saran and Sons P. Ltd. v. ITO

ACIT, Central Circle-19, New Delhi vs. M/S K.R. Pulp & Papers Ltd, New Delhi

In the result, the appeal of the Revenue is

ITA 5064/DEL/2017[2009-10]Status: DisposedITAT Delhi31 Mar 2022AY 2009-10

Bench: Shri R.K. Panda & Shri N.K. Choudhry

For Appellant: Ms. Monika Aggarwal, AdvocateFor Respondent: Smt. Sunita Singh, CIT-DR
Section 132Section 143(3)Section 147Section 80I

…ase and those considered by the Supreme Court in the case of Lakhmani Mewal Das [1976] 103 ITR 437." 6. The view taken by the Supreme Court in Lakhmani Mewal Das (supra) was followed in Ganga Saran and Sons Private Limited versus Income-Tax Officer-I, [1981] 130 ITR 1 (SC). The matter was again examined by the Supreme Court in Phool Chand Bajrang Lai and Another versus Income-Tax Officer and Another, [1993] (203) ITR 456 (SC). In the said case, information was received by the Assessing Officer that the third company had never actually advanced loans to any person and the said third company was in the business co…

Income Tax Officer, (Exemptions), Ward-Surat, Surat vs. Monoharlal Jain Memorial Foundation, Navsari

In the result, the appeal of the Revenue is dismissed

ITA 375/SRT/2019[2009-10]Status: DisposedITAT Surat28 Feb 2022AY 2009-10

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.375/Srt/2019 (िनधा"रणवष" / Assessment Year: (2009-10) (Virtual Court Hearing) Income Tax Officer (Exemptions), Manohar Lal Jain Memorial Room No. 105, 1St Floor, Income Foundation, Vs. Sardar Chowk, Vijalpore, Navsari- Tax Office, Anavil Business Centre, 396 445 Nr. Brts Bus Stop, Adajan, Surat- 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaatm 9015 D (Appellant ) (Respondent)

For Appellant: Shri Sujesh Suratwala, C.AFor Respondent: Shri H.P.Meena– CIT-DR
Section 10Section 12ASection 142(1)Section 144Section 147Section 148

…the court can certainly examine whether the reasons are relevant and have a bearing on the matters in regard to which he is required to entertain the belief before he can issue notice under section 147 of the Act. [ Ganga Saran & Sons (P.) Ltd. v. ITO (1981) 130 ITR 1 (SC)] 12. Based on the factual position narrated above, we do not find any infirmity in the order passed by Ld. CIT(A). That being so, we decline to interfere in the order passed by Ld. CIT(A) and the addition so deleted by Ld. CIT(A) on this issue, is hereby upheld. The ground raised by Revenue stands dismissed. 13.In the result, the appeal of th…

D.C.I.T., Circle-11(1), Kolkata vs. Turtle Ltd., Howrah

In the result, the appeal of the revenue is dismissed

ITA 2620/KOL/2019[2012-13]Status: DisposedITAT Kolkata23 Feb 2022AY 2012-13

Bench: Shri A. T. Varkey, Jm & Shri Girish Agrawal, Am]

Section 139Section 142(1)Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 3

…eve escapement of income, but also what was the failure on the part of the assessee to disclose truly and fully the material facts necessary for assessment. 4 Turtle Ltd. AY: 2012-13 9. The Hon’ble Supreme Court in Ganga Saran and Sons P. Ltd. v. ITO, [1981] 130 ITR 1 (SC). held “ It is well settled as a result of several decision of this Court that two distinct condition must be satisfied before the AO can assume jurisdiction to issue notice u/s 147. First he must have reason to believe that the income of assessee has escaped assessment. – The important words under Section 147(a) are “has reason to believe” & t…

Bentley Nevada Inc., Gurgaon vs. DCIT, Circle- 1(1)(2), International Taxation, New Delhi

In the result, all the four appeals of the assessee in ITA Nos

ITA 6303/DEL/2017[2011-12]Status: DisposedITAT Delhi03 Feb 2022AY 2011-12

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 148

…ntion of such employees in the assessment order. In our considered opinion, there needs to be close nexus between the material before the Assessing Officer and the belief which he has formed. 16. The Hon'ble Supreme Court in the case of Ganga Saran & Sons 130 ITR 1, has remarked “The words “has reason to believe” are stronger than the words "is satisfied.". The belief entertained by the Income Tax Officer must not be arbitrary or irrational. It must be reasonable or, in other words, it must be based on reasons which are relevant and material. 17. In light of the afore stated observations, we are of the view…

Bentley Nevada Inc., Gurgaon vs. DCIT, Circle- 1(1)(2), International Taxation, New Delhi

In the result, all the four appeals of the assessee in ITA Nos

ITA 6302/DEL/2017[2010-11]Status: DisposedITAT Delhi03 Feb 2022AY 2010-11

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 148

…ntion of such employees in the assessment order. In our considered opinion, there needs to be close nexus between the material before the Assessing Officer and the belief which he has formed. 16. The Hon'ble Supreme Court in the case of Ganga Saran & Sons 130 ITR 1, has remarked “The words “has reason to believe” are stronger than the words "is satisfied.". The belief entertained by the Income Tax Officer must not be arbitrary or irrational. It must be reasonable or, in other words, it must be based on reasons which are relevant and material. 17. In light of the afore stated observations, we are of the view…

Bentley Nevada Inc., Gurgaon vs. DCIT, Circle- 1(1)(2), International Taxation, New Delhi

In the result, all the four appeals of the assessee in ITA Nos

ITA 6301/DEL/2017[2009-10]Status: DisposedITAT Delhi03 Feb 2022AY 2009-10

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 148

…ntion of such employees in the assessment order. In our considered opinion, there needs to be close nexus between the material before the Assessing Officer and the belief which he has formed. 16. The Hon'ble Supreme Court in the case of Ganga Saran & Sons 130 ITR 1, has remarked “The words “has reason to believe” are stronger than the words "is satisfied.". The belief entertained by the Income Tax Officer must not be arbitrary or irrational. It must be reasonable or, in other words, it must be based on reasons which are relevant and material. 17. In light of the afore stated observations, we are of the view…

Bentley Nevada Inc., Gurgaon vs. DCIT, Circle- 1(1)(2), International Taxation, New Delhi

In the result, all the four appeals of the assessee in ITA Nos

ITA 6300/DEL/2017[2008-09]Status: DisposedITAT Delhi03 Feb 2022AY 2008-09

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 148

…ntion of such employees in the assessment order. In our considered opinion, there needs to be close nexus between the material before the Assessing Officer and the belief which he has formed. 16. The Hon'ble Supreme Court in the case of Ganga Saran & Sons 130 ITR 1, has remarked “The words “has reason to believe” are stronger than the words "is satisfied.". The belief entertained by the Income Tax Officer must not be arbitrary or irrational. It must be reasonable or, in other words, it must be based on reasons which are relevant and material. 17. In light of the afore stated observations, we are of the view…

Ceebuild Company Pvt. Ltd., Kolkata vs. D.C.I.T., Circle-1(2), Kolkata

In the result, the appeal of assessee is allowed

ITA 1266/KOL/2019[2010-11]Status: DisposedITAT Kolkata05 Jan 2022AY 2010-11

Bench: Shri A. T. Varkey & Shri Manoj Kumar Agarwal]

Section 143(3)Section 147Section 148

…. When there is “reason to suspect” then AO to make a reasonable enquiry and collect material which would make him belief, that there is in fact an escapement of income. It is settled by the Hon’ble Supreme Court in Ganga Saran and Sons P. Ltd. v. ITO, [1981] 130 ITR 1 (SC) that the expression “reason to believe” the expression in section 147 ‘is stronger” then the expression “is satisfied”. Therefore the AO has to record his reason to believe escapement of income and if he intends to reopen an assessment which has been framed earlier u/s 143(3) after the expiry of four (4) years from the end of the relevant asse…

D.C.I.T.Circle-6(1), Kolkata vs. M/S Coal Sale Co.Ltd., Kolkata

In the result, the appeal of the revenue is dismissed and the cross-objection of the assessee is allowed

ITA 2364/KOL/2019[2014-15]Status: DisposedITAT Kolkata17 Dec 2021AY 2014-15

Bench: Shri P. M. Jagtap, Hon’Ble Vice- & Shri A.T. Varkey, Hon’Ble]

Section 143(3)Section 147Section 148

…o his own discretion. If discretion is exercised under the direction or compliance with some higher authorities instruction, then it will be a cases of failure to exercise discretion altogether. 17. In the case of Ganga Saran and Sons P. Ltd. v. ITO, [1981] 130 ITR 1 (SC) the Hon’ble Supreme Court held: “It is well settled as a result of several decision of this Court that two distinct condition must be satisfied before the AO can assume jurisdiction to issue notice u/s 147. First he must have reason to believe that the income of assessee has escaped assessment. – The important words under Section 147(a) are “h…

Deputy Commissioner of Income Tax Circle-6(2)(1), Bangalore vs. Sri C Gangadhara Murthy, Bangalore

In the result, the appeals filed by the Revenue for assessment years 2009-2010, 2010-2011 and 2011-2012 are allowed for statistical purposes

ITA 2399/BANG/2018[2011-12]Status: DisposedITAT Bangalore30 Nov 2021AY 2011-12

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.V.Chandrasekhar, AdvocateFor Respondent: Sri.Sumer Singh Meena, CIT-DR
Section 144Section 147Section 148

…sons to Suspect, but they are not reasons to believe that the income has escaped assessment within the meaning of that section, Reliance is placed on the decision of the Hon’ble Apex Court in the case of Ganga Saran & Sons (P) Ltd. v. ITO& Others, reported in 130 ITR 1.” 8 ITA Nos.2397-2399/Bang/2018 Sri C Gangadhara Murthy. 7.2 The above objections of the assessee are not specific nor clear. On the contrary, the same is very vague. However, the objection of the assessee was disposed by the Assessing Officer on 16.09.2014 itself. The A.O. annexed the copy of the order disposing of the assessee’s objection along…

Deputy Commissioner of Income Tax Circle-6(2)(1), Bangalore vs. Sri C Gangadhara Murthy, Bangalore

In the result, the appeals filed by the Revenue for assessment years 2009-2010, 2010-2011 and 2011-2012 are allowed for statistical purposes

ITA 2398/BANG/2018[2010-11]Status: DisposedITAT Bangalore30 Nov 2021AY 2010-11

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.V.Chandrasekhar, AdvocateFor Respondent: Sri.Sumer Singh Meena, CIT-DR
Section 144Section 147Section 148

…sons to Suspect, but they are not reasons to believe that the income has escaped assessment within the meaning of that section, Reliance is placed on the decision of the Hon’ble Apex Court in the case of Ganga Saran & Sons (P) Ltd. v. ITO& Others, reported in 130 ITR 1.” 8 ITA Nos.2397-2399/Bang/2018 Sri C Gangadhara Murthy. 7.2 The above objections of the assessee are not specific nor clear. On the contrary, the same is very vague. However, the objection of the assessee was disposed by the Assessing Officer on 16.09.2014 itself. The A.O. annexed the copy of the order disposing of the assessee’s objection along…

Deputy Commissioner of Income Tax Circle-6(2)(1), Bangalore vs. Sri C Gangadhara Murthy, Bangalore

In the result, the appeals filed by the Revenue for assessment years 2009-2010, 2010-2011 and 2011-2012 are allowed for statistical purposes

ITA 2397/BANG/2018[2009-10]Status: DisposedITAT Bangalore30 Nov 2021AY 2009-10

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.V.Chandrasekhar, AdvocateFor Respondent: Sri.Sumer Singh Meena, CIT-DR
Section 144Section 147Section 148

…sons to Suspect, but they are not reasons to believe that the income has escaped assessment within the meaning of that section, Reliance is placed on the decision of the Hon’ble Apex Court in the case of Ganga Saran & Sons (P) Ltd. v. ITO& Others, reported in 130 ITR 1.” 8 ITA Nos.2397-2399/Bang/2018 Sri C Gangadhara Murthy. 7.2 The above objections of the assessee are not specific nor clear. On the contrary, the same is very vague. However, the objection of the assessee was disposed by the Assessing Officer on 16.09.2014 itself. The A.O. annexed the copy of the order disposing of the assessee’s objection along…

Shri Rai Singh Sihag, Jaipur vs. Income Tax Officer, Ward-3-1, Jaipur

In the result, this appeal of the assessee is allowed

ITA 441/JPR/2019[2007-08]Status: DisposedITAT Jaipur15 Nov 2021AY 2007-08

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 441/Jp/2019 Assessment Year: 2007-08 Shri Rai Singh Sihag, Cuke I.T.O. Vs. B-105, Vaishali Nagar, Ward- 3(1), Jaipur. Jaipur. Pan No.: Bgvps 4485 F Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Ashok Kr. Gupta & Shri S.L. Jain (Advs.) Jktlo Dh Vksj Ls@ Revenue By :Shri A.S. Nehra (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 02/11/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 15/11/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A)-1, Jaipur Dated 13/07/2017 For The A.Y. 2007-08. Following Grounds Have Been Taken By The Assessee: “1. The Reasons For Reopening Of The Assessment Not Valid :- That On The Facts & In The Circumstances Of The Case Ld. Ao Has Grossly Erred In Law & Facts In Invoking Action U/S 147.The Notice For Reassessment Is So Hastily Issued Without Examining The Correct Factual & Legal Position. The Action For Reassessment Is Often Made Without Application Of Mind Fairly & Objectively The Ao. Lakhmani Mewal Das 103 Itr 437 (Sc)

For Appellant: Shri Ashok kr. Gupta &For Respondent: Shri A.S. Nehra (Addl.CIT)
Section 143(2)Section 147Section 148Section 151Section 234ASection 68

…he correct factual and legal position. The action for reassessment is often made without application of mind fairly and objectively the AO. Lakhmani Mewal Das 103 ITR 437 (SC) 2 ITA 441/JP/2019_ Shri Rai Singh Sihag Vs ITO Ganga Saran & Sons (P) Ltd. Vs. ITO 130 ITR 1 (SC) Bir Bahadur Gingh Sijwali Vs. ITA No. 3814/ De1/11 Amrik Singh Vs. ITO ward-1, Kapurthala, ITA No. 630(Asr)/2015. 2. Re-assessment is based on borrowed satisfaction :- That on the facts and in the circumstances of the case Ld. AO has grossly erred in law and facts by confirming issuing notice Ws 148 on the basis of AIR information in respect o…

Sarthak Real Built Pvt. Ltd, Indore vs. Dy, CIT, CPC-TDS, Ghaziabad

ITA 819/IND/2017[14-15--26Q/Q-4]Status: DisposedITAT Indore13 Oct 2021

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing

Section 143(3)Section 148Section 69A

…fully and truly all material facts and the notice issued by him would be liable to be struck down as invalid. This ratio has been laid down by the Hon'ble Supreme Court in the case of Ganga Saran & Sons (P) Ltd. vs. ITO & Ors. (1981) 22 CTR (SC) 112 : (1981) 130 ITR 1 (SC) : TC51R.639 reversing the decision of 16 Ferro Concrete Construction P. Ltd. . ITA No.439/Ind/2017 & others the Calcutta High Court in ITO vs. Ganga Saran & Sons (P) Ltd. (1981) 22 CTR (SC) 112 : (1981) 130 ITR 1 (SC) : TC51R.639]. The Hon'ble Supreme Court observed that "Having reason to believe" means that not only there is a reason for…

Assistant Commissioner of Income Tax 1 (1), Indore vs. M/S Ferro Concreate Construction (India) Pvt. Ltd Indore, Indore

ITA 439/IND/2017[09-10]Status: DisposedITAT Indore13 Oct 2021

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing

Section 143(3)Section 148Section 69A

…fully and truly all material facts and the notice issued by him would be liable to be struck down as invalid. This ratio has been laid down by the Hon'ble Supreme Court in the case of Ganga Saran & Sons (P) Ltd. vs. ITO & Ors. (1981) 22 CTR (SC) 112 : (1981) 130 ITR 1 (SC) : TC51R.639 reversing the decision of 16 Ferro Concrete Construction P. Ltd. . ITA No.439/Ind/2017 & others the Calcutta High Court in ITO vs. Ganga Saran & Sons (P) Ltd. (1981) 22 CTR (SC) 112 : (1981) 130 ITR 1 (SC) : TC51R.639]. The Hon'ble Supreme Court observed that "Having reason to believe" means that not only there is a reason for…

M/S. Ferro Concrete Con. India Pvt. Ltd., Indore vs. The DCIT Circle-1(1), Indore

ITA 359/IND/2017[2009-10]Status: DisposedITAT Indore13 Oct 2021AY 2009-10

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing

Section 143(3)Section 148Section 69A

…fully and truly all material facts and the notice issued by him would be liable to be struck down as invalid. This ratio has been laid down by the Hon'ble Supreme Court in the case of Ganga Saran & Sons (P) Ltd. vs. ITO & Ors. (1981) 22 CTR (SC) 112 : (1981) 130 ITR 1 (SC) : TC51R.639 reversing the decision of 16 Ferro Concrete Construction P. Ltd. . ITA No.439/Ind/2017 & others the Calcutta High Court in ITO vs. Ganga Saran & Sons (P) Ltd. (1981) 22 CTR (SC) 112 : (1981) 130 ITR 1 (SC) : TC51R.639]. The Hon'ble Supreme Court observed that "Having reason to believe" means that not only there is a reason for…

M/S. Ferro Concrete Con. India Pvt. Ltd., Indore vs. The Pr.CIT-1, Indore

ITA 284/IND/2017[2012-13]Status: DisposedITAT Indore13 Oct 2021AY 2012-13

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing

Section 143(3)Section 148Section 69A

…fully and truly all material facts and the notice issued by him would be liable to be struck down as invalid. This ratio has been laid down by the Hon'ble Supreme Court in the case of Ganga Saran & Sons (P) Ltd. vs. ITO & Ors. (1981) 22 CTR (SC) 112 : (1981) 130 ITR 1 (SC) : TC51R.639 reversing the decision of 16 Ferro Concrete Construction P. Ltd. . ITA No.439/Ind/2017 & others the Calcutta High Court in ITO vs. Ganga Saran & Sons (P) Ltd. (1981) 22 CTR (SC) 112 : (1981) 130 ITR 1 (SC) : TC51R.639]. The Hon'ble Supreme Court observed that "Having reason to believe" means that not only there is a reason for…

Sunita Madhok, Bangalore vs. The Assistant Commissioner of Income Tax Circle-1(2)(1), Bangalore

In the result, the appeals by the assessee are partly allowed

ITA 555/BANG/2018[2007-08]Status: DisposedITAT Bangalore11 Oct 2021AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H.N. Khincha, CAFor Respondent: Smt. H. Kabila, Addl.CIT(DR)(ITAT), Bengaluru
Section 234BSection 69

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER ITA Nos.554 & 555/Bang/2018 Assessment years : 2006-07 & 2007-08 Sunita Madhok, Vs. The Assistant Commissioner L/R of late Sri Romesh Madhok, of Income Tax, # 327, 5th Main Road, 1st Block, Circle 1(2)(1), Koramangala, Bengaluru. Bangalore – 560 004. PAN: ABJPM 9641D APPELLANT RESPONDENT Appellant by : Shri H.N. Khincha, CA Respondent by : Smt. H. Kabila, Addl.CIT(DR)(ITAT), Bengaluru. Date of hearing : 23.08.2021 Date of Pronouncement : 11.10.2021 O R D E R Per Ch…

Sunita Madhok, Bangalore vs. The Assistant Commissioner of Income Tax Circle-1(2)(1), Bangalore

In the result, the appeals by the assessee are partly allowed

ITA 554/BANG/2018[2006-07]Status: DisposedITAT Bangalore11 Oct 2021AY 2006-07

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H.N. Khincha, CAFor Respondent: Smt. H. Kabila, Addl.CIT(DR)(ITAT), Bengaluru
Section 234BSection 69

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER ITA Nos.554 & 555/Bang/2018 Assessment years : 2006-07 & 2007-08 Sunita Madhok, Vs. The Assistant Commissioner L/R of late Sri Romesh Madhok, of Income Tax, # 327, 5th Main Road, 1st Block, Circle 1(2)(1), Koramangala, Bengaluru. Bangalore – 560 004. PAN: ABJPM 9641D APPELLANT RESPONDENT Appellant by : Shri H.N. Khincha, CA Respondent by : Smt. H. Kabila, Addl.CIT(DR)(ITAT), Bengaluru. Date of hearing : 23.08.2021 Date of Pronouncement : 11.10.2021 O R D E R Per Ch…

Income Tax Officer, Ward - 3(2)(3), Bangalore vs. Sri Made Gowda Thibbe Gowda, Bangalore

In the result, the appeal of the revenue is dismissed and CO of the assessee is partly allowed

ITA 910/BANG/2019[2008-09]Status: DisposedITAT Bangalore29 Sept 2021AY 2008-09

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2008-09

For Appellant: Shri H. Guruswamy, ITP & Shri Ravi Kiran, CAFor Respondent: Shri Priyadarshi Mishra, Jt. CIT(DR)(ITAT), Bengaluru
Section 131Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER Assessment year : 2008-09 The Income Tax Officer, Vs. Sri Made Gowda Thibbe Gowda, Ward 3(2)(3), No.290, BEML Layout Cross, 1st Phase, V Stage, Bangalore. Rajarajeshwarinagar, Bangalore – 560 098. PAN: AEJPG 5365D APPELLANT RESPONDENT CO No.51/Bang/2019 [in ITA No.910/Bang/2019] Assessment year : 2008-09 Sri Made Gowda Thibbe Gowda, Vs. The Income Tax Officer, Bangalore – 560 098. Ward 3(2)(3), PAN: AEJPG 5365D Bangalore. CROSS OBJECTOR RESPONDENT / APPELLANT IN APP…