Thayappa Balakrishna, Bangalore vs. The Principal Commissioner of Income Tax, Bengaluru-1, Bengaluru
In the result, the appeal filed by the assessee stands allowed
ITA 1027/BANG/2024[2014-15]Status: DisposedITAT Bangalore22 Aug 2024AY 2014-15
Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2014-15 Shri Thayappa Balakrishna, No. 987, 11Th Main, The Principal 1St Block, Commissioner Of 3Rd Stage, Income-Tax, Basaveshwaranagar, Bengaluru – 1. Vs. Bangalore – 560 079. Pan: Abdpb4893N Appellant Respondent : Shri Ravi Shankar .S.V, Assessee By Advocate Revenue By : Shri D.K. Mishra, Cit-Dr
For Respondent: Shri Ravi Shankar .S.V
Section 143(3)Section 147Section 148Section 263
…to appreciate the reasons for the amendment inserting Explanation 3, it would be necessary to advert to some of the judgments of the High Courts, prior to the amendment. The Punjab and Haryana High Court, in its decision, in Vipan Khanna v. Asstt. CIT [2002] 255 ITR 2201 dealt with the question as to whether, after initiating proceedings under section 147 on the ground that the petitioner had claimed depreciation at a higher rate, the Assessing Officer would be justified in launching an inquiry into issues which were not connected with the claim of depreciation. This question was answered in the negative. A Divi…