“reopening of assessment”

ReassessmentSections 147-151Sections 147-1514,262 judgments

The decision most relied on for reopening of assessment is GKN Driveshafts (India) Ltd. v. ITO (259 ITR 19), cited in 1,349 judgments on BharatTax.

Leading authorities on reopening of assessment

GKN Driveshafts (India) Ltd. v. ITO

259 ITR 19 · 2003 · Supreme Court

1,349

citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.

291 ITR 500 · 2007 · Supreme Court

1,030

citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO

236 ITR 34 · 1999 · Supreme Court

862

citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

CIT v. Lovely Exports (P) Ltd.

216 CTR 195 · 2008 · Supreme Court

854

citing judgments

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

CIT v. Jet Airways (I) Ltd.

331 ITR 236 · 2011 · High Court

694

citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

CIT v. RRJ Securities Ltd.

380 ITR 612 · 2016 · High Court

689

citing judgments

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

Union of India v. Ashish Agarwal

444 ITR 1 · 2022 · Supreme Court

524

citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

PCIT v. Meenakshi Overseas Pvt. Ltd.

395 ITR 677 · 2017 · High Court

471

citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Judgments citing reopening of assessment

Megahertz Systems Pvt Ltd, Mumbai vs. ACIT Circle 5 (2) (2), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 2814/MUM/2023[2009-10]Status: DisposedITAT Mumbai30 Jan 2024AY 2009-10

Bench: Shri Vikas Awasthy & Shri Amarjit Singhmegahertz Systems Vs. Asst. Commissioner Of Private Limited, 251/253, Income Tax, Circle 5(2)(2) Tardeo Court, Opp. Swati Aayakar Bhavan, Snacks Tardeo Road Wrqh+C23, Maharshi Near Bhatia Hospital, Karve Road, New Marine Grant Road West, Lines, Churchgate, Mumbai – 400 007 Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aadcm8203F Appellant .. Respondent Appellant By : None Respondent By : Ms. Indira Adakil Date Of Hearing 23.01.2024 Date Of Pronouncement 30.01.2024

For Appellant: NoneFor Respondent: Ms. Indira Adakil

Section 143(1)Section 147Section 148Section 250Section 69C

tangible material. 5. The Ld. CIT(A) erred in confirming the order of Ld. Assessing Officer disregarding the fact that the reopening of assessment was on the basis of vague, unclear and ambiguous reasons. 6. The Ld. CIT(A) erred in confirming the addition made by the Ld. Assessing Officer ... circumstances we don’t find any merit in this ground of appeal of the assessee, therefore, ground no. 2 to 6 regarding reopening of assessment are dismissed. Ground No. 1: 6. Being a general grounds of appeal it does not require any adjudication since we have dealt with the specific

ITO Ward - 4, Rohtak vs. Surender Dalal, Rohtak

In the result, appeal of the Assessee is partly allowed as

ITA 7714/DEL/2019[2009-10]Status: DisposedITAT Delhi30 Jan 2024AY 2009-10

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.7714/Del/2019 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Ito, Surender Dalal, Ward-4, Vs. Dalal Bhawan, Aayakar Bhawan, Rohtak, Haryana Near Petrol Pump, Gohana Road, Rohtak, Haryana. Pan No.Aqlps2166C अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.7490/Del/2019 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Surender Dalal, Ito, Dalal Bhawan, Vs. Ward-4, Near Petrol Pump, Aayakar Bhawan, Gohana Road, Rohtak, Haryana Rohtak, Haryana. Pan No.Aqlps2166C अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 151Section 69

property. 3. Firstly, we take up the appeal of the assessee, where the assessee in his ground nos. 2 to 6 challenged the reopening of assessment u/s 148 of the Act as bad in law. 4. Ld. Counsel for the assessee referring to page 4 of the Paper Book which ... investment on construction of house was made during the year under consideration i.e. 2009-10 but the Assessing Officer proceeded to reopen the assessment based on the report of DDIT and without making any further enquiries. Ld. Counsel further submitted that notice u/s 148 cannot be issued on the basis

Surender Dalal, Rohtak vs. ITO Ward - 4, Rohtak

In the result, appeal of the Assessee is partly allowed as

ITA 7490/DEL/2019[2009-10]Status: DisposedITAT Delhi30 Jan 2024AY 2009-10

Section 147Section 148Section 151Section 69

ITO, Ward-5, Hisar vs. The Virat Coop. House Building Society Ltd., Hisar

In the result, the appeal of the Revenue is dismissed

ITA 4166/DEL/2017[2007-08]Status: DisposedITAT Delhi30 Jan 2024AY 2007-08

Bench: Shri G.S. Pannu, Vice- & Shri Challa Nagendra Prasadassessment Year: 2007-08 Ito, Ward 5, Vs. The Virat Co-Op House Building Hisar Society Ltd. Alia The Hisar Virat Co-Op Building Society Ltd., H. No. 110A, Sector 15, Hisar Pan :Aaeat0472C (Appellant) (Respondent)

Section 142(1)Section 144Section 147Section 148

learned CIT (Appeals). 5. Heard rival contentions. 6. The assessee contended before the learned CIT (Appeals) that the service of notice for reopening the assessment under Section 144 is bad in law for the following reasons: “4. That the above fixture of notice is invalid due to following reasons ... evidences on record, the case laws relied on, the learned CIT (Appeals) held that the service of notice under Section 148 for reopening of assessment is bad in law and consequently the 6 assessment framed under Section 144 of the Act was quashed observing as under: “A Perusal

Nikunj Kaushik Shah, Mumbai vs. ITO Ward-32(1), Mumbai

Appeal of the assessee is allowed on merits

ITA 2919/MUM/2023[2011-12]Status: DisposedITAT Mumbai29 Jan 2024AY 2011-12

Bench: Shri Aby T. Varkey & Shri Gagan Goyalnikunj Kaushik Shah, 201, Laxmi Palace Chsl, Vileparle (East), Mumbai- 400057, Pan: Apeps6446R ...... Appellant Vs. Ito-32(1), R. No. 335, Kautilya Bhavan, Bkc, Bandra (E) Mumbai- 400051 ..... Respondent

For Appellant: Shri Rajesh Kothari, Ld. ARFor Respondent: Shri Ashok Kumar Ambastha, Ld. DR

Section 10(38)Section 143(1)Section 147Section 148Section 149(1)(b)Section 250Section 68Section 69C

Infrastructure Ltd. u/s. 69C based on the assumption that the commission is paid for arranging the said profit without any corroborative evidence. Reopening of Assessment 6) Without prejudice to above, the learned assessing officer ('Ld. AO') erred in reopening the assessment under section 147 of the Act, issuing notice under ... section 149(1)(b) of the Act were not satisfied in the facts of the present case. 8) The Id. AO erred in reopening the assessment u/s. 147 and issuing notice u/s. 148 of the Income Tax Act, 1961 merely based on the receipt of some information about money laundering

Sai Diamonds, Mumbai vs. ACIT, Circle - 19(3), Mumbai

ITA 3165/MUM/2023[20012-13]Status: DisposedITAT Mumbai25 Jan 2024

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Mrugakshi K. JoshiFor Respondent: Smt. Shreekala Pardeshi

Section 143(3)Section 147Section 68

opening, since the concerned party has retracted the statement as the same being given under coercion/undue influence. 4. The AO has erred in reopening the assessment purely on presumption basis and to make an enquiry or verification. 5. The learned CIT(A) failed to take into consideration the cogent evidence ... such purchases. Therefore, the ground no. 3 of the assessee is partly allowed. 8. The ground No. 1 & 2 pertaining to reopening of assessment was not pressed, therefore, the same stand dismissed.” (Emphasis Supplied) On perusal of above, it is clear that in identical facts and 11. circumstances, the Tribunal

ACIT, CC-2(1), Kol, Kolkata vs. Shalimar Hatcheries Limited, Kolkata

In the result, the appeal of the Revenue is allowed and the Cross Objection filed by the assessee is dismissed

ITA 546/KOL/2023[2012-13]Status: DisposedITAT Kolkata24 Jan 2024AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawali.T.A. No. 546/Kol/2023) Assessment Year: 2012-2013 Assistant Commissioner Of Income Tax,....Appellant Central Circle-2(1), Kolkata, Aayakar Bhawan Poorva, 3Rd Floor, 110, Shanti Pally, Kolkata-700107 -Vs.- Shalimar Hatcheries Ltd.,......................Respondent 46C, Chowringhee Road, Park Street, 17Th Floor, Everest House, Kolkata-700071 [Pan: Aadcs6537J] - A N D - C.O. No. 13/Kol/2023 (In I.T.A. No. 546/Kol/2023) Assessment Year: 2012-2013 Shalimar Hatcheries Ltd.,..................Cross Objector 46C, Chowringhee Road, Park Street, Kolkata-700071 [Pan: Aadcs6537J] -Vs.- Assistant Commissioner Of Income Tax,....Respondent Central Circle-2(1), Kolkata, Aayakar Bhawan Poorva, 110, Shanti Pally, Kolkata-700107 Appearances By: Shri P.P. Barman, Addl. Cit, Appeared On Behalf Of The Revenue

Section 132Section 139Section 143(2)Section 143(3)Section 147Section 148Section 153ASection 35(1)(ii)

above extent”. Therefore, Hon’ble High Courts are unanimous in their approach that in case objections filed by the assessee against the proposition, reopening of assessment are not disposed of, then such an action of the ld. Assessing Officer would not be fatal to the proceeding, rather ... have gone into rest of the judgments filed by the ld. Counsel for the assessee during the course of hearing while challenging the reopening of assessment. He submitted in the second-fold, that the assessee has filed its original return, which was duly gone into an assessment under section

DCIT-14(1)(2), Mumbai vs. M/S. Reliance Infrastructure Limited, Mumbai

ITA 1149/MUM/2023[2015-16]Status: DisposedITAT Mumbai24 Jan 2024AY 2015-16

Bench: Shri.Narender Kumar Choudhry () & Shri S Rifaur Rahman () Ι.Τ.Α. No.1147/Mum/2023 : A.Y. 2011-12 Ι.Τ.Α. No.1148/Mum/2023 : A.Y. 2012-13 Ι.Τ.Α. No.1149/Mum/2023 : A.Y. 2015-16 Dcit, Circle-14(1)(2), Mumbai Vs M/S Reliance Infrastructure Ltd, Room No.455, 4Th Floor Ground Floor, Reliance Centre, Aayakar Bhavan, M.K. Road 19, Walchandhirachand Marg Mumbai-400 020 Ballard Estate, Mumbai-400 001 Appellant Pan : Aaacr7446Q Respondent Present For The Assessee : Shri Niraj Sheth (Ld. Adv), Sh. Jitendra Sanghvi (Ld. Ca) Present For The Department : Shri Rahul Kumar (Ld. Cit Dr) Date Of Hearing 14/12/2023 Date Of Pronouncement 24/01/2024 Order Per N.K. Choudhry (Jm): These Appeals Have Been Preferred By The Assessee, Against The Separate Ordersevendated 08/02/2023 Impugned Herein Passed By The National Faceless Appeal Centre, Delhi ( In Short `Nfac') / Ld. Commissioner Of Income Tax (Appeals) (In Short `Ld. Commissioner') Under Section 250 Of The Income-Tax Act, 1961 (In Short, `The Act') For The A.Ys. 2011-12, 2012- 13 & 2015-16, Respectively. 2

For Appellant: Shri Niraj Sheth (Ld. Adv)For Respondent: Shri Rahul Kumar (Ld. CIT DR)

Section 115JSection 143(1)Section 143(3)Section 147Section 250

1 ITA 1147 to 1149/Mum/2023 Reliance Infrastructure Ltd IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D”, MUMBAI BEFORE SHRI.NARENDER

Mrs. Nisha Ashish Gupta, Mumbai vs. ITO-31(2) (4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1519/MUM/2021[2014-15]Status: DisposedITAT Mumbai23 Jan 2024AY 2014-15

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.1519/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2014-15) Mrs. Nisha Ashish Gupta बिधम/ Ito-31(2)(4) 1501, Anmol Enclave, Opp Pratyakshakar Bhavan, C- Vs. Patel Auto, Goregaon West, 13, Bandra Kurla Mumbai-400062. Complex, Bandra (East), Mumbai-400051. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Adlpg0969J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Vishnu Agarwal/Shri Amit Agarwal Revenue By: Shri Ashok Kumar Ambastha (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 21/12/2023 घोषणा की तारीख /Date Of Pronouncement: 23/01/2024 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 18.08.2021 For The Assessment Year 2014-15. 2. The Main Grievance Of The Assessee Is Against The Action Of The Ld. Cit(A) Upholding The Action Of The Ao Disallowing The Long Term Capital Gain (Ltcg) Claimed By The Assessee In Respect Of Sale Of Shares M/S. Sunrise Asian Limited (Hereafter “M/S. Sunrise”) Of Rs.98,81,550/- U/S 68 Of The Income Tax Act, 1961 (Hereinafter “The Act”). & Thus Denying Deduction U/S 10(38) Of The Act As Well As Upholding Addition Of Rs.1,97,631/- As Commission For Arranging The Bogus Ltcg (2% Of Commission) U/S 69C Of The Act.

For Appellant: Shri Vishnu Agarwal/Shri AmitFor Respondent: Shri Ashok Kumar Ambastha (Sr

Section 10(38)Section 132(4)Section 147Section 68Section 69C

shares dealt by assessee which was held to be bogus as per the investigation report of Kolkata Income Tax Department. The validity of reopening of assessment is not in challenge before us. The claim of exemption u/s 10(38) of the Act on sale of shares of Sunrise Asian Limited

Vayoo Nandan Finance Company Pvt Ltd, New Delhi vs. ITO Ward 26(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3097/DEL/2019[2009-10]Status: DisposedITAT Delhi23 Jan 2024AY 2009-10

Bench: Shri M. Balaganeshm/S. Vayoo Nandan Finance Vs. Ito, Company Pvt. Ltd, Ward-26(2), B-6, Ganpati Apartment, 6, New Delhi Alipur Road, Civil Lines, New Delhi Pan: Aaavc0737F Assessee By : Dr. Rakesh Gupta, Adv Shri Shrey Jain, Adv Revenue By: Ms. Kirti Sankratyayan, Sr. Dr Date Of Hearing 04/01/2024 Date Of Pronouncement 23/01/2024

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Ms. Kirti Sankratyayan, Sr. DR

Section 143(1)Section 143(3)Section 147Section 148

some broker. This fact got unearthed based on some information received from Assistant Director of Income Tax (Investigation), Ahmedabad. The reasons recorded for reopening the assessment are as under:- “Reasons for issue of Notice u/s 148 for reopening of assessment u/s 147 of IT Act 1961 for the A.Y.2009-10 ... treated as a return in response to notice issued u/s 148 of the Act. The assessee sought for the reasons recorded for reopening the assessment and the same were duly supplied to the assessee. The assessee filed objections for the reasons recorded vide letter dated 14.12.2016. These objections were

Reserve Bank Staff and Officers Co-Op Credit Society Ltd, Mumbai vs. ITO Ward 26 (1)(1), Mumbai

In the result, all the five appeals filed by the assessee are allowed

ITA 3118/MUM/2023[2020-21]Status: DisposedITAT Mumbai22 Jan 2024AY 2020-21

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Siddesh Mayekar, ARFor Respondent: Smt. Mahita Nair, DR

Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

Income-tax Act, 1961 (the Act) without appreciating the facts, submissions, documents and case law placed on record 2. Validity of reopening of assessment 2.1. The learned CIT(A) erred in upholding the validity of reopening of assessment even though there was no reason to believe that the income ... assessment was reopened merely on the basis of audit objection. 2.2. The learned CIT (A) erred in upholding the validity of reopening of assessment even though the assessment was reopened due to change of opinion, ITA No. 3114 & Ors/Mum/2023 Reserve bank staff and officers co-op credit society

Reserve Bank Staff and Officers Co-Op Credit Society Ltd, Mumbai vs. ITO Ward 26 (1)(1), Mumbai

In the result, all the five appeals filed by the assessee are allowed

ITA 3117/MUM/2023[2018-19]Status: DisposedITAT Mumbai22 Jan 2024AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Siddesh Mayekar, ARFor Respondent: Smt. Mahita Nair, DR

Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

Reserve Bank Staff and Officers Co-Op Credit Society Ltd, Mumbai vs. ITO Ward 26 (1) (1), Mumbai

In the result, all the five appeals filed by the assessee are allowed

ITA 3116/MUM/2023[2017-18]Status: DisposedITAT Mumbai22 Jan 2024AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Siddesh Mayekar, ARFor Respondent: Smt. Mahita Nair, DR

Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

Reserve Bank Staff and Officers Co-Op Credit Society Ltd, Mumbai vs. ITO Ward 26 (1)(1), Mumbai

In the result, all the five appeals filed by the assessee are allowed

ITA 3115/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Jan 2024AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Siddesh Mayekar, ARFor Respondent: Smt. Mahita Nair, DR

Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

Reserve Bank Staff and Officers Co-Op Credit Society Ltd, Mumbai vs. ITO Ward 26 (1) (1), Mumbai

In the result, all the five appeals filed by the assessee are allowed

ITA 3114/MUM/2023[2013-14]Status: DisposedITAT Mumbai22 Jan 2024AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Siddesh Mayekar, ARFor Respondent: Smt. Mahita Nair, DR

Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

DCIT, CC-06, New Delhi vs. Naveen Infradevelopers & Engineers Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 80/DEL/2022[2012-13]Status: HeardITAT Delhi22 Jan 2024AY 2012-13

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Subhra Jyoti Chakraborty, CIT- DR

Section 147Section 148Section 68

addition of Rs. 65,40,00,000/- u/s 68 of the Act on concluding that when on the ground on which the reopening of assessment was based, no additions are made by the Assessing Officer in the order of assessment, he cannot make additions on some other grounds which ... assessee with the facts, the Assessing Officer was satisfied with the explanation of the assessee in so far as reasons for reopening the assessment are concerned. However, the Assessing Officer noticed that the assessee had some transaction with Super Alliance Marketing Pvt Ltd with credit entry of Rs. 65.4 crores

Deputy Commissioner of Income Tax, C-1(1)(1), Bangalore vs. Algonomy Software Private Limited (Formerly Known As Manthan Software Services Pvt Ltd), Bangalore

In the result, all the appeals filed by the revenue stands dismissed and the cross objections being C

ITA 946/BANG/2023[2015-16]Status: DisposedITAT Bangalore19 Jan 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

For Respondent: Ms. Neera Malhotra, CIT-DR

Section 143(3)Section 147Section 148Section 40

very outset of the matter, the Ld.Counsel appearing for the assessee submitted before us that the ground challenging the reopening of assessment under section 148 though raised by the assessee in each year are not pressed. Hence this particular ground of appeal is dismissed as not pressed. The cross objections

Deputy Commissioner of Income Tax, C-1(1)(1), Bangalore vs. Algonomy Software Private Limited (Formerly Known As Manthan Software Services Pvt Ltd), Bangalore

In the result, all the appeals filed by the revenue stands dismissed and the cross objections being C

ITA 945/BANG/2023[2014-15]Status: DisposedITAT Bangalore19 Jan 2024AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

For Respondent: Ms. Neera Malhotra, CIT-DR

Section 143(3)Section 147Section 148Section 40

Deputy Commissioner of Income Tax, C-1(1)(1), Bangalore vs. Algonomy Software Private Limited (Formerly Known As Manthan Software Services Pvt Ltd), Bangalore

In the result, all the appeals filed by the revenue stands dismissed and the cross objections being C

ITA 944/BANG/2023[2013-14]Status: DisposedITAT Bangalore19 Jan 2024AY 2013-14

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

For Respondent: Ms. Neera Malhotra, CIT-DR

Section 143(3)Section 147Section 148Section 40

Deputy Commissioner of Income Tax, C-1(1)(1), Bangalore vs. Algonomy Software Private Limited (Formerly Known As Manthan Software Services Pvt Ltd), Bangalore

ITA 943/BANG/2023[2012-13]Status: DisposedITAT Bangalore19 Jan 2024AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

For Appellant: Shri Narendra Kumar JainFor Respondent: Ms. Neera Malhotra, CIT-DR

Section 143(3)Section 147Section 148Section 40