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“Section 150(2)”

Section References (mined)Section 150Section 150(2)53 judgments

The decision most relied on for Section 150(2) is 1. S. S. Gadgil v. Lal & Co. (53 ITR 231), cited in 158 judgments on BharatTax.

Leading authorities on Section 150(2)

1. S. S. Gadgil v. Lal & Co.
53 ITR 231 · 1964 · Supreme Court
158
citing judgments

Income-tax assessment proceedings are administrative in nature, not civil disputes or judicial proceedings between contesting parties. Income-tax authorities act as administrative bodies to estimate income and assess tax, and the proper service of notice within the limitation period is foundational for reassessment jurisdiction.

Rajinder Nath v. CIT
120 ITR 14 · 1979 · Supreme Court
56
citing judgments

A 'direction' issued by an appellate or revisional authority under Sections 150(1) or 153(3) of the Income-tax Act must be a specific, clear, and mandatory positive command requiring action, and not merely an observation or finding, to be legally effective.

Bharti Airtel Ltd. v. Add!. Cl'I
43 Taxmann.com 150 · 2014 · High Court
37
citing judgments

Providing corporate guarantee does not constitute an international transaction if it involves no cost to the assessee and has no bearing on profits, income, loss, or assets, even after amendment to Explanation to Section 92B.

M B Traders v. ACIT
132 TTJ 490 · 2010 · ITAT
27
citing judgments

Section 148 notices can be issued at any time for assessments or reassessments made in consequence of or to give effect to any final finding, direction, or order of any higher authority.

PCIT v. Krishna Devi
138 Taxmann.com 150 · 2022 · Supreme Court
24
citing judgments

The Supreme Court rejects revenue's appeal in a case concerning the assessment of income, indicating a procedural aspect or a specific issue of law was affirmed. The case involves scrutiny assessments under Section 143(2) and potentially reassessment under Sections 147/148.

Calcutta in Reliance Jute Industries Ltd. v. Income Tax Officer
150 ITR 643 · 1984 · High Court
23
citing judgments

The Assessing Officer (AO) is not required to refer the valuation to the District Valuation Officer (DVO) if the AO has conducted a detailed inquiry and is satisfied with the cost of construction. Strict adherence to procedural requirements is essential; failure to comply with mandatory conditions renders the assessment based on such non-compliance invalid.

549 (Delhi);\nvi) GookluckAutomobils P. Ltd. v. ACIT
26 Taxmann.com 254 · 2012 · High Court
22
citing judgments

The Delhi High Court decision in Gookluck Automobils P. Ltd. v. ACIT is cited for a proposition, but the provided passages are incomplete and do not reveal the specific holding.

Pavan Morarka v. ACIT-2
136 Taxmann.com 2 · 2022 · High Court
14
citing judgments

The proposition of law for which this case is cited is not clearly ascertainable from the provided passages, as they only list it as a cited case without detailing the specific legal point decided. However, its prominent placement with sections 147, 148, and 132 suggests it relates to reassessment or search and seizure proceedings.

Judgments citing Section 150(2)

The DCIT, Central Circle-1(1), Ahmedabad vs. M/S. Venus Infrastructure & Developers Pvt. Ltd., Ahmedabad

In the result, the appeal of the Revenue is hereby dismissed

ITA 38/AHD/2021[2017-18]Status: DisposedITAT Ahmedabad14 Feb 2024AY 2017-18

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 37 & 38/Ahd/2021 धििाधरणणवध/Asstt. Years: 2008-09 & 2017-18 D.C.I.T, M/S Venus Infrastructure & Central Circle-1(1), Vs. Developers Pvt. Ltd., Ahmedabad 1101 Venus Amadeus, Jodhpur Cross Road, Ahmedabad-380015. Pan: Aahcs6254J (Applicant) (Respondent) Revenue By : Shri Akhilendra Pratap Yadaw Assessee By : Shri Tushar Hemani, Sr. Advocate With Shri Parimalsinh B. Parmar & Shri Vijay Govani A.Rs सुिणाईकीतारीख/Date Of Hearing : 08/02/2024 घोवणाकीतारीख/Date Of Pronouncement: 14/02/2024 आदेश/O R D E R Per Waseem Ahmed: The Captioned Two Appeal Have Been Filed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-11, Ahmedabad, Of Even Dated 20/01/2021 Arising In The Matter Of Assessment Order Passed Under S. 147 R.W.S. 143(3) & 143(3) Of The Income Tax Act 1961 (Here- In-After Referred To As "The Act") Relevant To The Assessment Years 2008-09 & 2017-18. First, We Take Up Ita No. 38/Ahd/2021, An Appeal By The Revenue For Ay 2017-18

For Appellant: ShriFor Respondent: Shri Akhilendra Pratap Yadaw
Section 80Section 80I

r.w.s. 143(3) for various reasons. The relevant findings of the learned CIT(A) read as under: i. Barred by limitation under section 150(2) Act 5.1.7 The appellant submitted that the time limit for issue of notice u/s.148 for the year under consideration i.e. A.Y.2008-09 in the case ... initiated in the case of assessee. However, it has been argued by the appellant that because of the application of section 150(2) of IT Act the aforesaid time limit for issue of notice u/s. 147 of IT Act in J:hej;as_e. of. assessee company was limited upto

The DCIT, Central Circle-1(1), Ahmedabad vs. M/S. Venus Infrastructure & Developers Pvt. Ltd., Ahmedabad

In the result, the appeal of the Revenue is hereby dismissed

ITA 37/AHD/2021[2008-09]Status: DisposedITAT Ahmedabad14 Feb 2024AY 2008-09

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 37 & 38/Ahd/2021 धििाधरणणवध/Asstt. Years: 2008-09 & 2017-18 D.C.I.T, M/S Venus Infrastructure & Central Circle-1(1), Vs. Developers Pvt. Ltd., Ahmedabad 1101 Venus Amadeus, Jodhpur Cross Road, Ahmedabad-380015. Pan: Aahcs6254J (Applicant) (Respondent) Revenue By : Shri Akhilendra Pratap Yadaw Assessee By : Shri Tushar Hemani, Sr. Advocate With Shri Parimalsinh B. Parmar & Shri Vijay Govani A.Rs सुिणाईकीतारीख/Date Of Hearing : 08/02/2024 घोवणाकीतारीख/Date Of Pronouncement: 14/02/2024 आदेश/O R D E R Per Waseem Ahmed: The Captioned Two Appeal Have Been Filed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-11, Ahmedabad, Of Even Dated 20/01/2021 Arising In The Matter Of Assessment Order Passed Under S. 147 R.W.S. 143(3) & 143(3) Of The Income Tax Act 1961 (Here- In-After Referred To As "The Act") Relevant To The Assessment Years 2008-09 & 2017-18. First, We Take Up Ita No. 38/Ahd/2021, An Appeal By The Revenue For Ay 2017-18

For Appellant: ShriFor Respondent: Shri Akhilendra Pratap Yadaw
Section 80Section 80I

r.w.s. 143(3) for various reasons. The relevant findings of the learned CIT(A) read as under: i. Barred by limitation under section 150(2) Act 5.1.7 The appellant submitted that the time limit for issue of notice u/s.148 for the year under consideration i.e. A.Y.2008-09 in the case ... initiated in the case of assessee. However, it has been argued by the appellant that because of the application of section 150(2) of IT Act the aforesaid time limit for issue of notice u/s. 147 of IT Act in J:hej;as_e. of. assessee company was limited upto