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345 results for “depreciation”+ Section 154(3)clear

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Key Topics

Addition to Income77Section 15475Section 1160Section 143(3)49Disallowance49Section 14A47Section 115J43Depreciation39Deduction33Section 10A

M/S. KARNATAKA POWER CORPORATION LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 11(5) PRESENTLY CIRCLE 4(1)(1), BENGALURU

In the result, the appeal filed by the assessee is partly allowed

ITA 282/BANG/2017[2002 - 2003]Status: DisposedITAT Bangalore11 Jan 2021

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Narendra Sharma, AdvocateFor Respondent: Sri.Kannan Narayanan, JCIT-DR
Section 115JSection 143Section 143(3)Section 154Section 263

154 of the Act, without appreciating that in the guise of rectifying the order dated 20/10/2011, has attempted to rectify already concluded issues in the original order of assessment passed under section 143[3] of the Act dated 10/02/2005, under the facts and circumstances of the case. 5. The learned Commissioner of Income-tax [Appeals] failed to appreciate that

Showing 1–20 of 345 · Page 1 of 18

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27
Section 25025
Section 143(1)24

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeal filed by the Revenue is allowed for statistical purpose

ITA 2400/BANG/2018[2012-13]Status: DisposedITAT Bangalore16 Aug 2022AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahuthe Dy. Commissioner Of Vs Shri C. Gangadhara Murthy Income-Tax, No. 322, 3Rd A Corss, 2Nd Block Circle - 6(2)(1) 3Rd Stage, Basaveshwaranagar Bangalore . Bangalore 560079. Pan – Agipg 2668 N (Appellant) (Respondent)

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Sumer Singh Meena, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 2

depreciation allowance or any other allowance under this Act has been computed." 18. Explanation 2 to above section clearly provides three situations where it is deemed that income has escaped assessment and, therefore, initiation of assessment/reassessment proceedings by issue of notice under section 148(1) would be valid. These situations are :— (i) when return of income is not filed

DINESH KUMAR SINGHI,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2011-12 is partly allowed

ITA 699/BANG/2015[2005-06]Status: DisposedITAT Bangalore10 Apr 2018AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri K.R. Pradeep, C.AFor Respondent: Shri K.V. Arvind, Standing Counsel for Dept
Section 10BSection 132Section 143(3)Section 148Section 153ASection 154

154 (PB-2 page 589) and also proceeding u/s 148 was initiated and the same stands closed in the absence of any further development (PB-2 page 591). The issue of notice u/s 148 was against law and however in the absence of any order the assessee has no grievance to pursue. The assessment came to be concluded u/s 153A

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

ITA 725/BANG/2018[2013-14]Status: DisposedITAT Bangalore31 Jul 2020AY 2013-14

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Percy Pardiwala, Sr. Advocate along with Ajay Roti, C.AFor Respondent: Shri K.V Arvind, Advocate
Section 10ASection 143Section 143(3)Section 144C(1)Section 92C

Section 92CC with the caption “Advance Pricing Agreement” provides through sub-section (1): `The Board, with the approval of the Central Government, may enter into an advance pricing agreement with any person, determining the arm's length price … in relation to an international transaction …’. Sub-section (2) gives the manner of determination of the ALP referred to in sub-section

SHRI. JITENDRA VIRWANI,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

ITA 46/BANG/2021[2002-03]Status: DisposedITAT Bangalore23 Jun 2021AY 2002-03

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, CAFor Respondent: Shri Priyadarshi Mishra, Addl.CIT(DR)(ITAT), Bengaluru
Section 147Section 234DSection 69

154(Bom) = (2010-TIOL-146-HC-MUM- IT) after considering the decision of the Hon'ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Pvt. Ltd. 291 ITR 500 (SC) = (2007-TIOL-95-SC-IT) has held that even when an intimation is issued u/s. 143(1) of the Act, the validity of initiation of reassessment proceedings

SHRI. JITENDRA VIRWANI,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

ITA 47/BANG/2021[2003-04]Status: DisposedITAT Bangalore23 Jun 2021AY 2003-04

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, CAFor Respondent: Shri Priyadarshi Mishra, Addl.CIT(DR)(ITAT), Bengaluru
Section 147Section 234DSection 69

154(Bom) = (2010-TIOL-146-HC-MUM- IT) after considering the decision of the Hon'ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Pvt. Ltd. 291 ITR 500 (SC) = (2007-TIOL-95-SC-IT) has held that even when an intimation is issued u/s. 143(1) of the Act, the validity of initiation of reassessment proceedings

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

154(Bom) = (2010-TIOL-146-HC-MUM- IT) after considering the decision of the Hon'ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Pvt. Ltd. 291 ITR 500 (SC) = (2007-TIOL-95-SC-IT) has held that even when an intimation is issued u/s. 143(1) of the Act, the validity of initiation of reassessment proceedings

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

154(Bom) = (2010-TIOL-146-HC-MUM- IT) after considering the decision of the Hon'ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Pvt. Ltd. 291 ITR 500 (SC) = (2007-TIOL-95-SC-IT) has held that even when an intimation is issued u/s. 143(1) of the Act, the validity of initiation of reassessment proceedings

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 20/BANG/2017[2009-10]Status: DisposedITAT Bangalore21 Jun 2019AY 2009-10

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1216/BANG/2014[2008-09]Status: DisposedITAT Bangalore21 Jun 2019AY 2008-09

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1220/BANG/2014[2012-13]Status: DisposedITAT Bangalore21 Jun 2019AY 2012-13

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 22/BANG/2017[2011-12]Status: DisposedITAT Bangalore21 Jun 2019AY 2011-12

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1217/BANG/2014[2009-10]Status: DisposedITAT Bangalore21 Jun 2019AY 2009-10

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 2338/BANG/2016[2011-12]Status: DisposedITAT Bangalore21 Jun 2019AY 2011-12

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 2328/BANG/2016[2007-08]Status: DisposedITAT Bangalore21 Jun 2019AY 2007-08

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1215/BANG/2014[2007-08]Status: DisposedITAT Bangalore21 Jun 2019AY 2007-08

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1218/BANG/2014[2010-11]Status: DisposedITAT Bangalore21 Jun 2019AY 2010-11

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 2336/BANG/2016[2009-10]Status: DisposedITAT Bangalore21 Jun 2019AY 2009-10

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 19/BANG/2017[2008-09]Status: DisposedITAT Bangalore21 Jun 2019AY 2008-09

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

ITA 2337/BANG/2016[2010-11]Status: DisposedITAT Bangalore21 Jun 2019AY 2010-11

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

3. That the learned CIT(A) has erred in considering the rate of tax as 15% in USA, UK, Austria and Canada and 20% for Spain whereas the rate of tax as per the relevant clause of the respective DTAA is 10%. 4. That the learned CIT(A) has erred in not considering that the order under section 154