M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

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

disallowance made by the Learned AO under Section\n14A without recording the satisfaction is bad and invalid.\n\n7.\nBased on the above submissions, it is humbly prayed that the\nimpugned order for AY 2017-18 may be quashed.\n\n Assessment Years 2018-19 to 2020-21:\n\n1.\nIt is submitted that the Assessee's Appeal

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved.” 12.4 The ld. A.R. submitted that the ld. Commissioner of Income Tax (Appeals) has basically

INCOME TAX OFFICER, W-1, VIJAYANAGAR vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved.” 12.4 The ld. A.R. submitted that the ld. Commissioner of Income Tax (Appeals) has basically

INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved.” 12.4 The ld. A.R. submitted that the ld. Commissioner of Income Tax (Appeals) has basically

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved.” 12.4 The ld. A.R. submitted that the ld. Commissioner of Income Tax (Appeals) has basically

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved.” 12.4 The ld. A.R. submitted that the ld. Commissioner of Income Tax (Appeals) has basically

M/S MSPL LIMITED,MUMBAI vs. ACIT, BANGALORE

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2005-06

132A, as the case may be, shall abate. Sub-section (2) of section 153A of the Act provides that if any proceeding or any order of assessment or reassessment made under sub-section (1) is annulled in appeal or any other legal provision, then the assessment or reassessment relating to any assessment year which had abated under the second proviso

MOHAMMED MUJEEB SIKANDER,MANGALORE vs. DCIT, CENTRAL CIRCLE (1), MANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

132A, the same shall abate. In terms of Sec.153C of the Act, if in the course of search of a person u/s.132 of the Act, any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person who is searched u/s.132

MOHAMMED MUJEEB SIKANDER,MANGALORE vs. DCIT, CENTRAL CIRCLE (1), MANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

132A, the same shall abate. In terms of Sec.153C of the Act, if in the course of search of a person u/s.132 of the Act, any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person who is searched u/s.132

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

disallowance of “building under construction” expenses—\nwere made contrary to the facts on record, showing that even the\napproving authority had not noticed the basic accounting treatment.\n17.7 The ld. AR relied on several judicial precedents to support his\nargument that mechanical approval under section 153D of the Act\ninvalidates the assessment. He cited the decision

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

disallowed after recording the statement and declaring in the statement the assessee has not retracted with the separate statement before the investigation wing. These expenditures are lump sum taken in the nature of annuity. Therefore, assessment has been rightly framed by the AO. The learned CIT(A) has also rightly dismissed. 13. Considering the rival submissions and perusing the entire

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

disallowed after recording the statement and declaring in the statement the assessee has not retracted with the separate statement before the investigation wing. These expenditures are lump sum taken in the nature of annuity. Therefore, assessment has been rightly framed by the AO. The learned CIT(A) has also rightly dismissed. 13. Considering the rival submissions and perusing the entire

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

disallowed after recording the statement and declaring in the statement the assessee has not retracted with the separate statement before the investigation wing. These expenditures are lump sum taken in the nature of annuity. Therefore, assessment has been rightly framed by the AO. The learned CIT(A) has also rightly dismissed. 13. Considering the rival submissions and perusing the entire

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

disallowed after recording the statement and declaring in the statement the assessee has not retracted with the separate statement before the investigation wing. These expenditures are lump sum taken in the nature of annuity. Therefore, assessment has been rightly framed by the AO. The learned CIT(A) has also rightly dismissed. 13. Considering the rival submissions and perusing the entire

M/S. H. M. CONSTRUCTIONS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL RANGE - 1(4), BANGALORE

In the result, appeals being ITA Nos

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

132A in the second proviso to sub- section (1) of section 153A shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person.” 16. From the above, it is seen that the jurisdictional conditions and circumstances prescribed by the legislature

M/S. H. M. CONSTRUCTIONS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL RANGE - 1(4), BANGALORE

In the result, appeals being ITA Nos

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

132A in the second proviso to sub- section (1) of section 153A shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person.” 16. From the above, it is seen that the jurisdictional conditions and circumstances prescribed by the legislature

M/S. H. M. CONSTRUCTIONS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL RANGE - 1(4), BANGALORE

In the result, appeals being ITA Nos

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

132A in the second proviso to sub- section (1) of section 153A shall be construed as reference to the date of receiving the books of account or documents or assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person.” 16. From the above, it is seen that the jurisdictional conditions and circumstances prescribed by the legislature