MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , MANGALORE

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reassessment and the assessee was asked to explain it but the statement was itself not furnished to the assessee. As such, besides non-furnishing of the reasons for re-opening there was also a gross violation of the principles of natural justice

MOHAMMED IBRABIM MOHIDEEN ,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MANGALURU

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reassessment and the assessee was asked to explain it but the statement was itself not furnished to the assessee. As such, besides non-furnishing of the reasons for re-opening there was also a gross violation of the principles of natural justice

MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeal of the assessee in ITA\nNo

reassessment and the assessee was asked to explain it but the statement was\nitself not furnished to the assessee. As such, besides non-furnishing of the reasons\nfor re-opening there was also a gross violation of the principles of natural justice

NIYAZ SEA FOODS ,MANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , MANGALORE

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reassessment under Section 153C follows lines pari materia with Section 153A. D. The First Proviso to Section 153C introduces a legal fiction on the basis of which the commencement date for computation of the six year or the ten year block is deemed to be the date of receipt of books of accounts by the jurisdictional AO. The identification

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

natural justice and the order of the lower authorities prevails. 17. Before us, ld. A.R. is not able to substantiate how the opportunity of hearing has not been given to the assessee. Hence, this ground of appeal in ITA Nos.982 to 987/Bang/2023 in assessment years 2011-12 to 2016-17 is dismissed. 18. Ground Nos.5

JOHN DISTILLERIES PVT LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

natural justice and the order of the lower authorities prevails. 17. Before us, ld. A.R. is not able to substantiate how the opportunity of hearing has not been given to the assessee. Hence, this ground of appeal in ITA Nos.982 to 987/Bang/2023 in assessment years 2011-12 to 2016-17 is dismissed. 18. Ground Nos.5

JOHN DEVELOPERS ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

natural justice and the order of the lower authorities prevails. 17. Before us, ld. A.R. is not able to substantiate how the opportunity of hearing has not been given to the assessee. Hence, this ground of appeal in ITA Nos.982 to 987/Bang/2023 in assessment years 2011-12 to 2016-17 is dismissed. 18. Ground Nos.5

JOHN DEVELOPERS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

natural justice and the order of the lower authorities prevails. 17. Before us, ld. A.R. is not able to substantiate how the opportunity of hearing has not been given to the assessee. Hence, this ground of appeal in ITA Nos.982 to 987/Bang/2023 in assessment years 2011-12 to 2016-17 is dismissed. 18. Ground Nos.5

M/S. PAUL RESORTS & HOTELS PVT. LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

natural justice and the order of the lower authorities prevails. 17. Before us, ld. A.R. is not able to substantiate how the opportunity of hearing has not been given to the assessee. Hence, this ground of appeal in ITA Nos.982 to 987/Bang/2023 in assessment years 2011-12 to 2016-17 is dismissed. 18. Ground Nos.5

M/S. PAUL RESORTS & HOTELS PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

natural justice and the order of the lower authorities prevails. 17. Before us, ld. A.R. is not able to substantiate how the opportunity of hearing has not been given to the assessee. Hence, this ground of appeal in ITA Nos.982 to 987/Bang/2023 in assessment years 2011-12 to 2016-17 is dismissed. 18. Ground Nos.5

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1) , BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

natural justice and the order of the lower authorities prevails. 17. Before us, ld. A.R. is not able to substantiate how the opportunity of hearing has not been given to the assessee. Hence, this ground of appeal in ITA Nos.982 to 987/Bang/2023 in assessment years 2011-12 to 2016-17 is dismissed. 18. Ground Nos.5

M/S. HARIS MARINE PRODUCTS,MANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALORE

In the result, both the appeals of the assessee are\nallowed

reassessment under Section 153C follows lines pari materia\nwith Section 153A.\nD. The First Proviso to Section 153C introduces a legal\nfiction on the basis of which the commencement date for\ncomputation of the six year or the ten year block is deemed to\nbe the date of receipt of books of accounts by the\njurisdictional AO. The identification

JOHN DISTILLERIES PVT LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

justice: For this proposition, he relied on the\nfollowing judgements:-\n1. Goetze (India) Ltd. vs. Commissioner of Income-tax (2006) 284 ITR 323\n2. Goetz India CIT vs. Text Hundred India Pvt. Ltd. (2013) 351 ITR 57\n3. Fibres & Fabrics International (P) Ltd. vs. ACIT, Circle-11(3),\nBangalore (2013) 33 taxmann.com 90 (Bangalore Trib)\n4. HL Malhotra

M/S. EMIRATES HINDUSTAN BUILDERS AND DEVELOPERS,KERALA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

reassessment under Section 153C follows lines pari materia\nwith Section 153A.\nD. The First Proviso to Section 153C introduces a legal\nfiction on the basis of which the commencement date for\ncomputation of the six year or the ten year block is deemed to\nbe the date of receipt of books of accounts by the\njurisdictional AO. The identification

MKH INFRASTRUCTURE,KERALA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

reassessment under Section 153C follows lines pari materia\nwith Section 153A.\nD. The First Proviso to Section 153C introduces a legal\nfiction on the basis of which the commencement date for\ncomputation of the six year or the ten year block is deemed to\nbe the date of receipt of books of accounts by the\njurisdictional AO. The identification

TABESCO HINDUSTAN INFRA DEVELOPERS PVT LTD.,,KERALA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

reassessment under Section 153C follows lines pari materia\nwith Section 153A.\nD. The First Proviso to Section 153C introduces a legal\nfiction on the basis of which the commencement date for\ncomputation of the six year or the ten year block is deemed to\nbe the date of receipt of books of accounts by the\njurisdictional AO. The identification

TABESCO HINDUSTAN INFRA DEVELOPERS PVT LTD., ,KERALA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , MANGALORE

In the result, appeals of the assessee in ITA Nos

reassessment under Section 153C follows lines pari materia\nwith Section 153A.\nD. The First Proviso to Section 153C introduces a legal\nfiction on the basis of which the commencement date for\ncomputation of the six year or the ten year block is deemed to\nbe the date of receipt of books of accounts by the\njurisdictional AO. The identification

M/S. HARIS MARINE PRODUCTS,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, MANGALORE

In the result, both the appeals of the assessee are\nallowed

reassessment under Section 153C follows lines pari materia\nwith Section 153A.\nD. The First Proviso to Section 153C introduces a legal\nfiction on the basis of which the commencement date for\ncomputation of the six year or the ten year block is deemed to\nbe the date of receipt of books of accounts by the\njurisdictional AO. The identification