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501 results for “reassessment”+ Section 10(38)clear

Sorted by relevance

Delhi1,964 Mumbai1,690 Chennai580 Bangalore501 Jaipur464 Ahmedabad371 Hyderabad336 Kolkata300 Chandigarh205 Pune164 Surat159 Indore146 Raipur142 Amritsar115 Cochin85 Rajkot83 Visakhapatnam79 Karnataka57 Patna56 Nagpur55 Lucknow54 Agra50 Telangana47 Cuttack43 Allahabad41 Guwahati39 Jodhpur34 Dehradun33 SC19 Ranchi16 Jabalpur8 Calcutta8 Kerala6 Orissa6 A.K. SIKRI ROHINTON FALI NARIMAN3 Rajasthan3 Varanasi3 Panaji3 Gauhati2 Uttarakhand1

Key Topics

Addition to Income79 Section 153A67 Section 153C66 Section 143(3)59 Section 14857 Section 13248 Section 14A36 Disallowance32 Section 14729 Section 133A

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

ITA 66/BANG/2024[2015-16]Status: DisposedITAT Bangalore07 May 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore

Section 10(38)Section 143(3)Section 144CSection 147Section 147rSection 148Section 151Section 153Section 153CSection 250

Showing 1–20 of 501 · Page 1 of 26

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25

Reopening of Assessment17

10(38) of the Act and this capital gain has been earned by sale of share as penny stock. After recording of reasons and taking necessary approval from the competent authorities as per extended date by the CBDT, the approval was granted and notice under section 148 of the Act was issued to the assessee. The assessee furnished reply

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

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

In the result, appeal of the assessee in ITA

ITA 1165/BANG/2023[2015-16]Status: DisposedITAT Bangalore10 Jun 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 115BSection 132(4)Section 250Section 69B

10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under

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

In the result, appeal of the assessee in ITA

ITA 1163/BANG/2023[2013-14]Status: DisposedITAT Bangalore10 Jun 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 115BSection 132(4)Section 250Section 69B

10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under

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

In the result, appeal of the assessee in ITA

ITA 1156/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 115BSection 132(4)Section 250Section 69B

10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under

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

In the result, appeal of the assessee in ITA

ITA 1164/BANG/2023[2014-15]Status: DisposedITAT Bangalore10 Jun 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 115BSection 132(4)Section 250Section 69B

10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under

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

In the result, appeal of the assessee in ITA

ITA 1166/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 115BSection 132(4)Section 250Section 69B

10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under

M/S. RAJESH EXPORTS LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), BENGALURU

In the result, all these seven appeals are partly allowed in the terms indicated above

ITA 931/BANG/2017[2008 - 09]Status: DisposedITAT Bangalore27 Nov 2018

Bench: Shri Sunil Kumar Yadav & Shri A. K. Garodia

For Appellant: Shri. Rajesh Mehta, Director

Section 10Section 10ASection 132(1)Section 153Section 153ASection 1O

10 that during the search, registers containing details of ICDs given by the assessee to various parties against collateral in the form of property at varying rates of interest was seized and the assessee was not offering interest on all these ICDs on accrual basis. Hence, it is not acceptable that no incriminating material was found and therefore, we find

M/S RAJESH EXPORTS LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(2), BANGALORE

In the result, all these seven appeals are partly allowed in the terms indicated above

ITA 928/BANG/2017[2009-10]Status: DisposedITAT Bangalore27 Nov 2018AY 2009-10

Bench: Shri Sunil Kumar Yadav & Shri A. K. Garodia

For Appellant: Shri. Rajesh Mehta, Director

Section 10Section 10ASection 132(1)Section 153Section 153ASection 1O

10 that during the search, registers containing details of ICDs given by the assessee to various parties against collateral in the form of property at varying rates of interest was seized and the assessee was not offering interest on all these ICDs on accrual basis. Hence, it is not acceptable that no incriminating material was found and therefore, we find

M/S RAJESH EXPORTS LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(2), BANGALORE

In the result, all these seven appeals are partly allowed in the terms indicated above

ITA 930/BANG/2017[2011-12]Status: DisposedITAT Bangalore27 Nov 2018AY 2011-12

Bench: Shri Sunil Kumar Yadav & Shri A. K. Garodia

For Appellant: Shri. Rajesh Mehta, Director

Section 10Section 10ASection 132(1)Section 153Section 153ASection 1O

10 that during the search, registers containing details of ICDs given by the assessee to various parties against collateral in the form of property at varying rates of interest was seized and the assessee was not offering interest on all these ICDs on accrual basis. Hence, it is not acceptable that no incriminating material was found and therefore, we find

M/S RAJESH EXPORTS LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(2), BANGALORE , BANGALORE

In the result, all these seven appeals are partly allowed in the terms indicated above

ITA 174/BANG/2018[2012-13]Status: DisposedITAT Bangalore27 Nov 2018AY 2012-13

Bench: Shri Sunil Kumar Yadav & Shri A. K. Garodia

For Appellant: Shri. Rajesh Mehta, Director

Section 10Section 10ASection 132(1)Section 153Section 153ASection 1O

10 that during the search, registers containing details of ICDs given by the assessee to various parties against collateral in the form of property at varying rates of interest was seized and the assessee was not offering interest on all these ICDs on accrual basis. Hence, it is not acceptable that no incriminating material was found and therefore, we find

M/S RAJESH EXPORTS LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(2), BANGALORE

In the result, all these seven appeals are partly allowed in the terms indicated above

ITA 929/BANG/2017[2010-11]Status: DisposedITAT Bangalore27 Nov 2018AY 2010-11

Bench: Shri Sunil Kumar Yadav & Shri A. K. Garodia

For Appellant: Shri. Rajesh Mehta, Director

Section 10Section 10ASection 132(1)Section 153Section 153ASection 1O

10 that during the search, registers containing details of ICDs given by the assessee to various parties against collateral in the form of property at varying rates of interest was seized and the assessee was not offering interest on all these ICDs on accrual basis. Hence, it is not acceptable that no incriminating material was found and therefore, we find

M/S RAJESH EXPORTS LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(2), BANGALORE

In the result, all these seven appeals are partly allowed in the terms indicated above

ITA 175/BANG/2018[2013-14]Status: DisposedITAT Bangalore27 Nov 2018AY 2013-14

Bench: Shri Sunil Kumar Yadav & Shri A. K. Garodia

For Appellant: Shri. Rajesh Mehta, Director

Section 10Section 10ASection 132(1)Section 153Section 153ASection 1O

10 that during the search, registers containing details of ICDs given by the assessee to various parties against collateral in the form of property at varying rates of interest was seized and the assessee was not offering interest on all these ICDs on accrual basis. Hence, it is not acceptable that no incriminating material was found and therefore, we find

M/S RAJESH EXPORTS LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(2), BANGALORE

In the result, all these seven appeals are partly allowed in the terms indicated above

ITA 176/BANG/2018[2014-15]Status: DisposedITAT Bangalore27 Nov 2018AY 2014-15

Bench: Shri Sunil Kumar Yadav & Shri A. K. Garodia

For Appellant: Shri. Rajesh Mehta, Director

Section 10Section 10ASection 132(1)Section 153Section 153ASection 1O

10 that during the search, registers containing details of ICDs given by the assessee to various parties against collateral in the form of property at varying rates of interest was seized and the assessee was not offering interest on all these ICDs on accrual basis. Hence, it is not acceptable that no incriminating material was found and therefore, we find

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

In the result, the appeal filed by the Revenue is allowed

ITA 1666/BANG/2024[2017-18]Status: HeardITAT Bangalore30 Dec 2024AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

For Appellant: Ms. Neera Malhotra CIT-D.RFor Respondent: Sri Prakash Shridhar Hegde, CA

Section 11Section 11(6)Section 250Section 270ASection 274

38,920/- [ Rs.55,56,54,057/- (revenue expenditure) + Rs. 8,11,20,826/- (capital expenditure)] which amounts to claim of double deduction & the same is accepted by the assessee on the I. Tax web portal. It is worthwhile here to note that once the Auditor uploads the audit report on the I. Tax Web Portal from his professional

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 497/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceedings. the aspect of ‘reasonable cause”. IBM - Reference to Explanation 3 to section foreign entities had reasonable cause to 271(1)(c) of the Act was upheld not offer the receipts to tax in the return under section 139 of the Act basis: - (Page 10-11 of the CIT(A)’s order) IBM Corp’s assessment order

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 544/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceedings. the aspect of ‘reasonable cause”. IBM - Reference to Explanation 3 to section foreign entities had reasonable cause to 271(1)(c) of the Act was upheld not offer the receipts to tax in the return under section 139 of the Act basis: - (Page 10-11 of the CIT(A)’s order) IBM Corp’s assessment order

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 499/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceedings. the aspect of ‘reasonable cause”. IBM - Reference to Explanation 3 to section foreign entities had reasonable cause to 271(1)(c) of the Act was upheld not offer the receipts to tax in the return under section 139 of the Act basis: - (Page 10-11 of the CIT(A)’s order) IBM Corp’s assessment order

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 496/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment proceedings. the aspect of ‘reasonable cause”. IBM - Reference to Explanation 3 to section foreign entities had reasonable cause to 271(1)(c) of the Act was upheld not offer the receipts to tax in the return under section 139 of the Act basis: - (Page 10-11 of the CIT(A)’s order) IBM Corp’s assessment order

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

ITA 109/BANG/2022[2018-19]Status: DisposedITAT Bangalore14 Nov 2022AY 2018-19

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri A. Shankar, Senior AdvocateFor Respondent: Shri Manjunath Karkihalli, D.R

10. Section 153A of the Act starts with a non obstante clause. The fetters imposed upon the Assessing Officer by the strict procedure to assume jurisdiction to reopen the assessment under Sections 147 and 148, have been removed by the non obstante clause with which sub section (1) of Section 153A opens. The time-limit within which the notice under