INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

reassessment under the Income-tax Act, and the time limit for completion of such action under section 153 or section 1538 thereof,\n(i) expires on the 31st day of March, 2021 due to its extension by the said notification, such time limit shall stand extended to the 30th day of April, 2021;\nPage 13

M/S. ACER INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, both the appeals of the assessee are partly allowed

Bench: Shri B.R Baskaran & Shri Pavan Kumar Gadale

13) Due date for passing final assessment order u/s 153(1) r.w.s 3rd proviso to the said 31.03.2012 section. 6. To adjudicate the addition ground, the relevant statutory provisions have to be seen. IT(TP)A Nos.502 & 2837/Bang/2017 Page 5 of 45 Time limit for completion of assessments and reassessments

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

13……………………………………………………………………………… ………………………………………………………………………may be noted above that under the first proviso to the newly substituted section 143(1), with effect from June 1, 1999, except as provided in the provision itself, the acknowledgment of the return shall be deemed to be an intimation under section 143(1) where (a) either no sum is payable by the assessee, or (b) no refund

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

13……………………………………………………………………………… ………………………………………………………………………may be noted above that under the first proviso to the newly substituted section 143(1), with effect from June 1, 1999, except as provided in the provision itself, the acknowledgment of the return shall be deemed to be an intimation under section 143(1) where (a) either no sum is payable by the assessee, or (b) no refund

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

13……………………………………………………………………………… ………………………………………………………………………may be noted above that under the first proviso to the newly substituted section 143(1), with effect from June 1, 1999, except as provided in the provision itself, the acknowledgment of the return shall be deemed to be an intimation under section 143(1) where (a) either no sum is payable by the assessee, or (b) no refund

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

13……………………………………………………………………………… ………………………………………………………………………may be noted above that under the first proviso to the newly substituted section 143(1), with effect from June 1, 1999, except as provided in the provision itself, the acknowledgment of the return shall be deemed to be an intimation under section 143(1) where (a) either no sum is payable by the assessee, or (b) no refund

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

13……………………………………………………………………………… ………………………………………………………………………may be noted above that under the first proviso to the newly substituted section 143(1), with effect from June 1, 1999, except as provided in the provision itself, the acknowledgment of the return shall be deemed to be an intimation under section 143(1) where (a) either no sum is payable by the assessee, or (b) no refund

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings IBM Deutschland 501/Bang/2024 During re- 2012- GMBH ("IBM 271(1)(c) Not filed assessment 13

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings IBM Deutschland 501/Bang/2024 During re- 2012- GMBH ("IBM 271(1)(c) Not filed assessment 13

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings IBM Deutschland 501/Bang/2024 During re- 2012- GMBH ("IBM 271(1)(c) Not filed assessment 13

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings IBM Deutschland 501/Bang/2024 During re- 2012- GMBH ("IBM 271(1)(c) Not filed assessment 13

SHRI M. THIMMEGOWDA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess' to complete assessment proceedings. (vi) Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under section 153A merges into one. Only one assessment shall be made separately for each assessment year on the basis of the findings of the search and any other material existing or brought on the record

SHRI M. THIMMEGOWDA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess' to complete assessment proceedings. (vi) Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under section 153A merges into one. Only one assessment shall be made separately for each assessment year on the basis of the findings of the search and any other material existing or brought on the record

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

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

13 of 73 was held therein that for the AYs 2001 to 2003-04 no additions can be made in an assessment made u/s 153A if there is no incriminating material. This proposition has been accepted by the Supreme Court by dismissing the SLP. 24. The ld. AR also relied on the Co-ordinate Bench decision of the Tribunal

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

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

13 of 73 was held therein that for the AYs 2001 to 2003-04 no additions can be made in an assessment made u/s 153A if there is no incriminating material. This proposition has been accepted by the Supreme Court by dismissing the SLP. 24. The ld. AR also relied on the Co-ordinate Bench decision of the Tribunal

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

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

13 of 73 was held therein that for the AYs 2001 to 2003-04 no additions can be made in an assessment made u/s 153A if there is no incriminating material. This proposition has been accepted by the Supreme Court by dismissing the SLP. 24. The ld. AR also relied on the Co-ordinate Bench decision of the Tribunal

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

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

13 of 73 was held therein that for the AYs 2001 to 2003-04 no additions can be made in an assessment made u/s 153A if there is no incriminating material. This proposition has been accepted by the Supreme Court by dismissing the SLP. 24. The ld. AR also relied on the Co-ordinate Bench decision of the Tribunal

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

In the result, the appeals by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri George George K.

13 of 73 was held therein that for the AYs 2001 to 2003-04 no additions can be made in an assessment made u/s 153A if there is no incriminating material. This proposition has been accepted by the Supreme Court by dismissing the SLP. 24. The ld. AR also relied on the Co-ordinate Bench decision of the Tribunal