DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE vs. MR. D K SHIVAKUMAR, BANGALORE

Section 148 shall give way to\nSection 153C. There is a reason for saying so because if a notice u/s.153C is issued to\nhe third party (assessee), then the AO may assess or reassess

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE vs. MR. D K SHIVAKUMAR, BANGALORE

In the result, we allow appeal filed by the assessee

Section 148 shall give way to\nSection 153C. There is a reason for saying so because if a notice u/s.153C is issued to\nhe third party (assessee), then the AO may assess or reassess

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE vs. MR. D K SHIVAKUMAR, BANGALORE

In the result, we allow appeal filed by the assessee

Section 148 shall give way to\nSection 153C. There is a reason for saying so because if a notice u/s.153C is issued to\nhe third party (assessee), then the AO may assess or reassess

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE vs. MR. D K SHIVAKUMAR, BANGALORE

Section 148 shall give way to\nSection 153C. There is a reason for saying so because if a notice u/s.153C is issued to\nhe third party (assessee), then the AO may assess or reassess

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

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

Section 148. Issue of notice where income has escaped assessment.—(1) Before making the assessment, reassessment or recomputation under section

RAHUL MEKA ,BENGALURU vs. INCOME TAX OFFICER, WARD INTERNATIONAL TAXATION-1(2) , BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Section 148 - to issue a reassessment notice. 80. In Ashish Agarwal (supra), this Court directed that Section 148 notices which

THAYAPPA BALAKRISHNA,BANGALORE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-1, BENGALURU

In the result, the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2014-15 Shri Thayappa Balakrishna, No. 987, 11Th Main, The Principal 1St Block, Commissioner Of 3Rd Stage, Income-Tax, Basaveshwaranagar, Bengaluru – 1. Vs. Bangalore – 560 079. Pan: Abdpb4893N Appellant Respondent : Shri Ravi Shankar .S.V, Assessee By Advocate Revenue By : Shri D.K. Mishra, Cit-Dr

section 148 to assess or reassess the income which has escaped assessment only after sub-section (2) of section 148

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

reassessment proceedings − Category C: 271(1)(c) case where original return under section 139(1) of the Act has been filed however, secondment related receipts were offered to tax only in the return filed under section 148

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

reassessment proceedings − Category C: 271(1)(c) case where original return under section 139(1) of the Act has been filed however, secondment related receipts were offered to tax only in the return filed under section 148

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

reassessment proceedings − Category C: 271(1)(c) case where original return under section 139(1) of the Act has been filed however, secondment related receipts were offered to tax only in the return filed under section 148

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

reassessment proceedings − Category C: 271(1)(c) case where original return under section 139(1) of the Act has been filed however, secondment related receipts were offered to tax only in the return filed under section 148

NEETA BHAMBHANI,BENGALURU vs. DCIT, (IT), CIRCLE-1(1), BENGALURU

In the result, I pass the following:-

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 148 of the Act dt: 10/04/2024 is barred by limitation and the reassessment proceedings to deserves to be quashed

ARUN DURAISWAMY,MYSORE, KARNATAKA vs. ITO, INTL. TAXATION WARD 1(1), BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

148 of the new regime only if three years or less have elapsed from the end of the relevant assessment year; (iii) the proviso to Section 149(1)(b) of the new regime stipulates that the Revenue can issue reassessment

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

reassess the income in respect of any\nissue, which has escaped assessment, and such issue has come to the notice\nsubsequently in the course of proceedings under this section,\nnotwithstanding that the reasons for such issue have not been included in\nthe reasons recorded under such Section 2 of Section 148

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

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

reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, notwithstanding that the reasons for such issue have not been included in the reasons recorded under sub-section (2) of section 148

PAKARAHALLI NARAYANAPPA SRINIVASGOWDA ,BANGALORE vs. INCOME TAX OFFICER, WARD-6(3)(1), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2016-17

148 of the Act and the consequent reassessment proceedings are barred by limitation. Accordingly, the reassessment proceedings initiated in the present case are liable to be quashed. Therefore, the reassessment order passed under section

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, appeals filed by the assessee are partly allowed in above\nterms

reassess the income in respect of any\nissue, which has escaped assessment, and such issue has come to the notice\nsubsequently in the course of proceedings under this section,\nnotwithstanding that the reasons for such issue have not been included in\nthe reasons recorded under such Section 2 of Section 148

SAIKAT CHINMAY BHATTACHARYA,MUMBAI vs. DY. CIT, INTERNATIONAL TAXATION, CIRCLE 1(1), BANGALORE

In the result the appeal filed by the assessee is allowed

Section 148 of the\nI.T.Act on 01.04.2022, beyond the period of limitation and the same has already\nbeen held not to be permissible by the Apex Court in Rajeev Bansal's case (supra),\nwhich reads as under:-\n\"19(e). The Finance Act, ([2021]) 431 ITR (St.) 52) substituted the old regime\nfor reassessment