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

In the result, we allow appeal filed by the assessee

reassessment, because\nof the non obstante clause begins with the said sections. The language used in these\nsections, i.e. 'notwithstanding anything contained' in section 139, section 147, sectior\n148, section 149, section 151

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

reassessment, because\nof the non obstante clause begins with the said sections. The language used in these\nsections, i.e. 'notwithstanding anything contained' in section 139, section 147, sectior\n148, section 149, section 151

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

reassessment, because\nof the non obstante clause begins with the said sections. The language used in these\nsections, i.e. 'notwithstanding anything contained' in section 139, section 147, sectior\n148, section 149, section 151

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

reassessment, because\nof the non obstante clause begins with the said sections. The language used in these\nsections, i.e. 'notwithstanding anything contained' in section 139, section 147, sectior\n148, section 149, section 151

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

reassessment, because\nof the non obstante clause begins with the said sections. The language used in these\nsections, i.e. 'notwithstanding anything contained' in section 139, section 147, sectior\n148, section 149, section 151

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

reassessment orders are also without jurisdiction. Section 282A of the Act, 1961 has no relevance with respect to the recording of satisfaction or prior permission by the PCIT under section 151

M/S. CRYSTAL GRANITE AND MARBLE PRIVATE LIMITED,RAMANAGARAM vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes and Stay Petition is dismissed as infructuous

Bench: Shri George George K & Shri Laxmi Prasad Sahus.P No.29/Bang/2023 Assessment Year: 2017-18

151 (as those provisions existed upto 31-3-2021), stood substituted, along with a new provision enacted by way of section 148A of that Act. In absence of any saving clause, to save the pre-existing (and now substituted) provisions, the assessing officer could only initiate reassessment

M/S. GITA REFRACTORIES PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD- 11(2), BANGALORE

In the result, the second question is answered in favour of the assessee and against the revenue and as a result thereof the appeal fails and dismissed as such

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2005-06

section, it is clear that the issuance of notice u/s 148 of the Act, in the case of reassessment completed u/s 143(3) beyond four years, the CCIT or CIT has power to give approval u/s 151

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time-limit prescribed for completion of an assessment or reassessment

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time-limit prescribed for completion of an assessment or reassessment

SRI RAJESH KUMAR,BANGALORE vs. ACIT, BANGALORE

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadaleassessment Year : 2005-06

reassess the income of the other person in accordance with the provisions of section 153 A , if the Assessing officer……. It is humbly submitted that for the purposes of assessment under section 153C of the Act the procedure adopted should be as envisaged in the provisions of section 153A of the Act. Thus, the entire assessment under section 153C

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

Bench: Shri Chandra Poojari & Shri George George K.

151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time-limit prescribed for completion of an assessment or reassessment

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

Bench: Shri Chandra Poojari & Shri George George K.

151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time-limit prescribed for completion of an assessment or reassessment

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

Bench: Shri Chandra Poojari & Shri George George K.

151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time-limit prescribed for completion of an assessment or reassessment

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

151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section I53A. The time-limit prescribed for completion of an assessment or reassessment

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

151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section I53A. The time-limit prescribed for completion of an assessment or reassessment

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

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time- limit prescribed for completion of an assessment or reassessment

M/S SPR SPIRITS PVT.LTD. ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1 (3) , BENGALURU

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

151 which requires sanction to be obtained by the Assessing Officer by issue of notice to reopen the assessment under Section 148 has also been excluded in a case covered by Section 153A. The time- limit prescribed for completion of an assessment or reassessment