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

In the result the appeal filed by the assessee is allowed

sections 147 to 151 of the old law ceased to operate from April 1,\n2021; (iii) after April 1, 2021, any reference to the Income Tax Act means the\nIncome Tax Act as amended by the Finance Act 2021; (iv) the time limits\nprescribed for issuing reassessment

RAGHAVAN NAMBATH MENON,BENGALURU vs. ITO, WARD INTL. TAXATION 1(2), BMTC BUILDING, KORAMANGALA, BENGALURU

In the result, I pass the following:-

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

reassessment notices for past assessment years only if the time limit survives according to Section 149(1)(b) of the old regime, that is, six years from the end of the relevant assessment year; and (iv) all notices issued invoking the time limit under section 149(1)(b) of the old regime will have to be dropped if the income

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

1) Notwithstanding anything contained in section 139, section 147,\nsection 148, section 149, section 151 and section 153, in the case of a\nperson where a search is initiated under section 132 or books of account,\nother documents or any assets are requisitioned under section 132A after\nthe 31st day of May, 2003, the Assessing Officer shall

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

1) Notwithstanding anything contained in section 139, section 147,\nsection 148, section 149, section 151 and section 153, in the case of a\nperson where a search is initiated under section 132 or books of account,\nother documents or any assets are requisitioned under section 132A after\nthe 31st day of May, 2003, the Assessing Officer shall

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

1) Notwithstanding anything contained in section 139, section 147,\nsection 148, section 149, section 151 and section 153, in the case of a\nperson where a search is initiated under section 132 or books of account,\nother documents or any assets are requisitioned under section 132A after\nthe 31st day of May, 2003, the Assessing Officer shall

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

1) Notwithstanding anything contained in section 139, section 147,\nsection 148, section 149, section 151 and section 153, in the case of a\nperson where a search is initiated under section 132 or books of account,\nother documents or any assets are requisitioned under section 132A after\nthe 31st day of May, 2003, the Assessing Officer shall

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

1 April 2021, the prior approval must be obtained IT(IT)A No.813/Bang/2024 Page 18 of 24 from the appropriate authorities specified under section 151 of the new regime. The effect of Section 151 of the new regime is thus: (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment

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

1) Notwithstanding anything contained in section 139, section 147, section 148, section. 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized orrequisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information. contained therein

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

1) Notwithstanding anything contained in section 139, section 147,\nsection 148, section 149, section 151 and section 153, in the case of a\nperson where a search is initiated under section 132 or books of account,\nother documents or any assets are requisitioned under section 132A after\nthe 31st day of May, 2003, the Assessing Officer shall

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A of the Act, it is evident that for the purposes of computing

M/S SYNDICATE BANK,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, UDUPI

In the result, appeal of the revenue in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A of the Act, it is evident that for the purposes of computing

THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU vs. M/S. BLUELINE FOODS (INDIA) PVT. LTD.,, MANGALURU

reassessment\nunder section 148 of the Act, material or evidence relatable to the\ndocuments for which the requisition had been sent under section 132A\ncould not be taken into consideration.”\nThe learned Departmental Representative filed copies of warrant of\nauthorization under section 132 of the Act dated 29-10-2004 which\nare issued in the name of K. M. Shah

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

reassess total income of such other person of such assessment year in the manner provided in section 153-A." Section 153C of the act after being amended by Finance Act, 2015 reads thus:— 153C. Assessment of income of any other person.—(1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

reassess total income of such other person of such assessment year in the manner provided in section 153-A." Section 153C of the act after being amended by Finance Act, 2015 reads thus:— 153C. Assessment of income of any other person.—(1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

Accordingly, the appeals filed by the assessee are allowed in above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

reassess total income of such other person of such assessment year in the manner provided in section 153-A." Section 153C of the act after being amended by Finance Act, 2015 reads thus:— 153C. Assessment of income of any other person.—(1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151

DANDU JOJAPPA FRANCIS,BANGALORE vs. INCOME TAX OFFICER, WARD-4(2)(3), BENGALURU

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2016-17

1 April 2021, the prior approval must be obtained from the appropriate authorities specified under Section 151 of the new regime. The effect of Section 151 of the new regime is thus: Page 16 of 21 (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment

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 proceeding on or after 1

M/S. EAGLE TRADERS & LOGISTICS,BELLARY vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(3), BANGALORE

reassess total\nincome of such other person of such assessment year in the manner provided in\nsection 153-A.\"\nSection 153C of the act after being amended by Finance Act, 2015 reads thus:—\n153C. Assessment of income of any other person.—(1) Notwithstanding anything\ncontained in section 139, section 147, section 148, section 149, section 151