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.

reassess income of such other person in accordance with the provisions of Section 153A.” ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore Page 45 of 115 10.2. Thus, the scope of provisions of section 153A of the Act could be summarized as follows: Scenario Scope of Section 153A 1

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.

reassessment can be made. The relevant extract is reproduced below:- “The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 196 is as under : (i) Once a search takes place under section 132, notice under section 153A(1

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.

reassessment can be made. The relevant extract is reproduced below:- “The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 196 is as under : (i) Once a search takes place under section 132, notice under section 153A(1

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.

reassessment can be made. The relevant extract is reproduced below:- “The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 196 is as under : (i) Once a search takes place under section 132, notice under section 153A(1

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.

reassessment can be made. The relevant extract is reproduced below:- “The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 196 is as under : (i) Once a search takes place under section 132, notice under section 153A(1

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.

reassessment can be made. The relevant extract is reproduced below:- “The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 196 is as under : (i) Once a search takes place under section 132, notice under section 153A(1

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.

reassessment can be made. The relevant extract is reproduced below:- “The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 196 is as under : (i) Once a search takes place under section 132, notice under section 153A(1

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.

reassessment can be made. The relevant extract is reproduced below:- “The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 196 is as under : (i) Once a search takes place under section 132, notice under section 153A(1

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

reassess the total income for those assessment years. The second proviso to Section 153A provides for abatement of assessment/reassessment proceedings which are pending on the date of search/requisition. Section 153A(2) provides that when the assessment made under Section 153(A)(1

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

reassess the total income for those assessment years. The second proviso to Section 153A provides for abatement of assessment/reassessment proceedings which are pending on the date of search/requisition. Section 153A(2) provides that when the assessment made under Section 153(A)(1

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

reassess the total income for those assessment years. The second proviso to Section 153A provides for abatement of assessment/reassessment proceedings which are pending on the date of search/requisition. Section 153A(2) provides that when the assessment made under Section 153(A)(1

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

reassess the total income for those assessment years. The second proviso to Section 153A provides for abatement of assessment/reassessment proceedings which are pending on the date of search/requisition. Section 153A(2) provides that when the assessment made under Section 153(A)(1

M/S. SPR SPIRITS PRIVATE LIMITED (FORMERLY KNOWN AS SPR GROUP HOLDINGS PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, assessee’s appeal in ITA No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess the total income for those assessment years. The second proviso to Section 153A provides for abatement of assessment/reassessment proceedings which are pending on the date of search/requisition. Section 153A(2) provides that when the assessment made under Section 153(A)(1

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

reassess the total income for those assessment years. The second proviso to Section 153A provides for abatement of assessment/reassessment proceedings which are pending on the date of search/requisition. Section 153A(2) provides that when the assessment made under Section 153(A)(1

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

reassessment can be made. The relevant extract is reproduced below:- “The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 196 is as under : (i) Once a search takes place under section 132, notice under section 153A(1

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

reassessment can be made. The relevant extract is reproduced below:- “The legal position that emerges on a perusal of section 153A and section 132 of the Income-tax Act, 196 is as under : (i) Once a search takes place under section 132, notice under section 153A(1

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

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

reassess the total income of six assessment years falling\nwithin the period of those six assessment years immediately preceding the assessment\nyear in which search is conducted. Under the new provisions of section 153A, the\nstatute is provides wide powers to the Assessing Officer in respect of assessments\nalready completed u/s 143(1