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14 results for “reassessment”+ Section 194Cclear

Sorted by relevance

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Key Topics

Section 40A(3)27Section 14814Section 143(3)13Section 4013Section 36(1)(viia)10Addition to Income10Section 1479Disallowance9Section 194C8Section 36(1)(vii)

THE JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-4 , BANGALORE vs. M/S MPHASIS LIMITED , BANGALORE

In the result, both the appeals are dismissed

ITA 3418/BANG/2018[2009-10]Status: DisposedITAT Bangalore03 Jun 2020AY 2009-10

Bench: Shri N.V. Vasudevan & Shri B R Baskaranassessment Year: 2009-10

For Appellant: Shri Pradeep Kumar, CIT(DR)(ITAT), BengaluruFor Respondent: Shri Padam Chand Khincha, CA
Section 10ASection 143(3)Section 147Section 148Section 195Section 40

reassessment order passed by the learned AO under section 143(3) read with section 147 be quashed or in the alternative, the disallowance confirmed under section 40(a)(i) be deleted, payments made to AEs be held as not liable TDS under section 195 and interest levied under section 234B and 234C be deleted. The appellant prays accordingly

7
TDS7
Deduction6

M H SUDHARSHAN REDDY ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE

In the result, appeal of the assessee is allowed

ITA 1169/BANG/2018[2008-09]Status: DisposedITAT Bangalore12 Aug 2020AY 2008-09

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadaleshri M H Sudharshan Reddy, 20, 1St H Cross, 8Th Main, S S Layout, Shardha Colony, Basaveshwaranagar, Bangalore-560 079 ….Appellant. Pan Alips 3131M Vs. Dy. Commissioner Of Income Tax, Circle 6(2)(1), Bangalore. ……Respondent. Assessee By: Shri R. Chandrashekar, Advocate. Revenue By: Shri Priyadarshi Misra, Jcit (D.R.)

For Appellant: Shri R. Chandrashekar, AdvocateFor Respondent: Shri Priyadarshi Misra, JCIT (D.R.)
Section 143(2)Section 143(3)Section 147Section 194CSection 194H

reassessment proceedings, the Assessing Officer observed that the assessee has debited commission charges, land development cost and hire charges without deduction of tax and the payments exceeds the specified amounts under Section 194C

SRI. K. SATISH KUMAR,BENGALURU vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE-9, BANGALORE

In the result, the assessee’s appeal is allowed

ITA 1988/BANG/2016[2007-08]Status: DisposedITAT Bangalore01 Aug 2022AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2007-08

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Dr. Manjunath Karkihalli, D.R
Section 133A(1)Section 143(3)Section 234Section 234A

194C. Once the provisions of sec.194C is involved, all these payments can also be disallowed u/s 40(a)(ia) of the Act. This line of action is not considered by the AO. The disallowance made by the AO is based on documents found during the survey. Therefore, the view of the appellant that disallowances were made on surmise, assumption

BASAVA ROAWAYS (INDIA) PVT. LTD,SEDAM vs. INCOME TAX OFFICER, WARD-1, GULBARGA, GULBARGA

In the result, the appeal of assessee is hereby partly allowed for statistical purposes

ITA 565/BANG/2025[2013-14]Status: DisposedITAT Bangalore12 Mar 2026AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2013-14

For Appellant: Shri Rajkumar Hanchal, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 142(1)Section 144Section 147Section 148Section 148ASection 194ASection 194CSection 250

Section Amount (Rs.) Ultratech Cement 194C 12,41,23,184 Vasavadatta Cement 194C 5,68,01,670 . ITA No.565 /Bang/2025 Page 3 of 16 Total 18,09,24,854 6. Considering the above receipts of Rs. 18,09,24,854 reflected in Form 26AS, the AO proceeded to estimate the income of the assessee by applying a profit rate

UNITED BREWERIES LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-7(1)(1), BENGALURU

ITA 2569/BANG/2017[2013-14]Status: DisposedITAT Bangalore01 Jun 2022AY 2013-14

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92Section 92B(1)

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. 6.2.4 Accordingly, it was proposed to the assessee that the disallowance u/s 14A will be made by invoking

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

In the result, appeal of the revenue in ITA No

ITA 1219/BANG/2019[2015-16]Status: DisposedITAT Bangalore08 Aug 2024AY 2015-16

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

For Appellant: Shri S. Ananthan, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115JSection 36(1)(vii)Section 36(1)(viia)

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

MUNIYAPPA MUNIRAJU ,BENGALURU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-2, BENGALURU

In the result, appeal filed by the assessee is allowed

ITA 1119/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Sept 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2017-18 Shri. Muniyappa Muniraju, Vs. Pr. Cit, No.1/3, 1St Cross, Muni Narasimhaiah Bangalore - 2. Garden, Chocolate Factory Main Road, Btm I Stage, Bangalore – 560 029, Karnataka. Pan : Anjpm 0458 N Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 04.09.2025 Date Of Pronouncement : 11.09.2025

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Muthu Shankar, CIT(DR)(ITAT), Bangalore
Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 194CSection 194HSection 263Section 44A

194C of the Act however it has been deducted under section 194H of the Act under the head commission which is completely wrong. The learned Counsel further referred to Paper Book Page No. 22 which is submission made before AO in which it has been clarified that Rs.12 lakhs is included in the turnover of Rs.24,50,000/- and assessee

SANDEEP VIMALCHAND GADIA,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(5), BENGALURU

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 2404/BANG/2024[2012-13]Status: DisposedITAT Bangalore31 Jan 2025AY 2012-13

Bench: Shri. Laxmi Prasad Sahu & Shri. Prakash Chand Yadavassessment Year : 2012-13

For Appellant: Shri. Chaitanya A. V. Mudrabettu, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 148Section 194CSection 69A

section 194C of the Act of Rs.5,520/- and assessee has not filed return of income. Therefore, the entire receipt shown in Form 26AS was treated as profit under the head “Profit and Gains of Business or Profession”. Accordingly, the assessment was completed on 26.11.2024. Assessee filed appeal before the CIT(A) on 04.02.2020 with a delay. However, the learned

PERFECT ROOFING,HASSAN vs. INCOME-TAX OFFICER, WARD-1 & TPS, HASSAN

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 800/BANG/2024[2016-17]Status: DisposedITAT Bangalore19 Jun 2024AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Ms. Lakshmi S., AdvocateFor Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 147Section 148Section 194CSection 44ASection 68

194C which is 30% of Rs.69,656. Accordingly total income was assessed at Rs.63,27,377 in the assessment u/s. 147 r.w.s. 144(b) of the Act. 3. On appeal, the CIT(Appeals) issued two notices on 05.02.2024 and 19.02.204 fixing hearing on 20.02.24 and 26.02.2024 and ex parte order was passed on 27.02.2024 dismissing the appeal for non- prosecution

M/S. AMRUT DISTILLERIES PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals filed by the assessee are treated as allowed for statistical purposes

ITA 949/BANG/2023[2016-17]Status: DisposedITAT Bangalore28 Jan 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahuandshri. Soundararajan K

For Appellant: Shri. Prateek P, CAFor Respondent: Shri. Sridhar E, CIT(DR)(ITAT), Bangalore
Section 133ASection 40A(3)

reassess taking into consideration the other material in respect of completed assessments/unabated assessments.” The other material referred to herein, it is submitted, includes material or evidence gathered during survey proceedings and the assessment proceedings. It is submitted that material unearthed during survey proceedings albeit contemporaneous with the search proceedings in question itself, especially sworn statements, which, in the absence

M/S. AMRUT DISTILLERIES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals filed by the assessee are treated as allowed for statistical purposes

ITA 950/BANG/2023[2017-18]Status: DisposedITAT Bangalore28 Jan 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahuandshri. Soundararajan K

For Appellant: Shri. Prateek P, CAFor Respondent: Shri. Sridhar E, CIT(DR)(ITAT), Bangalore
Section 133ASection 40A(3)

reassess taking into consideration the other material in respect of completed assessments/unabated assessments.” The other material referred to herein, it is submitted, includes material or evidence gathered during survey proceedings and the assessment proceedings. It is submitted that material unearthed during survey proceedings albeit contemporaneous with the search proceedings in question itself, especially sworn statements, which, in the absence

M/S. AMRUT DISTILLERIES PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals filed by the assessee are treated as allowed for statistical purposes

ITA 948/BANG/2023[2015-16]Status: DisposedITAT Bangalore28 Jan 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahuandshri. Soundararajan K

For Appellant: Shri. Prateek P, CAFor Respondent: Shri. Sridhar E, CIT(DR)(ITAT), Bangalore
Section 133ASection 40A(3)

reassess taking into consideration the other material in respect of completed assessments/unabated assessments.” The other material referred to herein, it is submitted, includes material or evidence gathered during survey proceedings and the assessment proceedings. It is submitted that material unearthed during survey proceedings albeit contemporaneous with the search proceedings in question itself, especially sworn statements, which, in the absence

JCIT, BANGALORE vs. M/S HEWLETT PACKARD INDIA SALES P. LTD.,, BANGALORE

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

ITA 1252/BANG/2015[2010-11]Status: DisposedITAT Bangalore08 Sept 2025AY 2010-11

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT)
Section 143(3)Section 144CSection 40

reassessed on an annual basis. For the purpose of the valuation of the defective parts it was explained that it is refurbished valuation as Net repair the standard and cannot be less than zero. Net repair standard cost is the cost to repair a defective part subject to applicable warranty relief. This methodology was explained and verified by learned

HEWLETT PAKCARD INDIA SALES PRIVATE LIMITED,BANGALORE vs. JCIT, BANGALORE

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

ITA 1245/BANG/2015[2010-11]Status: DisposedITAT Bangalore08 Sept 2025AY 2010-11

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT)
Section 143(3)Section 144CSection 40

reassessed on an annual basis. For the purpose of the valuation of the defective parts it was explained that it is refurbished valuation as Net repair the standard and cannot be less than zero. Net repair standard cost is the cost to repair a defective part subject to applicable warranty relief. This methodology was explained and verified by learned