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

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

reassess in the light of the provision of the section 153C of the Act. 7.3.4 During the course of hearing the Learned AR has relied on the Judgement of the Division Bench of The Jurisdictional Karnataka High Court in Writ Appeal No. 830 to 834 of 2022 , order dated 22/01/2014, which we have dealt with in detail in the later

M/S UNITED SPIRITS LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-7 , BANGALORE

In the result, ground 7 is allowed for statistical purposes

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.3091/Bang/2018 : Asst.Year 2014-2015 M/S.United Spirits Limited The Joint Commissioner Of 6Th Floor, Ub Towers, Income-Tax, Special Range-7 V. Bangalore. # 24 Vittal Mallya Road Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent)

50D, 45(4) contain 7 IT(TP)A No.3091/Bang/2018 M/s.United Spirits Limited. deeming provisions. While computing total income, the real income is adjusted by including therein various legal fictions/deeming provisions incorporated in the Income tax Act. After this process only, the total income is arrived at. Sec.92(1) states that any “income” arising from an international transaction shall be computed