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486 results for “reassessment u/s 147”+ Disallowanceclear

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Key Topics

Section 148103Section 143(3)88Section 153A83Section 14780Addition to Income69Section 13249Section 14A48Disallowance42Section 153C

M/S VVD CONSTRUCTIONS PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

ITA 3385/BANG/2018[2011-12]Status: DisposedITAT Bangalore22 Mar 2021AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Smt. R. Premi, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 143(3)Section 148Section 36(1)(iii)

147 dtd: 08.11.2017 of the Act without issue of mandatory notice u/s. 143(2) of the Act as a result of which the Assessment is liable to be annulled since the assessment is non est in law.” 65. Further, the assessee has also filed the following additional grounds:- “1. The Notice u/s. 148 stated to have been issued

Showing 1–20 of 486 · Page 1 of 25

...
39
Reassessment37
Section 133A27
Reopening of Assessment25

M/S VVD CONSTRUCTIONS PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

ITA 3387/BANG/2018[2013-14]Status: DisposedITAT Bangalore22 Mar 2021AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Smt. R. Premi, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 143(3)Section 148Section 36(1)(iii)

147 dtd: 08.11.2017 of the Act without issue of mandatory notice u/s. 143(2) of the Act as a result of which the Assessment is liable to be annulled since the assessment is non est in law.” 65. Further, the assessee has also filed the following additional grounds:- “1. The Notice u/s. 148 stated to have been issued

M/S VVD CONSTRUCTIONS PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

ITA 3384/BANG/2018[2010-11]Status: DisposedITAT Bangalore22 Mar 2021AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Smt. R. Premi, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 143(3)Section 148Section 36(1)(iii)

147 dtd: 08.11.2017 of the Act without issue of mandatory notice u/s. 143(2) of the Act as a result of which the Assessment is liable to be annulled since the assessment is non est in law.” 65. Further, the assessee has also filed the following additional grounds:- “1. The Notice u/s. 148 stated to have been issued

M/S VVD CONSTRUCTIONS PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

ITA 3388/BANG/2018[2015-16]Status: DisposedITAT Bangalore22 Mar 2021AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Smt. R. Premi, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 143(3)Section 148Section 36(1)(iii)

147 dtd: 08.11.2017 of the Act without issue of mandatory notice u/s. 143(2) of the Act as a result of which the Assessment is liable to be annulled since the assessment is non est in law.” 65. Further, the assessee has also filed the following additional grounds:- “1. The Notice u/s. 148 stated to have been issued

M/S VVD CONSTRUCTIONS PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, ITA No.3384/Bang/2018 is allowed, while ITA Nos

ITA 3386/BANG/2018[2012-13]Status: DisposedITAT Bangalore22 Mar 2021AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Smt. R. Premi, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 143(3)Section 148Section 36(1)(iii)

147 dtd: 08.11.2017 of the Act without issue of mandatory notice u/s. 143(2) of the Act as a result of which the Assessment is liable to be annulled since the assessment is non est in law.” 65. Further, the assessee has also filed the following additional grounds:- “1. The Notice u/s. 148 stated to have been issued

TEXO THE BUILDERS ,UDUPI vs. ACIT, CENTRAL CIRCLE-2, MANGALORE

In the result, we dismiss grounds raised by the assessee

ITA 1200/BANG/2025[2014-15]Status: DisposedITAT Bangalore13 Nov 2025AY 2014-15

Bench: Shri.Laxmi Prasad Sahu & Shri.Soundararajan K

For Appellant: Shri. Sandeep Chalapathy, CAFor Respondent: Shri. Subramanian S,JCIT(DR)(ITAT), Bangalore
Section 133ASection 147Section 148Section 154Section 40A(3)Section 68

reassessment proceedings u/s 147 of the Act and notice u/s 148 was issued on 07.02.2020. 1.3. Subsequently the assessment proceedings was completed on 26.09.2021 with the assessed income of Rs. 40,53,080/- and a demand of Rs. 24,73,105/-. The break-up of the same is as under. Particulars Amount Total Income as per Return of Income

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

ITA 721/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Jul 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

MANIPAL GLOBAL EDUCATION SERVICES PVT LTD., ,BANGALORE vs. ACIT, CENTRAL CIRCLE-2(2), BANGALORE

In the result, the appeal of the assessee is allowed

ITA 976/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Jul 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

MANIPAL HOSPITALS PVT. LTD (FORMERLY KNOWN AS COLUMBIA ASIA HOSPITALS PVT. LTD),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

ITA 722/BANG/2025[2018-19]Status: DisposedITAT Bangalore29 Jul 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD.,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

ITA 720/BANG/2025[2015-16]Status: DisposedITAT Bangalore29 Jul 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PVT. LTD. ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, the appeal of the assessee is allowed

ITA 719/BANG/2025[2014-15]Status: DisposedITAT Bangalore29 Jul 2025AY 2014-15

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Smt. Prajakta Thakur, Jt.CIT (DR)(ITAT), Bengaluru
Section 10(35)Section 143(2)Section 143(3)Section 14A

u/s. 14A of the Act. The ld. AO in para 3.1 straight away stated that, “During the financial year relevant to this assessment year, the assessee company has made investments in mutual funds and equity investments in Indian companies, the income from which is not chargeable to tax. The asse was given an opportunity to explain why disallowance of Rs.97

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

In the result, the appeal of the assessee is partly allowed

ITA 527/BANG/2024[2018-19]Status: DisposedITAT Bangalore05 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Ms. Sunaina Bhatia, AdvocateFor Respondent: Shri V. Parithivel, JCIT-DR
Section 143(3)Section 14ASection 250

disallowing Rs. 1,32,40,428/- u/s. 14A r.w. Rule 8D under the facts & circumstances 9. We have heard the rival submissions and perused the material on record. 10. The ground nos. 1 and 4 are general in nature and do not require any adjudication. 11. During the course of hearing, the Ld.AR of the assessee has not pressed ground

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BANGALORE

In the result, all the COs by assessee in CO

ITA 785/BANG/2024[2020-21]Status: DisposedITAT Bangalore23 Jul 2024AY 2020-21

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Sri C. Ramesh, A.RFor Respondent: Smt. S, Praveena, D.R
Section 1Section 132Section 143(3)Section 148Section 14ASection 153ASection 154Section 234B(3)Section 234D

disallowance u/s 14A of the Income Tax Act, 1961 (in short “The Act”) read with Rule 8D of the Income Tax Rules. 3. Facts of the case are that on 21 .09.2017, a search action u/s. 132 of the Act was conducted in the case of M/S. Coffee Day Enterprises Ltd. at No. 23/2, Coffee Day Square, Vital Mallya Road

DEPUTY COMMISSIONER OF INCOME-TAX, , BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO

ITA 783/BANG/2024[2017-18]Status: DisposedITAT Bangalore23 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Sri C. Ramesh, A.RFor Respondent: Smt. S, Praveena, D.R
Section 1Section 132Section 143(3)Section 148Section 14ASection 153ASection 154Section 234B(3)Section 234D

disallowance u/s 14A of the Income Tax Act, 1961 (in short “The Act”) read with Rule 8D of the Income Tax Rules. 3. Facts of the case are that on 21 .09.2017, a search action u/s. 132 of the Act was conducted in the case of M/S. Coffee Day Enterprises Ltd. at No. 23/2, Coffee Day Square, Vital Mallya Road

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO

ITA 790/BANG/2024[2017-18]Status: DisposedITAT Bangalore23 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Sri C. Ramesh, A.RFor Respondent: Smt. S, Praveena, D.R
Section 1Section 132Section 143(3)Section 148Section 14ASection 153ASection 154Section 234B(3)Section 234D

disallowance u/s 14A of the Income Tax Act, 1961 (in short “The Act”) read with Rule 8D of the Income Tax Rules. 3. Facts of the case are that on 21 .09.2017, a search action u/s. 132 of the Act was conducted in the case of M/S. Coffee Day Enterprises Ltd. at No. 23/2, Coffee Day Square, Vital Mallya Road

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY ENTERPRISES, BENGALURU

In the result, all the COs by assessee in CO

ITA 782/BANG/2024[2016-17]Status: DisposedITAT Bangalore23 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Sri C. Ramesh, A.RFor Respondent: Smt. S, Praveena, D.R
Section 1Section 132Section 143(3)Section 148Section 14ASection 153ASection 154Section 234B(3)Section 234D

disallowance u/s 14A of the Income Tax Act, 1961 (in short “The Act”) read with Rule 8D of the Income Tax Rules. 3. Facts of the case are that on 21 .09.2017, a search action u/s. 132 of the Act was conducted in the case of M/S. Coffee Day Enterprises Ltd. at No. 23/2, Coffee Day Square, Vital Mallya Road

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

LOKESH TALANKI ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(3)(1), BANGALORE

In the result, appeals of the assessee are allowed

ITA 261/BANG/2019[2013-14]Status: DisposedITAT Bangalore13 Apr 2022AY 2013-14

Bench: Shri Beena Pillai & Ms. Padmavathy Sassessment Year : 2013-14

For Appellant: Shri Deepesh Waghale CAFor Respondent: Shri Shehnawaz Ul Rahaman Addln CIT
Section 142(1)Section 143(2)Section 143(3)Section 148Section 234BSection 54F

disallowing the claim u/s. 54F and recomputed the income of the assessee at Rs. 2,50,88,284. Aggrieved Page 4 of 23 the assessee filed an appeal before the CIT (A) challenging the re- opening of assessment and also the re-computation of capital gains. The CIT(A) held that the re-opening is valid and also confirmed

SHRI.J M VRUSHABENDRAIAH ,HOSPET vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1 , BELLARY

The appeal of the assessee is partly allowed

ITA 299/BANG/2019[2010-11]Status: DisposedITAT Bangalore20 Jul 2022AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Narayana K.R., D.R
Section 147Section 148Section 153CSection 250

disallowing the purchase expenses claimed by the Assessee u/s 37 r.w.s. 40A(3) of the Act. e. The Assessee wishes to submit that the reasons recorded by the learned AO are merely reasons to suspect and there is no belief that the income has escaped assessment. It is submitted that the provisions of section 147 of the Act require that

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

ITA 161/PAN/2019[2015-16]Status: DisposedITAT Bangalore30 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

For Appellant: Shri Ananthan S. & Smt. Lalitha Rameswaran, CAsFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 14ASection 234BSection 36(1)(vii)Section 36(1)(viia)Section 40Section 41(4)

disallowance made by the assessee u/s. 14A on the premise that there is no any incurred expend are incurred by the assessee towards earning exempt income. The assessee’s own fund is more than the investments made and there is decrease in quantum of investments during the year by Rs.59.36 crores and the increase in the internal fund