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

u/s 148 reopen the assessment of those six assessment year which falls\nwithin the exclusive jurisdiction of section 153A. Though, both provisions of the Act\nempowers the Assessing Officer to assess or reassess the income escaped from\nassessment, both sections are dealing with different situations. Section 147

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

u/s 148 reopen the assessment of those six assessment year which falls\nwithin the exclusive jurisdiction of section 153A. Though, both provisions of the Act\nempowers the Assessing Officer to assess or reassess the income escaped from\nassessment, both sections are dealing with different situations. Section 147

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

u/s 148 reopen the assessment of those six assessment year which falls\nwithin the exclusive jurisdiction of section 153A. Though, both provisions of the Act\nempowers the Assessing Officer to assess or reassess the income escaped from\nassessment, both sections are dealing with different situations. Section 147

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

u/s 148 reopen the assessment of those six assessment year which falls\nwithin the exclusive jurisdiction of section 153A. Though, both provisions of the Act\nempowers the Assessing Officer to assess or reassess the income escaped from\nassessment, both sections are dealing with different situations. Section 147

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

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 for the Assessment Year 2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1 54 on 29.07.2021, for the same AY, enhancing interest u./s 234B by Rs.1,68,14,539/and charged interest u/s 234D of Rs. 87,89,415/- since the interest initially undercharged under Section 234B(3). The appellant challenged this rectification order

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

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 for the Assessment Year 2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1 54 on 29.07.2021, for the same AY, enhancing interest u./s 234B by Rs.1,68,14,539/and charged interest u/s 234D of Rs. 87,89,415/- since the interest initially undercharged under Section 234B(3). The appellant challenged this rectification order

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

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 for the Assessment Year 2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1 54 on 29.07.2021, for the same AY, enhancing interest u./s 234B by Rs.1,68,14,539/and charged interest u/s 234D of Rs. 87,89,415/- since the interest initially undercharged under Section 234B(3). The appellant challenged this rectification order

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

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 for the Assessment Year 2011-12 on 28.06.2019, the AO passed a rectification order u/s. 1 54 on 29.07.2021, for the same AY, enhancing interest u./s 234B by Rs.1,68,14,539/and charged interest u/s 234D of Rs. 87,89,415/- since the interest initially undercharged under Section 234B(3). The appellant challenged this rectification order

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

INCOME TAX OFFICER, W-1, VIJAYANAGAR vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

JOHN DEVELOPERS ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

reopened u/s 153A of the Act without any seized material found during the course of search action. Assessment u/s 143(3) completed. Since regular assessment proceedings have been completed & are not pending, there would be no abatement of proceedings.ITA No.838 to 843/Bang/2023 M/s. Paul Resorts & Hotels Pvt. Ltd., Bangalore ITA No.844/Bang/2023 M/s. Paul Plathotathil John ITA Nos.845 to 847/Bang/2023

M/S. PAUL RESORTS & HOTELS PVT. LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened u/s 153A of the Act without any seized material found during the course of search action. Assessment u/s 143(3) completed. Since regular assessment proceedings have been completed & are not pending, there would be no abatement of proceedings. ITA No.838 to 843/Bang/2023 M/s. Paul Resorts & Hotels Pvt. Ltd., Bangalore M/s. Paul Plathotathil John ITA Nos.845 to 847/Bang/2023 M/s. John

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened u/s 153A of the Act without any seized material found during the course of search action. Assessment u/s 143(3) completed. Since regular assessment proceedings have been completed & are not pending, there would be no abatement of proceedings. ITA No.838 to 843/Bang/2023 M/s. Paul Resorts & Hotels Pvt. Ltd., Bangalore M/s. Paul Plathotathil John ITA Nos.845 to 847/Bang/2023 M/s. John

JOHN DEVELOPERS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened u/s 153A of the Act without any seized material found during the course of search action. Assessment u/s 143(3) completed. Since regular assessment proceedings have been completed & are not pending, there would be no abatement of proceedings. ITA No.838 to 843/Bang/2023 M/s. Paul Resorts & Hotels Pvt. Ltd., Bangalore M/s. Paul Plathotathil John ITA Nos.845 to 847/Bang/2023 M/s. John

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1) , BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened u/s 153A of the Act without any seized material found during the course of search action. Assessment u/s 143(3) completed. Since regular assessment proceedings have been completed & are not pending, there would be no abatement of proceedings. ITA No.838 to 843/Bang/2023 M/s. Paul Resorts & Hotels Pvt. Ltd., Bangalore M/s. Paul Plathotathil John ITA Nos.845 to 847/Bang/2023 M/s. John