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188 results for “reassessment u/s 147”+ Revision u/s 263clear

Sorted by relevance

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Key Topics

Section 143(3)72Section 153A67Section 14A67Section 153C66Addition to Income62Section 26347Section 14840Section 13237Disallowance

M/S. TOKAI RIKA MINDA INDIA PVT. LTD,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME-TAX(CENTRAL), BENGALURU

In the result, appeal of the assessee is dismissed

ITA 781/BANG/2023[2018-19]Status: DisposedITAT Bangalore14 Dec 2023AY 2018-19

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2018-19

For Appellant: Shri K.R. Vasudevan, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 142(1)Section 143(2)Section 143(3)Section 263Section 92C

reassessment order itself is bad in law, whether such order can be revised u/s. 263 of the Act. The Tribunal held that since no notice u/s. 143(2) was prepared, issued and served upon the assessee, the assessment framed u/s. 147

Showing 1–20 of 188 · Page 1 of 10

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30
Section 133A27
Reopening of Assessment13
Reassessment12

SHRI. K. MUNIRAJU,BANGALORE vs. PRINCIPAL COMMISSIONER INCOME TAX, CENTRAL, BANGALORE

In the result appeals filed by assessee for asst

ITA 1376/BANG/2019[2011-12]Status: DisposedITAT Bangalore20 Oct 2020AY 2011-12

Bench: Shri A.K Garodia & Smt. Beena Pillai

For Appellant: Shri Rajeev C Nulvi, AdvocateFor Respondent: Shri Dilip Reddy, Standing Counsel to Dept. (DR)
Section 143(3)Section 263

147 of the Income. Tax Act, 1961. Such order is not an erroneous order as he has followed the Jurisdictional High Court judgment. 4. In CIT Vs Parmanand M Patel (2005) 278 ITR 3 (Guj) held that it is well settled that once an appeal has been preferred against an order of assessment, the entire assessment is open before

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)

263 (Karn) wherein it was held that reopening notice issued beyond the period of limitation u/s. 149(1)(a)(iii) expired on the date of issue of notice and therefore notice of reassessment was barred by limitation. The Hon’ble Bombay High Court in the case of Dynacraft Air Controls v. Smt. Sneha Joshi

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)

263 (Karn) wherein it was held that reopening notice issued beyond the period of limitation u/s. 149(1)(a)(iii) expired on the date of issue of notice and therefore notice of reassessment was barred by limitation. The Hon’ble Bombay High Court in the case of Dynacraft Air Controls v. Smt. Sneha Joshi

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)

263 (Karn) wherein it was held that reopening notice issued beyond the period of limitation u/s. 149(1)(a)(iii) expired on the date of issue of notice and therefore notice of reassessment was barred by limitation. The Hon’ble Bombay High Court in the case of Dynacraft Air Controls v. Smt. Sneha Joshi

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)

263 (Karn) wherein it was held that reopening notice issued beyond the period of limitation u/s. 149(1)(a)(iii) expired on the date of issue of notice and therefore notice of reassessment was barred by limitation. The Hon’ble Bombay High Court in the case of Dynacraft Air Controls v. Smt. Sneha Joshi

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)

263 (Karn) wherein it was held that reopening notice issued beyond the period of limitation u/s. 149(1)(a)(iii) expired on the date of issue of notice and therefore notice of reassessment was barred by limitation. The Hon’ble Bombay High Court in the case of Dynacraft Air Controls v. Smt. Sneha Joshi

BHARATH BAFNA ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2 , BENGALURU

In the result, the appeal of the assessee is allowed

ITA 880/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 May 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Ravishankar S.V., AdvocateFor Respondent: Smt. Srinandini Das, CIT(DR)(ITAT), Bengaluru
Section 142(1)Section 147Section 148Section 26Section 263

revise the order u/s. 263 of the Act by the ld. PCIT. 7. The ld. CIT(DR) submits that when in the reassessment order framed pursuant to the order u/s. 263, the returned income of the assessee is accepted, the appeal of the assessee becomes infructuous and hence should be dismissed. 8. We have carefully considered the rival

SRI. BANDIGADI CHANDRAPPASHETTY RAJASHEKARA,SHIVAMOGGA vs. INCOME-TAX OFFICER, WARD-4, SHIMOGA

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

ITA 773/BANG/2023[2015-16]Status: DisposedITAT Bangalore23 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ravishankar S.V AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT (DR)
Section 143(3)Section 263

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

BANDIGADI CHANDRAPPASHETTY RAJASHEKARAPPA,SHIMOGA vs. INCOME TAX OFFICER, WARD-1 , SHIMOGA

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

ITA 306/BANG/2025[2015-16]Status: DisposedITAT Bangalore23 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ravishankar S.V AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT (DR)
Section 143(3)Section 263

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

BANDIGADI CHANDRAPPASHETTY RAJASHEKARAPPA,SHIMOGA vs. INCOME TAX OFFICER, WARD-1 , SHIMOGA

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

ITA 307/BANG/2025[2015-16]Status: DisposedITAT Bangalore23 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ravishankar S.V AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT (DR)
Section 143(3)Section 263

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

SRI. BANDIGADI CHANDRAPPASHETTY RAJASHEKARA,SHIVAMOGGA vs. INCOME TAX OFFICER, WARD-4, SHIVAMOGGA

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

ITA 772/BANG/2023[2015-16]Status: DisposedITAT Bangalore23 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ravishankar S.V AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT (DR)
Section 143(3)Section 263

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

THAYAPPA BALAKRISHNA,BANGALORE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-1, BENGALURU

In the result, the appeal filed by the assessee stands allowed

ITA 1027/BANG/2024[2014-15]Status: DisposedITAT Bangalore22 Aug 2024AY 2014-15

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2014-15 Shri Thayappa Balakrishna, No. 987, 11Th Main, The Principal 1St Block, Commissioner Of 3Rd Stage, Income-Tax, Basaveshwaranagar, Bengaluru – 1. Vs. Bangalore – 560 079. Pan: Abdpb4893N Appellant Respondent : Shri Ravi Shankar .S.V, Assessee By Advocate Revenue By : Shri D.K. Mishra, Cit-Dr

For Respondent: Shri Ravi Shankar .S.V
Section 143(3)Section 147Section 148Section 263

revised return of income on 05-02-2016 declaring total income of Rs.7,48,360/-. The case was selected for scrutiny under CASS, and accordingly assessment was completed u/s 143(3) of the Act on 21-12-2016 assessing the income at Rs. 1,17,48,360. 2.2 The case was subsequently reopened u/s 147

B N PRASANNA KUMAR,MANDYA vs. PRINCIPAL COMMISSIONER OF INCOME TAX, MYSORE

In the result, the appeal filed by the assessee is partly allowed

ITA 466/BANG/2020[2017-18]Status: DisposedITAT Bangalore19 Jul 2022AY 2017-18

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Ravi Shankar, AdvocateFor Respondent: Sri.Srinivas T.Bidari, CIT-DR
Section 115BSection 131Section 143(3)Section 263Section 271ASection 69A

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He cannot usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 544/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

revised under section 263 nor has been reassessed under section 147 of the Act. 3.5 Subsequent to the above, the issue on taxability payments to seconded employees was revisited in the Hon’ble Delhi HC decision in the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44 taxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 496/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

revised under section 263 nor has been reassessed under section 147 of the Act. 3.5 Subsequent to the above, the issue on taxability payments to seconded employees was revisited in the Hon’ble Delhi HC decision in the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44 taxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 499/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

revised under section 263 nor has been reassessed under section 147 of the Act. 3.5 Subsequent to the above, the issue on taxability payments to seconded employees was revisited in the Hon’ble Delhi HC decision in the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44 taxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

ITA 497/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

revised under section 263 nor has been reassessed under section 147 of the Act. 3.5 Subsequent to the above, the issue on taxability payments to seconded employees was revisited in the Hon’ble Delhi HC decision in the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44 taxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

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

revision, which is chargeable to tax and has escaped assessment. Explanation 1.—Production before the Assessing Officer of account books or other evidence from which material evidence could with due diligence have been discovered by the Assessing Officer will not necessarily amount to disclosure within the meaning of the foregoing proviso. Explanation 2.—For the purposes of this section

VSL STEELS LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, this appeal of the assessee is allowed

ITA 1492/BANG/2014[2005-06]Status: DisposedITAT Bangalore20 Dec 2019AY 2005-06

Bench: Shri Arun Kumar Garodia, Am & Shri Pavan Kumar Gadale, Jm Assessment Year : 2005 – 06 M/S Vsl Steels Limited, No. 539, Ashwini Complex, 4Th Floor, Cmh Road, Indiranagar, Hal 2Nd Vs. Dcit, Circle – 2 (3), Stage, Bengaluru Bengaluru – 560038 Pan: Aaics1510N Appellant Respondent & Assessment Year : 2005 – 06 M/S Vsl Steels Limited, No. 539, Ashwini Complex, 4Th Floor, Cmh Road, Indiranagar, Hal 2Nd Vs. Pcit – 7, Stage, Bengaluru Bengaluru – 560038 Pan: Aaics1510N Appellant Respondent Assessee By : Shri S. Ramasubramanian, C. A. Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 14.11.2019 Date Of Pronouncement : 20.12.2019

For Appellant: Shri S. Ramasubramanian, C. AFor Respondent: Shri Pradeep Kumar, CIT DR
Section 147Section 153C

revision was already in appeal before CIT (A). In this regard, it was submitted that it is noted by PCIT in Para 9 of the impugned order that notice u/s 263 was issued on 19.09.2014 and in Para 8, it is noted that the AO had not considered the issue regarding accommodation entries of Rs. 65 Lacs provided