SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), , BANGALORE

In the result, the appeals by the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

13. The expression ‘reason to believe' still continues to be part of main section 147. There is no distinction at all between the assessment deemed to be completed under section 143(1) and the assessment completed under section 143(3) of the Income Tax Act. The Hon'ble Bombay High Court in the case of Prashant S. Joshi

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), BANGALORE

In the result, the appeals by the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

13. The expression ‘reason to believe' still continues to be part of main section 147. There is no distinction at all between the assessment deemed to be completed under section 143(1) and the assessment completed under section 143(3) of the Income Tax Act. The Hon'ble Bombay High Court in the case of Prashant S. Joshi

SHRI. JITENDRA VIRWANI,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, both the appeals by the assessee are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 shall apply as they apply for the purposes of that section. (2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151. (3) If the person on whom a notice under section 148 is to be served is a person treated as the agent of a non-resident

SHRI. JITENDRA VIRWANI,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, both the appeals by the assessee are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 shall apply as they apply for the purposes of that section. (2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151. (3) If the person on whom a notice under section 148 is to be served is a person treated as the agent of a non-resident

INCOME TAX OFFICER, WARD - 3(2)(3), BANGALORE vs. SRI MADE GOWDA THIBBE GOWDA, BANGALORE

In the result, the appeal of the revenue is dismissed and CO of the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2008-09

13. The expression ‘reason to believe' still continues to be part of main section 147. There is no distinction at all between the assessment deemed to be completed under section 143(1) and the assessment completed under section 143(3) of the Income Tax Act. The Hon'ble Bombay High Court in the case of Prashant S. Joshi

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

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

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

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

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

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

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

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

In the result, we allow appeal filed by the assessee

147 comes in to operation\nwhere there is an escapement of income chargeable to tax and section 153A comes in\nto operation where there is search u/s 132. 13. Under the provisions of section 153A,\nthe Assessing Officer is bound to issue notice to the assessee to furnish the returns of\nincome for each assessment years falling within

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

13 proceedings Category C: 271(1)(c) case where original return under section 139(1) of the Act has been filed however, secondment related receipts were offered to tax only in the return filed under section 148 of the Act Compagnie IBM 2013- 271(1)(c) 545/Bang/2024 Filed but In ROI filed France 14 not offered u/s 148 Compagnie

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

13 proceedings Category C: 271(1)(c) case where original return under section 139(1) of the Act has been filed however, secondment related receipts were offered to tax only in the return filed under section 148 of the Act Compagnie IBM 2013- 271(1)(c) 545/Bang/2024 Filed but In ROI filed France 14 not offered u/s 148 Compagnie

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

13 proceedings Category C: 271(1)(c) case where original return under section 139(1) of the Act has been filed however, secondment related receipts were offered to tax only in the return filed under section 148 of the Act Compagnie IBM 2013- 271(1)(c) 545/Bang/2024 Filed but In ROI filed France 14 not offered u/s 148 Compagnie

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

13 proceedings Category C: 271(1)(c) case where original return under section 139(1) of the Act has been filed however, secondment related receipts were offered to tax only in the return filed under section 148 of the Act Compagnie IBM 2013- 271(1)(c) 545/Bang/2024 Filed but In ROI filed France 14 not offered u/s 148 Compagnie

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

147 comes in to operation\n\nPage 17 of 77\nwhere there is an escapement of income chargeable to tax and section 153A comes in\nto operation where there is search u/s 132. 13. Under the provisions of section 153A,\nthe Assessing Officer is bound to issue notice to the assessee to furnish the returns of\nincome for each assessment

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

147 comes in to operation\n\nPage 17 of 77\nITA Nos.45, 46, 47, 48/Bang/2020\nITA No.205/Bang/2022\nwhere there is an escapement of income chargeable to tax and section 153A comes in\n to operation where there is search u/s 132. 13. Under the provisions of section 153A,\nthe Assessing Officer is bound to issue notice to the assessee

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

147 comes in to operation\n\nwhere there is an escapement of income chargeable to tax and section 153A comes in\nto operation where there is search u/s 132. 13. Under the provisions of section 153A,\nthe Assessing Officer is bound to issue notice to the assessee to furnish the returns of\nincome for each assessment years falling within

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

147 comes in to operation\n\nPage 17 of 77\nITA Nos.45, 46, 47, 48/Bang/2020\nITA No.205/Bang/2022\nwhere there is an escapement of income chargeable to tax and section 153A comes in\nto operation where there is search u/s 132. 13. Under the provisions of section 153A,\nthe Assessing Officer is bound to issue notice to the assessee to furnish

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

In the result, appeal of the revenue in ITA No

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

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

NEETA BHAMBHANI,BENGALURU vs. DCIT, (IT), CIRCLE-1(1), BENGALURU

In the result, I pass the following:-

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

147 r.w.s 144C(13) of the Act dated 30/10/2025, the assessee has filed the present appeal before this Tribunal. The assessee has also filed a paper book comprising of 17 pages containing therein the copy of notice u/s. 148A(b) of the Act, copy of the order u/s. 148A(d) of the Act, copy of notice u/s

M/S. CRYSTAL GRANITE AND MARBLE PRIVATE LIMITED,RAMANAGARAM vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes and Stay Petition is dismissed as infructuous

Bench: Shri George George K & Shri Laxmi Prasad Sahus.P No.29/Bang/2023 Assessment Year: 2017-18

1) of section 3 of the said Act, relates to passing of an order under sub-section (13) of section 144C of the Income-tax Act or issuance of notice under section 148 as per time-limit specified in section 149 or sanction under section 151 of the Income-tax Act, and the time limit for completion of such action