KOGOD BASAVARAJU JAYACHANDRA ,HASSAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

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

ia) of the Act the interest expenditure were disallowed. But while computing assessed income The disallowance of interest was not added and loss claimed in the return was disallowedAccordingly, the AO completed the assessment on 24.03.2022. 4. Aggrieved from the above Order, assessee filed appeal before the CIT(A). The legal grounds challenging the notice issued under section

DCIT, HASSAN vs. M/S SUJATHA NARAYAN & ASSOCIATES, HASSAN

In the result, the appeals of the assessee are partly allowed for statistical purposes and that of the revenue are dismissed

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

reassessment proceedings can be initiated so long as assessment proceedings pending on the basis of return already filed are not terminated. Similar view was expressed by the Hon'ble Allahabad High Court in the case of Jhunjhunwala Vanaspati Ltd. v. ACIT, 266 ITR 664 (All) and in the case of KLM Royal Dutch Airlines v. ADIT

M/S. SUJATHA NARAYANAN & ASSOCIATES,HASSAN vs. ACIT, HASSAN

In the result, the appeals of the assessee are partly allowed for statistical purposes and that of the revenue are dismissed

Bench: Shri Sunil Kumar Yadav & Shri S. Jayaraman

reassessment proceedings can be initiated so long as assessment proceedings pending on the basis of return already filed are not terminated. Similar view was expressed by the Hon'ble Allahabad High Court in the case of Jhunjhunwala Vanaspati Ltd. v. ACIT, 266 ITR 664 (All) and in the case of KLM Royal Dutch Airlines v. ADIT

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

UNITED BREWERIES LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-7(1)(1), BENGALURU

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

IA are applicable; or (vi) any other transaction as may be prescribed, and where the aggregate of such transactions entered into by the assessee in the previous year exceeds a sum of twenty crore rupees.” 28. Section 92(2), as amended provided that where in an international transaction or specified domestic transaction, two or more associated enterprises enter into

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

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

Section 92CC with the caption “Advance Pricing Agreement” provides through sub-section (1): `The Board, with the approval of the Central Government, may enter into an advance pricing agreement with any person, determining the arm's length price … in relation to an international transaction …’. Sub-section (2) gives the manner of determination of the ALP referred to in sub-section

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

reassessments. Similarly time limit for rectification of order is given in section 154; for passing revising order under section 263 etc. etc. In such a scenario the question arises that if no time limit is provided, then can any time limit be ITA Nos.1215 to 1220/ Bang/2014 & 18 to 23/Bang/2017, ITA Nos. 2328, 2335 to 2339/Bang/2016 Page