IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

reassessment, referred to in\nclause (a) of sub-section (1), in a case where an order under sub-section (4) has\nbeen made accepting the application.”\n5.3 Before leaping to section 270A of the Act, we first consider\nsection 270AA of the Act in order to find out whether the Form 68\nfiled by the Assessee Company on 06/10/2022

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

147 application. It was pointed out by this Court in Suresh Koshy George v. University of Kerala [AIR 1969 SC 198 : (1969) 1 SCR 317 : (1969) 1 SCJ 543] that “the rules of natural justice are not embodied rules” and in the same case this Court approved the following observations from the judgment of Tucker, L.J. in Russel v. Duke

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

147 application. It was pointed out by this Court in Suresh Koshy George v. University of Kerala [AIR 1969 SC 198 : (1969) 1 SCR 317 : (1969) 1 SCJ 543] that “the rules of natural justice are not embodied rules” and in the same case this Court approved the following observations from the judgment of Tucker, L.J. in Russel v. Duke

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

147 application. It was pointed out by this Court in Suresh Koshy George v. University of Kerala [AIR 1969 SC 198 : (1969) 1 SCR 317 : (1969) 1 SCJ 543] that “the rules of natural justice are not embodied rules” and in the same case this Court approved the following observations from the judgment of Tucker, L.J. in Russel v. Duke

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

147 application. It was pointed out by this Court in Suresh Koshy George v. University of Kerala [AIR 1969 SC 198 : (1969) 1 SCR 317 : (1969) 1 SCJ 543] that “the rules of natural justice are not embodied rules” and in the same case this Court approved the following observations from the judgment of Tucker, L.J. in Russel v. Duke

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

147 application. It was pointed out by this Court in Suresh Koshy George v. University of Kerala [AIR 1969 SC 198 : (1969) 1 SCR 317 : (1969) 1 SCJ 543] that “the rules of natural justice are not embodied rules” and in the same case this Court approved the following observations from the judgment of Tucker, L.J. in Russel v. Duke

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

147 application. It was pointed out by this Court in Suresh Koshy George v. University of Kerala [AIR 1969 SC 198 : (1969) 1 SCR 317 : (1969) 1 SCJ 543] that “the rules of natural justice are not embodied rules” and in the same case this Court approved the following observations from the judgment of Tucker, L.J. in Russel v. Duke

JOHN DISTILLERIES 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

147 application. It was pointed out by this Court in Suresh Koshy George v. University of Kerala [AIR 1969 SC 198 : (1969) 1 SCR 317 : (1969) 1 SCJ 543] that “the rules of natural justice are not embodied rules” and in the same case this Court approved the following observations from the judgment of Tucker, L.J. in Russel v. Duke

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

Section 292B of the Act and they render the entire\nproceedings null and void.\nPage 58 of 147\n35. In the present case, it is seen that the Revenue has failed to allude to\nany steps which were taken to determine that the seized material belonged to\nthe respondent-assessee group. Notably, the satisfaction note has also been\nprepared

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

Section 153A. Of equal significance is the introduction of the concept of abatement of all pending assessments as a consequence of which curtains come down on regular assessments.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. John Developers, Bangalore , ITA Nos.961, 962, 982 to 987 & 1012/Bang/2023

THE JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-4 , BANGALORE vs. M/S MPHASIS LIMITED , BANGALORE

In the result, both the appeals are dismissed

Bench: Shri N.V. Vasudevan & Shri B R Baskaranassessment Year: 2009-10

reassessment order passed by the learned AO under section 143(3) read with section 147 be quashed or in the alternative, the disallowance confirmed under section 40(a)(i) be deleted, payments made to AEs be held as not liable TDS under section 195 and interest levied under section 234B and 234C be deleted. The appellant prays accordingly

DAVANAM JEWELLERS PRIVATE LIMITED,BANGALORE vs. ACIT, CENTRAL CIRCLE-1(4), BANGALORE

In the result appeal of the Assessee is dismissed

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubeyassessment Year: 2019-20

reassessment proceedings u/s. 147 of the act in absence of valid information suggesting escapement of income and without independent application of mind. The Ld. Authorized Representative reiterated the same ground in her submission. 14. We have carefully considered the contention of the Ld. Authorized Representative. We find that the search took place in case of some trust on 17.02.2021. There

M/S. IBM INDIA PVT LTD,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, (LTU), BANGALORE

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadaleassessment Year : 2004-05

147 of the Act are invalid, unlawful and grossly without jurisdiction, as pre-conditions prescribed in law were not satisfied. 2.2. The learned CIT(A) has erred in law, in upholding the initiation of the reassessment proceedings by the learned AO by disregarding the settled positions of law. 2.3. The learned CIT(A) has erred in not appreciating that

SHRI HINGULAMBIKA EDUCATION SOCIETY,GULBARGA vs. ITO (EXEMPTIONS), WARD-1, KALBURGI

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2020-21

147 notice, for Income escaped Assessment u/ sec. 148. The ld. A.R. argued that can that be interpreted, in a genuine case like this where though the assessee is not falling in these two categories, having complied the law voluntarily by filing the return of income after obtaining provisional registration as the due date is extended due to covid allowing

SREE GANESH GEARS PRIVATE LIMITED ,MYSURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2) , MYSURU

In the result, the appeal filed by assessee stands allowed for statistical purposes

Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahuassessment Year : 2006-07 M/S. Sree Ganesh Gears The Deputy Pvt. Ltd., Commissioner Of Plot No. 106, Belegola Income Tax, Industrial Area, Circle – 1(2), Mysuru – 570 016. Mysuru. Vs. Pan: Aaecs8142C Appellant Respondent : Shri Ajith .V, Advocate I/B Shri Assessee By B.S. Balachandran, Advocate : Shri Ganesh R Gale, Standing Revenue By Counsel For Department Date Of Hearing : 30-05-2024 Date Of Pronouncement : 07-06-2024 Order Per Beena Pillaipresent Appeal Has Been Filed By The Assessee Against Order Dated 05/03/2024 Passed By Nfac, Delhi For A.Y. 2006-07. “Legal Grounds: 1. The Order Dated 04 March 2024 Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre Is Bad & Erroneous & Against The Facts & Circumstances Of The Case; 2. The Learned Cit(A) Erred In Law & On Facts In Dismissing The Appeal Of The Appellant On The Grounds Of Limitation Without Appreciating That The Appeal Was Filed Within The Time Limit Provided By The Hon'Ble High Court

reassessment proceedings initiated by the Ld AO based on change of opinion and without having any tangible material which shows escapement of income, thereby violating the provisions of section 147 of the Act; 5. The learned CIT(A) erred in not appreciating that the Appellant had disclosed all material facts necessary for making an assessment and hence, the notice issued

JOHN DISTILLERIES PVT LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, BANGALORE

Section\n147 of the Act, he cannot make such disallowances in respect of matters which\nhave reached finality in the original assessment and which arc not in the nature of\nany escapement of income within the meaning of Section 147. The learned Counsel\nfor assessee pointed out that the original assessment was made Under Section\n143(1) and thereafter

KARNATAKA BANK LTD,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, MANGALORE

Appeals of the revenue are partly allowed for statistical purposes

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.\n\n9. From perusal of Section 14A of the Act, it is evident that for the purposes

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1), MANGALURU, MANGALURU vs. KARNATAKA BANK LTD., MANGALURU

Appeals of the revenue are partly allowed for\nstatistical purposes

reassess under Section 147 or pass an\norder enhancing the assessment or reducing a refund already\nmade or otherwise increasing the liability of the assessee under\nSection 154, for any assessment year beginning on or before the\n1st day of April 2001.\n9. From perusal of Section 14A of the Act, it is evident that for\nthe purposes of computing