SRI SRAVAN KUMAR NEELA,NALGONDA vs. ACIT CENTRAL CIRCLE 1, KOZHIKODE

In the result, the instant appeals by the assesses are dismissed

Bench: Shri Sanjay Arora & Shri Manomohan Dasuma Maheshwara Rao Chinni Asst. Cit, Central Circle -1, Hno. 7-298, 7 Ward Aayakar Bhavan (North Block) Gandhi Bomma Centre Vs. Kozhikode 673001 Dachepalle, Guntur 522414 [Pan:Arjpc0342D] (Appellant) (Respondent)

147 read with ITA No. 895, 899/Coch/2022 (AY : 2017-18) Uma Maheshwara Rao Chinni & Anr. v. Asst. CIT section 143(3) of Income Tax Act, 1961 (the Act) dated 27.12.2018 for Assessment Year (AY) 2017-18. The facts and circumstances of the two cases being the same, raising common issues for adjudication, the appeals per taken up together for hearing

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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 J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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 J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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 J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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 J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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 J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section

FEDERAL BANK LTD,KOCHI vs. ACIT CORP. CIRCLE-1(1 ) , KOCHI

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

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 J year beginning on or before the 1st day of April, 2001." The Hon’ble Court observed that sub-sections (2) and (3) were introduced to the main section

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

REENA ENGINEERS AND CONTRACTORS PRIVATE LTD,PANAJI vs. ACIT, CENTRAL CIRCLE-1, CALICUT

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

reassess such income for such assessment year. Further, section 147 makes it very clear that in order to invoke provisions of section 147, there should be income which has escaped assessment, and such escapement should be based on fresh tangible material which comes to the possession of the Assessing Officer subsequent to the completion of the original assessment and further

M/S SKYLINE E TECH,KOCHI vs. ACIT CIRCLE 2(2), KOCHI

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

business of development and sale of software as partnership firm, whose assessment was completed u/s. 143(3) r.w.s. 147 of the Act on 26.12.2008 at a net loss of Rs.22,90,188. The above assessment was revised by the CIT-II, Kochi by order u/s. 263 of the Act dated 03.3.2011 setting aside assessment already passed u/s. 143(3) r.w.s

M/S SKYLINE E TECH,KOCHI vs. ACIT CIRCLE 2(2), KOCHI

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

business of development and sale of software as partnership firm, whose assessment was completed u/s. 143(3) r.w.s. 147 of the Act on 26.12.2008 at a net loss of Rs.22,90,188. The above assessment was revised by the CIT-II, Kochi by order u/s. 263 of the Act dated 03.3.2011 setting aside assessment already passed u/s. 143(3) r.w.s

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM vs. VRINDAVAN BUILDERS PRIVATE LIMITED, PATHANAMTHITTA

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

u/s. 143(3) r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KOLLAM vs. VRINDAVAN BUILDERS PRIVATE LIMITED, PATHANAMTHITTA

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

u/s. 143(3) r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court

VRINDAVAN BHAVAN PVT LTD,NAGALAND vs. ACIT CENTRAL CIRCLE, KOLLAM

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

u/s. 143(3) r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court

VRINDAVAN BUILDERS PVT LTD,NAGALAND vs. ACIT CENTRAL CIRCLE, KOLLAM

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

u/s. 143(3) r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KERALA vs. VRINDAVAN BUILDERS PRIVATE LIMITED, PATHANAMTHITTA

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

u/s. 143(3) r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court

VRINDAVAN BUILDERS PVT LTD,NAGALAND vs. ACIT, CENTRAL CIRCLE, KOLLAM

In the result, the appeals filed by the assessee for assessment years 2012-13 to 2017-18 are allowed and the appeals filed by Revenue for assessment years 2013-14 to 2017-18 are dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm

u/s. 143(3) r.w.s. 147 of the Act. 6. Being aggrieved, an appeal was filed before the CIT(A). contesting that the very initiation of reassessment proceedings are 4 ITA 695 to 700 & 732 to 736/Coch/2024 Vrindavan Builders Pvt. Ltd. void in law as the AO had deliberately not followed the procedure laid down by the Hon'ble Supreme Court