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

29]\n■ The provisions of section 147 are analogous to provisions of section 153A. Section\n147 deals with income escaping assessment, and as per the said provisions, if any\nincome chargeable to tax in case of an assessee has escaped assessment for any\n assessment year, the Assessing Officer shall assess or reassess such income for such\n assessment year

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

29] ■ The provisions of section 147 are analogous to provisions of section 153A. Section 147 deals with income escaping assessment, and as per the said provisions, if any income chargeable to tax in case of an assessee has escaped assessment for any assessment year, the Assessing Officer shall assess or reassess such income for such assessment year. Further, section 147

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

29] ■ The provisions of section 147 are analogous to provisions of section 153A. Section 147 deals with income escaping assessment, and as per the said provisions, if any income chargeable to tax in case of an assessee has escaped assessment for any assessment year, the Assessing Officer shall assess or reassess such income for such assessment year. Further, section 147

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

29] ■ The provisions of section 147 are analogous to provisions of section 153A. Section 147 deals with income escaping assessment, and as per the said provisions, if any income chargeable to tax in case of an assessee has escaped assessment for any assessment year, the Assessing Officer shall assess or reassess such income for such assessment year. Further, section 147

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

29] ■ The provisions of section 147 are analogous to provisions of section 153A. Section 147 deals with income escaping assessment, and as per the said provisions, if any income chargeable to tax in case of an assessee has escaped assessment for any assessment year, the Assessing Officer shall assess or reassess such income for such assessment year. Further, section 147

ACIT, ERNAKULAM vs. APPOLO TYRES LTD, COCHIN

In the result, the Revenue’s appeals as well as the Assessee’s COs, are allowed

Bench: Shri Sanjay Arora & Shri Manomohan Das

29 ITR 529 (SC)(also see: Lakshmiratan Cotton Mills Co. v. CIT [1969] 73 ITR 634 (SC). There can again be no quarrel on the proposition that the assessee can furnish only what is available with it, as surely law cannot impose an impossible burden. Page 10 ITANos. 139 & 140/Coch/ 2020 (AYs 2009-10 & 2011-12) CO Nos. 02 & 03/Coch/2020

ACIT, ERNAKULAM vs. APPOLO TYRES LTD, COCHIN

In the result, the Revenue’s appeals as well as the Assessee’s COs, are allowed

Bench: Shri Sanjay Arora & Shri Manomohan Das

29 ITR 529 (SC)(also see: Lakshmiratan Cotton Mills Co. v. CIT [1969] 73 ITR 634 (SC). There can again be no quarrel on the proposition that the assessee can furnish only what is available with it, as surely law cannot impose an impossible burden. Page 10 ITANos. 139 & 140/Coch/ 2020 (AYs 2009-10 & 2011-12) CO Nos. 02 & 03/Coch/2020

DY.COMMISSIONER OF INCOME TAX, THRISSUR vs. THE CSB BANK LTD, THRISSUR

In the result, the appeal of revenue is dismissed

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 115 JB of the Act does not permit this as deduction. 3.4. Further this is actually provision claimed as bad debt by Vijaya Bank decision not accepted by Hon'ble Kerala high Court itself as the same issue was set aside to the Hon'ble ITAT to examine whether provision can be treated ad bad debts wrote

SRI UMA MAHESHWARA RAO CHINNI,GUNTUR vs. ASST COMMISSIONER OF INCOME TAX,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

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

THE ACIT, CIRCLE-1(1), THRRISSUR vs. MANJILAS AGRO FOODS PVT. LTD., THRISSUR

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

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S.

reassessment proceedings from time to time and had discussed the impugned issue with the AO. The assessee did not seek any reason before the AO and therefore cannot contend the reopening on this ground. The CIT(A) on merits held that claim of higher depreciation by the assessee is not justified. Aggrieved, the assessee is in appeal before the Tribunal

MANJILAS AGRO FOODS PVT. LTD,THRISSUR vs. THACIT,CIRCLE-1(1 ), THRISSUR

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

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S.

reassessment proceedings from time to time and had discussed the impugned issue with the AO. The assessee did not seek any reason before the AO and therefore cannot contend the reopening on this ground. The CIT(A) on merits held that claim of higher depreciation by the assessee is not justified. Aggrieved, the assessee is in appeal before the Tribunal

MANJILAS AGRO FOOD PVT.LTD.,THRISSUR vs. THE ITO,WARD-1(2),, THRISSUR

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

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S.

reassessment proceedings from time to time and had discussed the impugned issue with the AO. The assessee did not seek any reason before the AO and therefore cannot contend the reopening on this ground. The CIT(A) on merits held that claim of higher depreciation by the assessee is not justified. Aggrieved, the assessee is in appeal before the Tribunal

UNNIKRISHNAN. K,KUNNAMPALLY vs. THE ITO WARD 2, TIRUR

In the result, the assessee’s appeal is allowed on the aforesaid terms, and his stay petition dismissed

Bench: Shri Sanjay Arora & Dr. Seethalakshmi

u/s. 147, is made where an income is found subsequent to assessment to have escaped assessment. It therefore necessarily includes the income already assessed. This is, as afore-noted, for the reason that the assessing SA No. 11/Coch/2023 Unnikrishnan Kunnampally v. ITO authority is thereby reassessing the assessee’s total income for the relevant year. The AO was thus duty

SRI.PARAYARUKANDY VETTATH GANGADHARAN,CALICUT vs. THE DCIT CIRCLE-1(1), CALICUT

In the result, the assessee’s appeals are dismissed

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

147 read with sec.143(3) of the Income-tax Act, 1961 (the Act) dated 04.03.2015 for assessment years (AYs.) 2005- 2006 & 2008-09, by the Commissioner of Income-tax (Appeals) [CIT(A)] vide his orders of even date (05.01.2023). The appeals raising a common issue, were heard together, and are being disposed of per a common order for the sake

SRI.PARAYARUKANDY VETTATH GANGADHARAN,CALICUT vs. THE DCIT CIRCLE-1(1), CALICUT

In the result, the assessee’s appeals are dismissed

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

147 read with sec.143(3) of the Income-tax Act, 1961 (the Act) dated 04.03.2015 for assessment years (AYs.) 2005- 2006 & 2008-09, by the Commissioner of Income-tax (Appeals) [CIT(A)] vide his orders of even date (05.01.2023). The appeals raising a common issue, were heard together, and are being disposed of per a common order for the sake