M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254, or section 260 or section 262 or section 263 or section

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254, or section 260 or section 262 or section 263 or section

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,ERNAKULAM vs. ACIT CENTRAL CIRCLE-2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254, or section 260 or section 262 or section 263 or section

M/S SANTHIMADOM AYURNIKETHAN HEALTH RESORT & RESEARCH INSTITUTE TRUST,KOCHI vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250 or section 254, or section 260 or section 262 or section 263 or section

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

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

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

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

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

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

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

u/s. 147 was bad-in-law and reassessment so concluded not valid.” (emphasis, ours) 4. We may at the outset clarify two aspects. Firstly, the assessee’s COs, filed on 25/6/2020, though out of time by 3 days, were admitted as the delay is saved by the order of the Hon'ble Apex Court in Suo Motu Writ Petition

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

u/s. 147 was bad-in-law and reassessment so concluded not valid.” (emphasis, ours) 4. We may at the outset clarify two aspects. Firstly, the assessee’s COs, filed on 25/6/2020, though out of time by 3 days, were admitted as the delay is saved by the order of the Hon'ble Apex Court in Suo Motu Writ Petition

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

section 147 cannot be made in order to make a protective assessment or addition. The ratio of the decision of the Hon’ble Bombay High Court cited supra is squarely application to the facts of the case. Therefore, we are of the considered opinion that initiation of reassessment proceedings are bad in law. Accordingly, we quash the reassessment proceedings

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

section 147 cannot be made in order to make a protective assessment or addition. The ratio of the decision of the Hon’ble Bombay High Court cited supra is squarely application to the facts of the case. Therefore, we are of the considered opinion that initiation of reassessment proceedings are bad in law. Accordingly, we quash the reassessment proceedings

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

section 147 cannot be made in order to make a protective assessment or addition. The ratio of the decision of the Hon’ble Bombay High Court cited supra is squarely application to the facts of the case. Therefore, we are of the considered opinion that initiation of reassessment proceedings are bad in law. Accordingly, we quash the reassessment proceedings

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

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

section 147 cannot be made in order to make a protective assessment or addition. The ratio of the decision of the Hon’ble Bombay High Court cited supra is squarely application to the facts of the case. Therefore, we are of the considered opinion that initiation of reassessment proceedings are bad in law. Accordingly, we quash the reassessment proceedings

VRINDAVAN BUILDERS PVT KTD,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

section 147 cannot be made in order to make a protective assessment or addition. The ratio of the decision of the Hon’ble Bombay High Court cited supra is squarely application to the facts of the case. Therefore, we are of the considered opinion that initiation of reassessment proceedings are bad in law. Accordingly, we quash the reassessment proceedings

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

section 147 cannot be made in order to make a protective assessment or addition. The ratio of the decision of the Hon’ble Bombay High Court cited supra is squarely application to the facts of the case. Therefore, we are of the considered opinion that initiation of reassessment proceedings are bad in law. Accordingly, we quash the reassessment proceedings

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

section 147 cannot be made in order to make a protective assessment or addition. The ratio of the decision of the Hon’ble Bombay High Court cited supra is squarely application to the facts of the case. Therefore, we are of the considered opinion that initiation of reassessment proceedings are bad in law. Accordingly, we quash the reassessment proceedings

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

section 147 cannot be made in order to make a protective assessment or addition. The ratio of the decision of the Hon’ble Bombay High Court cited supra is squarely application to the facts of the case. Therefore, we are of the considered opinion that initiation of reassessment proceedings are bad in law. Accordingly, we quash the reassessment proceedings