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5 results for “reassessment u/s 147”+ Section 150clear

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Key Topics

Section 153C4Section 153A4Section 1474Addition to Income3Reassessment3Limitation/Time-bar3Section 1322Section 1442Section 2(22)(e)

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

In the result, the instant appeal by the assessee is dismissed

ITA 157/COCH/2023[2007-08]Status: DisposedITAT Cochin12 Apr 2024AY 2007-08

Bench: Shri Sanjay Arora & Shri Manomohan Dasparayarukandy Vettath Gangadharan Dy. Cit, Circle - 1(1) Kerala Transport Company (Decd., Calicut Vs. Represented By Lrs.) K.T.C. Building, Ymca Calicut 673001 [Pan: Adhpg8318B] (Appellant) (Respondent)

For Appellant: Shri Suresh Kumar C., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 147Section 148Section 149Section 150(1)Section 153Section 2(22)(e)Section 268A

u/s. 147 of the Act were initiated against individual partners, as the assessee, holding shares in the lender company/s, for AY 2007-08. Even as the assessee objected thereto, citing Board Circular (No. 459 dated 22.09.1987), the Assessing Officer (AO) assessed the deemed dividend at Rs.1,13,14,280/- relying on s. 150(1) of the Act, which provision reads

2
Section 143(3)2
Section 1502
Condonation of Delay2

M/S SANTHIMADOM HERBAL CITY TRUST,ERNAKULAM vs. ACIT CENTRAL CIRCLE 2, KOCHI

In the result, the assessee’s appeals are partly allowed

ITA 921/COCH/2022[2009-10]Status: DisposedITAT Cochin14 Nov 2023AY 2009-10

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

For Appellant: Sri.Mathew Joseph, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.DR
Section 132Section 144Section 153ASection 153C

u/s. 69. This assumes relevance as the primary onus for such an addition is on the Revenue inasmuch as it is only on discovery of such an investment that its nature and source is liable to be explained, with an addition ensuing where the same is not found satisfactory. Absence of such challenge to the impugned additions

M/S SANTHIMADOM HERBAL CITY TRUST,ERNAKULAM vs. ACIT CENTRAL CIRCLE -2, KOCHI

In the result, the assessee’s appeals are partly allowed

ITA 920/COCH/2022[2008-09]Status: DisposedITAT Cochin14 Nov 2023AY 2008-09

Bench: Shri Sanjay Arora, Am & Shri Manomohan Das, Jm

For Appellant: Sri.Mathew Joseph, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.DR
Section 132Section 144Section 153ASection 153C

u/s. 69. This assumes relevance as the primary onus for such an addition is on the Revenue inasmuch as it is only on discovery of such an investment that its nature and source is liable to be explained, with an addition ensuing where the same is not found satisfactory. Absence of such challenge to the impugned additions

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

In the result, the assessee’s appeals are dismissed

ITA 158/COCH/2023[2008-09]Status: DisposedITAT Cochin29 Apr 2024AY 2008-09

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Suresh Kumar C., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 143(3)Section 147Section 150

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

ITA 156/COCH/2023[2005-06]Status: DisposedITAT Cochin29 Apr 2024AY 2005-06

Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Suresh Kumar C., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 143(3)Section 147Section 150

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