M/S POPULAR FINANCE COMPANY,PATHANAMTHITTA vs. THE ACIT,CIR-1,, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

reassessment proceedings u/s. 263 pending till the decision of the Apex Court in the cases of Shri Arun Thomas & Shri Thomas Thomas for the Assessment Year 2008-09 as per law. 4. Against this the assessees are in appeal before us with the following grounds of appeals: 1. The order of the learned Pr. Commissioner of Income Tax, Kottayam

M/S.POPULAR FINANCE,PATHANAMTHITTA vs. THE ACIT, CIRCLE-1, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

reassessment proceedings u/s. 263 pending till the decision of the Apex Court in the cases of Shri Arun Thomas & Shri Thomas Thomas for the Assessment Year 2008-09 as per law. 4. Against this the assessees are in appeal before us with the following grounds of appeals: 1. The order of the learned Pr. Commissioner of Income Tax, Kottayam

M/S POPULAR FINANCE COMPANY,PATHANAMTHITTA vs. THE ACIT,CIR-1,, THIRUVALLA

In the result, the appeals of the Revenue are partly allowed for statistical purposes

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

reassessment proceedings u/s. 263 pending till the decision of the Apex Court in the cases of Shri Arun Thomas & Shri Thomas Thomas for the Assessment Year 2008-09 as per law. 4. Against this the assessees are in appeal before us with the following grounds of appeals: 1. The order of the learned Pr. Commissioner of Income Tax, Kottayam

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

In the result, the appeals filed by the assessee stand partly

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

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

ACIT, TRIVANDRUM vs. KERALA STATE ELECTRICITY BOARD, TRIVANDRUM

In the result, both the appeals of the Revenue are dismissed

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

1. The Ld. Commissioner of Income-tax (Appeals), Thiruvananthapuram erred in concluding that "the reopening made under section 147 of the Act by issue of notice u/s 148 of the Act on 30.03.2010 is invalid and as the legal ground raised by the Appellant is allowed, the grounds raised on merits become infructuous and therefore, not discussed'. I.T.A. Nos.52&53/Coch/2019

ACIT, TRIVANDRUM vs. KERALA STATE ELECTRICITY BOARD, TRIVANDRUM

In the result, both the appeals of the Revenue are dismissed

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

1. The Ld. Commissioner of Income-tax (Appeals), Thiruvananthapuram erred in concluding that "the reopening made under section 147 of the Act by issue of notice u/s 148 of the Act on 30.03.2010 is invalid and as the legal ground raised by the Appellant is allowed, the grounds raised on merits become infructuous and therefore, not discussed'. I.T.A. Nos.52&53/Coch/2019

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

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 147 will be rendered invalid -reliance placed on Saraswati Garewal [2024] 158 taxmann.com 37 (Raipur ITAT), Tata Capital Financial Services Ltd. v. Asst. CIT [2022] 137 taxmann.com 315 (Bom) and Sabh Infrastructure Ltd. v. ACIT [2018] 89 taxmann.com 409 (Del). Finally it is contended that no reassessment proceedings can be initiated for the purpose of making protective addition placing

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

u/s 147 will be rendered invalid -reliance placed on Saraswati Garewal [2024] 158 taxmann.com 37 (Raipur ITAT), Tata Capital Financial Services Ltd. v. Asst. CIT [2022] 137 taxmann.com 315 (Bom) and Sabh Infrastructure Ltd. v. ACIT [2018] 89 taxmann.com 409 (Del). Finally it is contended that no reassessment proceedings can be initiated for the purpose of making protective addition placing

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 147 will be rendered invalid -reliance placed on Saraswati Garewal [2024] 158 taxmann.com 37 (Raipur ITAT), Tata Capital Financial Services Ltd. v. Asst. CIT [2022] 137 taxmann.com 315 (Bom) and Sabh Infrastructure Ltd. v. ACIT [2018] 89 taxmann.com 409 (Del). Finally it is contended that no reassessment proceedings can be initiated for the purpose of making protective addition placing