THE COMMISSIONER OF INCOME TAX vs. REGENCY CREATIONS LTD

10B as the period of deduction of 10 years expires prior to assessment year 2005-06.” The second document relied on were the Instructions of 2006, dated 31st March, 2006: “INSTRUCTIONS NO.1 OF 2006, DT. 31ST MARCH, 2006 SUB: Deduction under Section 10A-Clarification-Reg. 31/3/2006 EXEMPTIONS SECTION 10A 1. Section 10A of the Income-tax Act, 1961 provides

DCIT CENTRAL CIRCLE-17, NEW DELHI vs. AL AMMAR FROZEN FOODS EXPORTS PVT. LTD, NEW DELHI

In the result, appeal of the Revenue is dismissed and cross\nobjection filed by the assessee is dismissed as infructuous

reassessment action, insofar as AY 2013-14 is\nconcerned, being beyond the maximum window of six\nyears would thus falter and fail on this score\nadditionally.\n\n23.\nThat takes us to the principal question and\nconcerning the legal requirements flowing from Section\n80-1A read along with Rule 12. We find that insofar as the\ndirectory nature of Section

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassessment made in pursuance to section 153A of the Act, is not a denovo assessment and, therefore, it was not open to the Page 46 of 63 ITA No. 5251 to 5257/DEL/2015 [A.Y 2006-07 to A.Y 2012-13] ITA No. 5451/DEL/2016 [A.Y 2013-14]; ITA No. 4492/DEL/2017 [A.Y 2014-15] M/s Jindal Photo LtdVs.The A.C.I.T assessee to claim

M/S JINDAL PHOTO LTD.,,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassessment made in pursuance to section 153A of the Act, is not a denovo assessment and, therefore, it was not open to the Page 46 of 63 ITA No. 5251 to 5257/DEL/2015 [A.Y 2006-07 to A.Y 2012-13] ITA No. 5451/DEL/2016 [A.Y 2013-14]; ITA No. 4492/DEL/2017 [A.Y 2014-15] M/s Jindal Photo LtdVs.The A.C.I.T assessee to claim

SHIKHAR EXPORTS,NEW DELHI vs. AITO WARD - 54(1), NEW DELHI

Bench: Shri M. Balaganesh & Shri Sudhir Kumarshikhar Exports Vs. Aito, Ward – 54(1) C/O. Pranshu Goel, C.A. New Delhi 5A/3A, Ansari Road Darya Ganj, New Delhi-110 002 Pan: Aadfs 6406 M (Appellant) (Respondent) Assessee By : Shri Pranshu Goel, C.A. & Shri Aditya Gupta, Adv. Revenue By: Shri V. K. Dubey, Sr. D.R. Date Of Hearing 15/10/2024 Date Of Pronouncement 18/10/2024

section 10B of the Act in the reassessment proceeding. 3. We have heard the rival submissions and perused the materials

JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, CC- 30, NEW DELHI

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee in ITA No

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

M/S. JINDAL PHOTO LTD.,NEW DELHI vs. ACIT, NEW DELHI

reassessment made in pursuance to section 153A of\nthe Act, is not a denovo assessment and, therefore, it was not open to the\nassessee to claim and be allowed such deduction or allowance of\nexpenditure which it had not claimed in the original assessment\nproceedings which in the case of assessee stood completed vide order dated\n15.01.2009 passed under section

COMPAREX INDIA P.LTD,NEW DELHI vs. ITO, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

10B(1)(e) of the Rules 16. On the facts and in law, the Ld.AO/Ld. TPO erred in proposing an adjustment without providing sufficient time to the Appellant and addressing any of the detailed contentions and explanations submitted by the Appellant in response to the show cause notice. Pertaining to Corporate Tax Grounds: 1. On the facts

THE COMMISSIONER OF INCOME TAX-V vs. ORIENT CRAFT LTD

reassessment proceedings under section 147 were not validly initiated. 2. The assessee is a company and for the assessment year 2002-03 it filed a return of income on 31st October, 2002 declaring a total income of Rs.4,45,35,395/-. The return was processed under Section 143(1) on 27th February, 2003; the income returned was accepted. Included

(Now known as Sony India Limited)

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 year the proceedings of which have been completed before the 1st day of October, 2009. (3) Where during the course of any proceeding for the assessment of income

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

10B of the Act. 4.1. The assessment concerning the appellant/assessee was framed under Section 143(3) of the Act. An order to that effect was passed on 12.12.2011, wherein the appellant/assessee‟s taxable income was assessed at Rs. 34,95,45,730/-, and the book profits under Section 115JB of the Act were enhanced

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

10B of the Act. 4.1. The assessment concerning the appellant/assessee was framed under Section 143(3) of the Act. An order to that effect was passed on 12.12.2011, wherein the appellant/assessee‟s taxable income was assessed at Rs. 34,95,45,730/-, and the book profits under Section 115JB of the Act were enhanced

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

10B of the Act. 4.1. The assessment concerning the appellant/assessee was framed under Section 143(3) of the Act. An order to that effect was passed on 12.12.2011, wherein the appellant/assessee‟s taxable income was assessed at Rs. 34,95,45,730/-, and the book profits under Section 115JB of the Act were enhanced

ITO, WARD-30(4), NEW DELHI vs. AMIT MITTAL, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Sh. C. M. Gargdr. B. R. R. Kumar

section 10B of Rs. 83,26,950/-, the ld. CIT(A) held that the reassessment proceedings were initiated for the reason