BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

reassessment or recomputation under section 147, the Income-tax Officer shall serve on the assessee a notice containing all or any of the requirements which may be included in a notice under sub-section (2) of section 139; and the provisions of the Act shall, so far as may be, apply accordingly as if the notice were a notice issued

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

reassessment proceedings of SEC for the same assessment year. On the date on which notices were issued to the petitioner under Sections 148 and 201(1

L.G. ELECTRONICS INDIA LTD., NOIDA vs. ITO, WARD- 2(2)(1)(INT. TAXATION), NEW DELHI

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

reassessment proceedings of SEC for the same assessment year. On the date on which notices were issued to the petitioner under Sections 148 and 201(1

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

reassessment proceedings of SEC for the same assessment year. On the date on which notices were issued to the petitioner under Sections 148 and 201(1

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

reassessment proceedings of SEC for the same assessment year. On the date on which notices were issued to the petitioner under Sections 148 and 201(1

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

reassessment proceedings of SEC for the same assessment year. On the date on which notices were issued to the petitioner under Sections 148 and 201(1

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

reassessment proceedings of SEC for the same assessment year. On the date on which notices were issued to the petitioner under Sections 148 and 201(1

LG ELECTRONICS INDIA LTD.,GR. NOIDA vs. ITO (TDS) INTERNATIONAL TAXATION, NOIDA

In the result, appeals are allowed, as indicated above

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-Assessment Year: 2005-06 With Assessment Year: 2006-07 With Assessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 M/S. Lg Electronics India Ltd., Vs. Ito (Tds), Plot No.51, Udyog Vihar, International Taxation, Surajpur Industrial Area, Noida Greater Noida (Up) Pan :Aaacl1745Q (Appellant) (Respondent)

reassessment proceedings of SEC for the same assessment year. On the date on which notices were issued to the petitioner under Sections 148 and 201(1

REEBOK INDIA COMPANY,GURUGRAM vs. JCIT (OSD), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Shri Kul Bharat

reassessment up to 6 years from the end of the assessment year for which the income has escaped assessment. Therefore, section 148 of the Act allows reopening of cases of one more preceding previous year than specified under section 201(3)(ii) of the Act. Due to this, order under section 201(1

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under sub-section (1). This amendment will take effect retrospectively from 1st April, 1989.” 9.2.4 As self evident from the Memorandum to the Finance Bill 2008, the new section 271(1B) was inserted with the intention to give validity to the ‘satisfaction’ made

(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

DIRECTOR OF INCOME TAX INTERNATIONAL TAXATION vs. GE PACKAGED POWER INC

201 of the Act. 23. For the above reasons, this Court finds that no interest is leviable on the respondent assessees under Section 234B, even though they filed returns declaring NIL income at the stage of reassessment. The payers were obliged to determine whether the assessees were liable to tax under Section 195(1