K K SPUN INDIA LIMITED,DELHI vs. DCIT, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

234C be recalculated or deleted.  The penalty proceedings under Section 271(1)(c) be quashed.  Any other relief deemed fit by the Hon’ble Tribunal be granted. 15. Thereafter, the assessee has also taken additional grounds of appeal, wherein assessee has challenged the reassessment

K K SPUN INDIA LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-2 NEW DELHI, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

234C be recalculated or deleted.  The penalty proceedings under Section 271(1)(c) be quashed.  Any other relief deemed fit by the Hon’ble Tribunal be granted. 15. Thereafter, the assessee has also taken additional grounds of appeal, wherein assessee has challenged the reassessment

SUNITA BHARDWAJ,NEW DELHI vs. ACIT CIRCLE 63(1), NEW DELHI

reassessment proceedings and notices were quashed.", "result": "Allowed", "sections": [ "147", "148", "143(3)", "68", "234A", "234B", "234C", "151", "150(1)", "150(2)" ], "issues

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

reassessment proceedings under section 147 of the Act in the absence of any live link or nexus between the ‘information’ and the formation of the belief that income chargeable to tax had escaped assessment. Without prejudice 3. That the AO/DRP erred in concluding that the Appellant had a Permanent Establishment (“PE”) under Article 5 of the India - Korea DTAA given

M/S. LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT (INTERNATIONAL TAXATION), NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

reassessment proceedings under section 147 of the Act in the absence of any live link or nexus between the ‘information’ and the formation of the belief that income chargeable to tax had escaped assessment. Without prejudice 3. That the AO/DRP erred in concluding that the Appellant had a Permanent Establishment (“PE”) under Article 5 of the India - Korea DTAA given

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- NOIDA, INTERNATIONAL TAXATION, NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

reassessment proceedings under section 147 of the Act in the absence of any live link or nexus between the ‘information’ and the formation of the belief that income chargeable to tax had escaped assessment. Without prejudice 3. That the AO/DRP erred in concluding that the Appellant had a Permanent Establishment (“PE”) under Article 5 of the India - Korea DTAA given

SECURITY PRINTING AND MINTING CORPORATION OF INDIA LTD,NEW DELHI vs. ACIT, CIRCLE 22(2), NEW DELHI

The appeal of the assessee is dismissed

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

reassessment order passed under section Page 2 of 8 147/143(3) of the Acton 02.09.2011 and consequential interest charged therein under section 234A, 234B and 234C

MAHARASHTRA FEEDS P. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE, FARIDABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

reassessment or re-computation 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

MAHARASHTRA FEEDS P. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE, FARIDABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

reassessment or re-computation 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

CAIRN UK HOLDING LTD.,AHMEDABAD vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result ground No. 5 of the appeal of the assessee is allowed

Bench: Shri H. S. Sidhu & Shri Prashant Maharishi

reassessment proceedings under section 147 / 148 of the Act based on the issue of an invalid notice under section 143(2) of the Act which is the primary requirement for initiation of any assessment proceedings;” Below Ground No. 3.11, the following grounds are added; Cairn U K Holdings Limited V DCIT ( International Taxation) New Delhi

ORANGE BUSINESS SERVICES INDIA SOLUTIONS PVT. LTD.,GURGAON vs. DCIT, CIRCLE-3, GURGAON

In the result, the appeal of the assessee is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumar(Through Video Conferencing)

reassessment proceedings were based on change of opinion on the same set of facts which were existing and considered at the time of original assessment concluded under section 143(3) of the Act. 2. Without prejudice to the above grounds, the Ld. CIT(A) on the facts and in |he circumstances of the case and in law, erred in confirming

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

reassessment proceedings initiated based on such approval were quashed.", "result": "Allowed", "sections": [ "147", "148", "151", "68", "250", "234A", "234B", "234C

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SUNITA BHARDWAJ,NEW DELHI vs. ITO WARD 61(1), NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SUMAN KISHORE,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

section 1 28.12.2019 CIT(A), NFAC, 144 r.w.s. 147 of the [Assessment Year 2012-13] Delhi order dated Income Tax Act, 30.01.2024 1961. 2. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2013-14] Delhi order dated the Income Tax Act, 30.01.2024 1961. 3. 30.03.2022 CIT(A), NFAC, 147 r.w.s. 144B of [Assessment Year 2014-15] Delhi order

SHRI BHARAT SINGH,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Amit Shukla & Shri O.P. Kant

reassessment proceedings were initiated under section 147 of the Act, which were abated due to the action under section 153A of the act and thus the ratio of making no addition in the case of Kabul Chawala(supra) does not apply in the facts of the instant case. 5.8 As regard to the argument that no presumption can be made

SHRI BHARAT SINGH,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Amit Shukla & Shri O.P. Kant

reassessment proceedings were initiated under section 147 of the Act, which were abated due to the action under section 153A of the act and thus the ratio of making no addition in the case of Kabul Chawala(supra) does not apply in the facts of the instant case. 5.8 As regard to the argument that no presumption can be made

DCIT, DEHRADUN vs. M/S. REED HYCALOG LIMITED PARTNERSHIP, NOIDA

In the result, the appeal of the Revenue is dismissed and the cross- objection of the assessee is partly allowed

Bench: : Shri Amit Shukla & Shri L.P. Sahuassessment Year: 2006-07

reassessment. The payers were obliged to determine whether the assessees were liable to tax under Section 195(1). and to what extent, by taking recourse to the mechanism provided in Section 195(2) of the Act. The failure of the payers to do so does not leave the Revenue without remedy; the payer may be regarded an assessee in- default