COMMISSIONER OF INCOME TAX vs. PAWAN GUPTA

The appeals are dismissed

d i th t 2009:DHC:1436-DB “It is true that the return was filed by the assessee in response to a notice under section 158BC(a). Clause (b) of section 158BC provides that the provisions of section 142 as well as sub-sections (2) and (3) of section 143 shall apply even in the case of a block

RAJAN GUPTA vs. COMMISSIONER OF INCOME TAX

The appeal is allowed as aforesaid

reassessment, which may be pending before an income-tax authority on the date on which an application under sub-section (1) of section 245C is made. xxxxx xxxxx xxxxx xxxxx‖ 11. Section 245C provides that an assessee may, at any stage of a ―case‖ relating to him, make an application in such form and in such manner

MR. KRISHNA KUMAR PANT,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

reassess by invoking provision of section 147 inasmuch as there is no application 15 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 of mind by the Ld. AO while recording of reasons, rendering assumption of jurisdiction as bad in law. He submitted that the observations of Ld. CIT(A) while disposing off the appeal of M/s SGS were not binding upon the Assessing

MR. RANJEET SINGH,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

reassess by invoking provision of section 147 inasmuch as there is no application 15 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 of mind by the Ld. AO while recording of reasons, rendering assumption of jurisdiction as bad in law. He submitted that the observations of Ld. CIT(A) while disposing off the appeal of M/s SGS were not binding upon the Assessing

MR. SANJIV NARAYAN,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

reassess by invoking provision of section 147 inasmuch as there is no application 15 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 of mind by the Ld. AO while recording of reasons, rendering assumption of jurisdiction as bad in law. He submitted that the observations of Ld. CIT(A) while disposing off the appeal of M/s SGS were not binding upon the Assessing

MR. J.S. GUJRAL,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

reassess by invoking provision of section 147 inasmuch as there is no application 15 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 of mind by the Ld. AO while recording of reasons, rendering assumption of jurisdiction as bad in law. He submitted that the observations of Ld. CIT(A) while disposing off the appeal of M/s SGS were not binding upon the Assessing

CIT vs. SELECT HOLIDAY RESORTS PVT LTD

The appeals stand disposed of as above

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE R.V.EASWAR

reassess under section 14 7 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 beginning on or before the 1st day of April, 2001." Q 11. By Notification No.45/2008 dated 24/03/2008, the Central Board of Direct Taxes (CBDT), in exercise

CIT vs. SELECT HOLIDAY RESORTS PVT LTD

The appeals stand disposed of as above

reassess under section 14 7 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 beginning on or before the 1st day of April, 2001." Q 11. By Notification No.45/2008 dated 24/03/2008, the Central Board of Direct Taxes (CBDT), in exercise

COMMSSIONER OF INCOME TAX DELHI-XVI vs. S.S. AHLUWALIA

d) cases or classes of cases. (4) Without prejudice to the provisions of sub-sections (1) and (2), the Board may, by general or special order, and subject to such conditions, restrictions or limitations as may be specified therein,— (a) authorise any Director General or Director to perform such functions of any other income-tax authority as may be assigned

COMMISSIONER OF WEALTH TAX vs. S.S. AHLUWALIA

d) cases or classes of cases. (4) Without prejudice to the provisions of sub-sections (1) and (2), the Board may, by general or special order, and subject to such conditions, restrictions or limitations as may be specified therein,— (a) authorise any Director General or Director to perform such functions of any other income-tax authority as may be assigned

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

D E R PER PRASHANT MAHARISHI, A. M. 01. This appeal is preferred by Cairn UK Holdings Limited, (hereinafter referred to as ‗Appellant‖) , against the order of the Deputy Commissioner of Income tax , Circle- 1 (2) (1) International taxes, New Delhi ( Hereinafter referred to as the ‗AO ‗) dated 25/01/2016 passed u/s 143(3) rws 148 of the Cairn

INTERNATIONAL HOSPITAL LIMITED vs. DCIT CIRCLE 12 (2)

Bench: HON'BLE MR. JUSTICE RAVINDER DUDEJA,HON'BLE MR. JUSTICE YASHWANT VARMA

d) order and the consequential notice under Section 148 issued pursuant to the aforesaid determination which for the first time came to be framed in the name of the resultant entity, Religare Enterprises Limited. Both the original Section 148 notice as well as the subsequent notice under Section 148A(b) were in the name of RSL. . Shorn of unnecessary details

ADIT, DEHRADUN vs. M/S. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit, Halliburton Offshore Services International Taxation, Inc. , Vs. 13-A,Subhash Road, C/O. Nangia & Company, Ca, Aayakar Bhawan, 75/7, Rajpur Road, Dehradun Dehradun Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Addl. Cit, Inc. , International Taxation, Vs. C/O. Nangia & Company, Ca, Subhash Road, Suite-4A, Plaza M-6, Jasola, Dehradun New Delhi Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Inc. , Adit, C/O. Nangia & Company, Ca, International Taxation, Vs. Suite-4A, Plaza M-6, Jasola, 13-A,Subhash Road, New Delhi Aayakar Bhawan, Pan:Aaach5154M Dehradun (Appellant) (Respondent) Halliburton Offshore Services Inc. Vs Ddit (International Taxation)

2). It is not in dispute that the amount has been received by the assessee-company. Therefore, the Assessing Officer added the said amount which was received by the non-resident company rendering services as per provisions of section 44BB to the ONGC and imposed the income-tax thereon. 7. Accordingly, for the reasons recorded above, we set aside

ALI MOHAMMAD,GHAZIABAD vs. ACIT, CIRCLE-2(1)(1), GHAZIABAD

In the result, appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.5608/Del/2024 िनधा"रणवष"/Assessment Year: 2014-15 बनाम Ali Mohammad Acit, Mohalla Kot Kachchi Saray, Vs. Circle-2(1)(1), Murad Nagar, Ghaziabad, Ghaziabad. Uttar Pradesh. Pan No.Etopm2968E अपीलाथ" Appellant ""यथ"/Respondent

reassessment or re-computation as specified in sub-section (2) of section 153, every such notice referred to in this clause shall be deemed to be a valid notice. Explanation.—For the removal of doubts, it is hereby declared that nothing contained in the first proviso or the 'second proviso shall apply to any return which has been furnished

ACIT, CIRCLE-19(2), NEW DELHI vs. P & R INFRAPROJECTS LTD, NEW DELHI

In the result, the appeal filed by the Revenue is dismissed

section 147 of the Act and issued notice u/s 148. 3. The AO in this case received information from the Dy. Director of Income- tax (Investigation)-II, Chandigarh that a survey operation u/s 133A of the Act was conducted in the case of the assessee at various places. During the course of survey and post survey enquiries, it was observed

SH. SANJAY DALMIA,NEW DELHI vs. DCIT, NEW DELHI

In the result all the appeal filed by the assessee are dismissed

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

reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates as applicable to such assessment year. ‖ 3. Thus, under the presently applicable provisions, the CBDT itself is not stating that notices u/ss 143/142 of the Act to be issued as was required under the earlier block assessment scheme

RAKESH KUMAR GUPTA,DELHI vs. LD. ITO, WARD 35(1), DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Rakesh Kumar Gupta, Income Tax Officer, Ward-35(1), B-2/38, Ground Floor, E-2, Civic Centre, Delhi-110002 Ashok Vihar, Phase-Ii, Vs Delhi-110052 Pan-Aafhr8657H Appellant Respondent

d) recording of any false entry in the books of account; (e) failure to record any receipt in books of account having a bearing on total income; and (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

D is received by the Principal Commissioner or Commissioner under sub-section (2) of that section; or (viii) the period commencing from the date on which an application is made before the Authority for Advance Rulings [or before the Board for Advance Rulings] under sub-section (1) of section Digitally Signed By:KAMLESH KUMAR Signing Date