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

45) "total income" means the total amount of income referred to in section 5, computed in the manner laid down in this Act; Chapter XIV - Procedure for Assessment Self-assessment 140A. (1) Where any tax is payable on the basis of any return required to be furnished under section 139 or section 142 or as the case Maharashtra Feeds

CIT vs. TEI TECHNOLOGIES PVT LTD

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

45). The phrase "total income" has been used in the Income-tax Act in several places with different connotations and shades. The phrase "total income" used in section 10A is one such variant. The phrase need not necessarily mean the total income as computed in accordance with the provisions of the Act. The relief under this section is with reference

CIT vs. TEI TECHNOLOGIES PVT LTD

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

45). The phrase "total income" has been used in the Income-tax Act in several places with different connotations and shades. The phrase "total income" used in section 10A is one such variant. The phrase need not necessarily mean the total income as computed in accordance with the provisions of the Act. The relief under this section is with reference

ADDL. CIT, GHAZIABAD vs. M/S. AMRIT CORP LTD., GHAZIABAD

Appeal stand allowed for statistical purposes

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2007-08 Ay: 2008-09

reassessment proceedings for the said assessment years were quashed holding that- a) “there was complete disclosure of all material facts relating to land by the assessee during the course of assessment proceedings and there was no failure on the part of assessee to disclose fully and truly all the material facts necessary for the assessment-years under consideration; b) there

AMRIT CORP LTD.,GHAZIABAD vs. ADDL. CIT, GHAZIABAD

Appeal stand allowed for statistical purposes

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2007-08 Ay: 2008-09

reassessment proceedings for the said assessment years were quashed holding that- a) “there was complete disclosure of all material facts relating to land by the assessee during the course of assessment proceedings and there was no failure on the part of assessee to disclose fully and truly all the material facts necessary for the assessment-years under consideration; b) there

ADDL. CIT, GHAZIABAD vs. M/S AMRIT CORP LTD., GHAZIABAD

Appeal stand allowed for statistical purposes

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2007-08 Ay: 2008-09

reassessment proceedings for the said assessment years were quashed holding that- a) “there was complete disclosure of all material facts relating to land by the assessee during the course of assessment proceedings and there was no failure on the part of assessee to disclose fully and truly all the material facts necessary for the assessment-years under consideration; b) there

AMRIT CORP LTD.,GHAZIABAD vs. ADDL. CIT, GHAZIABAD

Appeal stand allowed for statistical purposes

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2007-08 Ay: 2008-09

reassessment proceedings for the said assessment years were quashed holding that- a) “there was complete disclosure of all material facts relating to land by the assessee during the course of assessment proceedings and there was no failure on the part of assessee to disclose fully and truly all the material facts necessary for the assessment-years under consideration; b) there

RELIGARE CAPITAL MARKETS LTD.,NOIDA vs. ACIT, NEW DELHI

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

reassessments.—(1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of— (a) two years from the end of the assessment year in which the income was first assessable ; or …. ….. ….. Provided also that in case the assessment year in which the income was first assessable is the assessment year commencing

M/S RELIGARE CAPITAL MARKETS LIMITED,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

reassessments.—(1) No order of assessment shall be made under section 143 or section 144 at any time after the expiry of— (a) two years from the end of the assessment year in which the income was first assessable ; or …. ….. ….. Provided also that in case the assessment year in which the income was first assessable is the assessment year commencing

ACIT, NEW DELHI vs. M/S. HLS ASIA LTD., NEW DELHI

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

reassessment proceedings had claimed the benefit of weighted deduction in respect of warehouse charges on the basis of Section 35B(1)(b)(ix) read with Rule 6AA. The point remains that the head of expenditure on account of which the weighted deduction is claimed by the applicant-company is "warehouse charges". The apex court in CIT v. Assam Frontier

HLS ASIA LTD.,,NEW DELHI vs. CIT, NEW DELHI

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

reassessment proceedings had claimed the benefit of weighted deduction in respect of warehouse charges on the basis of Section 35B(1)(b)(ix) read with Rule 6AA. The point remains that the head of expenditure on account of which the weighted deduction is claimed by the applicant-company is "warehouse charges". The apex court in CIT v. Assam Frontier

M/S. HLS ASIA LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

reassessment proceedings had claimed the benefit of weighted deduction in respect of warehouse charges on the basis of Section 35B(1)(b)(ix) read with Rule 6AA. The point remains that the head of expenditure on account of which the weighted deduction is claimed by the applicant-company is "warehouse charges". The apex court in CIT v. Assam Frontier

DCIT, NEW DELHI vs. M/S. HLS ASIA LTD., NEW DELHI

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

reassessment proceedings had claimed the benefit of weighted deduction in respect of warehouse charges on the basis of Section 35B(1)(b)(ix) read with Rule 6AA. The point remains that the head of expenditure on account of which the weighted deduction is claimed by the applicant-company is "warehouse charges". The apex court in CIT v. Assam Frontier

HLS ASIA LTD.,NEW DELHI vs. CIT- IV, NEW DELHI

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

reassessment proceedings had claimed the benefit of weighted deduction in respect of warehouse charges on the basis of Section 35B(1)(b)(ix) read with Rule 6AA. The point remains that the head of expenditure on account of which the weighted deduction is claimed by the applicant-company is "warehouse charges". The apex court in CIT v. Assam Frontier

DCIT, NEW DELHI vs. M/S. HLS ASIA LTD., NEW DELHI

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

reassessment proceedings had claimed the benefit of weighted deduction in respect of warehouse charges on the basis of Section 35B(1)(b)(ix) read with Rule 6AA. The point remains that the head of expenditure on account of which the weighted deduction is claimed by the applicant-company is "warehouse charges". The apex court in CIT v. Assam Frontier

HLS ASIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

reassessment proceedings had claimed the benefit of weighted deduction in respect of warehouse charges on the basis of Section 35B(1)(b)(ix) read with Rule 6AA. The point remains that the head of expenditure on account of which the weighted deduction is claimed by the applicant-company is "warehouse charges". The apex court in CIT v. Assam Frontier

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

section 148 notices issued on 21st & 20th July, 2022, case-wise respectively. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

section 148 notices issued on 21st & 20th July, 2022, case-wise respectively. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions

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

section 148 notices issued on 21st & 20th July, 2022, case-wise respectively. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions