PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, DELHI

u/s 147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

DHARAMVIR KHOSLA ,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

147, 148, 149, 151 and 153.\n8.2 Having noticed the above, we may also refer to the second and the third\nproviso to section 153A(1). For the sake of convenience, the second and\nthird proviso to section 153A(1) of the said Act which is relevant is\nreproduced below and reads thus:\nProvided further that assessment or reassessment

LENIENT CONSULTANTS PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-2, NOIDA

In the result, the appeal of the Assessee is partly allowed\nas indicated above

reassessment shall be passed\nby an Assessing Officer below the rank of Joint Commissioner\nin respect of each assessment year referred to in clause (b) of\nsub-section (1) of section 153A, or the assessment year\nreferred to in clause (b) of sub-section (1) of section 153B,\nexcept with the prior approval of the Joint Commissioner.”\n8. As argued

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

1)(b) of the Act states the assessing officer shall assess or reassess the total income of the six years immediately preceding the assessment year....... and for the relevant assessment year under this section. Thereafter, the first proviso u/s 153A of the Act also mandates that the Assessing Officer shall assess or reassess the total income in respect of each

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-I, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

1)(b) of the Act states the assessing officer shall assess or reassess the total income of the six years immediately preceding the assessment year....... and for the relevant assessment year under this section. Thereafter, the first proviso u/s 153A of the Act also mandates that the Assessing Officer shall assess or reassess the total income in respect of each

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

1)(b) of the Act states the assessing officer shall assess or reassess the total income of the six years immediately preceding the assessment year....... and for the relevant assessment year under this section. Thereafter, the first proviso u/s 153A of the Act also mandates that the Assessing Officer shall assess or reassess the total income in respect of each

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

1)(b) of the Act states the assessing officer shall assess or reassess the total income of the six years immediately preceding the assessment year....... and for the relevant assessment year under this section. Thereafter, the first proviso u/s 153A of the Act also mandates that the Assessing Officer shall assess or reassess the total income in respect of each

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

1)(b) of the Act states the assessing officer shall assess or reassess the total income of the six years immediately preceding the assessment year....... and for the relevant assessment year under this section. Thereafter, the first proviso u/s 153A of the Act also mandates that the Assessing Officer shall assess or reassess the total income in respect of each

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

1)(b) of the Act states the assessing officer shall assess or reassess the total income of the six years immediately preceding the assessment year....... and for the relevant assessment year under this section. Thereafter, the first proviso u/s 153A of the Act also mandates that the Assessing Officer shall assess or reassess the total income in respect of each

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

1)(b) of the Act states the assessing officer shall assess or reassess the total income of the six years immediately preceding the assessment year....... and for the relevant assessment year under this section. Thereafter, the first proviso u/s 153A of the Act also mandates that the Assessing Officer shall assess or reassess the total income in respect of each

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PRAKASH INDUSTRIES LTD., HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

ACIT, CC-30, NEW DELHI vs. AMARJYOTI VANIJYA PVT. LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

1), which is as under :- “Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer

ACIT, CC-30, NEW DELHI vs. AMARJYOTI VANIJYA PVT. LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

1), which is as under :- “Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

ACIT. CENTRAL CIRCLE- 30, NEW DELHI vs. AMARJYOTI VANIJYA (P) LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

1), which is as under :- “Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PRAKASH INDUSTRIES LTD., HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

reassessment under section 147 shall abate.Assessments under section 153A i.e, “Assessment in case of search or requisition” shall not abate by operation of section 153A itself. In the year of search, no notice has to be issued under section 153A consequent to a search. However in the 6 preceding years, notice under 153A has to be mandatorily issued