PR. COMMISSIONER OF INCOME TAX vs. SMT. G. LAKSHMI ARUNA

Bench: K.SOMASHEKAR,UMESH M ADIGA

reassessment under Section 147 read with Section 144 by bringing to tax all the income which formed part of 6 total income under the original assessment order passed. However, it was noticed that though the assessment proceedings was initiated by issue of notice under Section 143(2), The Tribunal vide said order also knocked down the assessment proceedings completed under

PR. COMMISSIONER OF INCOME TAX vs. SHRI. GALI JANARDHANA REDDY

Bench: K.SOMASHEKAR,UMESH M ADIGA

reassessment under Section 147 read with Section 144 by bringing to tax all the income which formed part of 5 total income under the original assessment order passed. However, it was noticed that though the assessment proceedings was initiated by issue of notice under Section 143(2), The Tribunal vide said order also knocked down the assessment proceedings completed under

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

THE PR. COMMISIONER INCOME TAX vs. M/S. GMR INFRASTRUCTURE LTD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

THE PR. COMMISIONER OF INCOME TAX vs. M/S. GMR INFRASTRUCTURE LTD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR. COMMISSIONER OF INCOME TAX (CENTRAL) vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD.,

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

THE PR. COMMISIONER OF INCOME TAX vs. M/S. GMR INFRASTRUCTURE LTD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

DELL INDIA PVT LTD vs. THE JOINT COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr.Justice Aravind Kumar

reassess the income of petitioner under section 147 of the Act. Said reason assigned by the Assessing officer on being furnished came to be replied by petitioner- assessee by challenging the same on the grounds indicated in reply dated 09.05.2014 Annexure-N. Assessing officer after considering the said reply rejected the contentions raised for the reasons indicated in the communication

MPHASIS UK LIMITED vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Bench: The Hon'Ble Dr.Justice Vineet Kothari

reassessment proceedings. Firstly, not only the proceedings have been initiated way-back in the year 2015 and the proceedings are still pending before the said Assessing Authority, who is yet to decide all these objections raised by the assessee by an appropriate order, but also because the nature of objections raised before this Court do not render the proceedings

MPHASIS DEUTSCHLAND GMBH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Bench: The Hon'Ble Dr.Justice Vineet Kothari

reassessment proceedings. Firstly, not only the proceedings have been initiated way-back in the year 2015 and the proceedings are still pending before the said Assessing Authority, who is yet to decide all these objections raised by the assessee by an appropriate order, but also because the nature of objections raised before this Court do not render the proceedings

MPHASIS CORPORATION vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Bench: The Hon'Ble Dr.Justice Vineet Kothari

reassessment proceedings. Firstly, not only the proceedings have been initiated way-back in the year 2015 and the proceedings are still pending before the said Assessing Authority, who is yet to decide all these objections raised by the assessee by an appropriate order, but also because the nature of objections raised Date of Order -21-11-2017 W.P.No.45709/2017 Mphasis

THE COMMR OF INCOME TAX vs. M/S WIPRO LTD

Bench: RAVI MALIMATH,N.KUMAR

TDS. Therefore, the assessing officer disallowed the expenditure. The assessee had claimed warranty expenses as deduction. The same was also disallowed on the ground that it was only a provision to be treated as a contingent liability. The assessee had claimed a sum of Rs.2,36,04,819 as deduction of excise duty under Section