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

143(3) r/w Section 153A of the Act by following the judgment of this Hon’ble High Court in the case of M/s Lancy Constructions? In ITA Nos.354/2018 and 355/2018: “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

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

143(3) r/w Section 153A of the Act by following the judgment of this Hon’ble High Court in the case of M/s Lancy Constructions? In ITA Nos.354/2018 and 355/2018: “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

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

143(3) r/w Section 153A of the Act by following the judgment of this Hon’ble High Court in the case of M/s Lancy Constructions? In ITA Nos.354/2018 and 355/2018: “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

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

143(3) r/w Section 153A of the Act by following the judgment of this Hon’ble High Court in the case of M/s Lancy Constructions? In ITA Nos.354/2018 and 355/2018: “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

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

143(3) r/w Section 153A of the Act by following the judgment of this Hon’ble High Court in the case of M/s Lancy Constructions? In ITA Nos.354/2018 and 355/2018: “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

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

143(3) r/w Section 153A of the Act by following the judgment of this Hon’ble High Court in the case of M/s Lancy Constructions? In ITA Nos.354/2018 and 355/2018: “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

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

143(3) r/w Section 153A of the Act by following the judgment of this Hon’ble High Court in the case of M/s Lancy Constructions? In ITA Nos.354/2018 and 355/2018: “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

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

143(3) r/w Section 153A of the Act by following the judgment of this Hon’ble High Court in the case of M/s Lancy Constructions? In ITA Nos.354/2018 and 355/2018: “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

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S. TE CONNECTIVITY INDIA PVT. LTD.,

Accordingly dispose of the appeal as allowed

Bench: ACTING CHIEF JUSTICE,S RACHAIAH

143(3) read with Section 144C(13) of the Act was passed on 18.12.2018. Aggrieved by the DAO, the respondent-assessee filed objections to the same. The objections were disposed of, pursuant to which, the Assessing Officer passed the final assessment order dated 25.10.2019. Subsequently, the appellant-PCIT initiated proceedings under Section 263 of the Act on 19.03.2022 seeking

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

143(2), The Tribunal vide said order also knocked down the assessment proceedings completed under Section 144 read with Section 153D on similar ground that no satisfaction note was recorded by the assessing officer of the searched persons which is factually not applicable to the proceedings for the year under consideration. 4. Being aggrieved with the decision of the Tribunal

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

143(2), The Tribunal vide said order also knocked down the assessment proceedings completed under Section 144 read with Section 153D on similar ground that no satisfaction note was recorded by the assessing officer of the searched persons which is factually not applicable to the proceedings for the year under consideration. 4. Being aggrieved with the decision of the Tribunal

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

Bench: The Hon’Ble Mr.Justice Aravind Kumar

143(3) read with Section 144C of the Act came to be passed on 31.01.2014, Annexure-H. Being aggrieved by the same petitioner is said to have filed an appeal and same is filed before first appellate authority and same is pending. 3. First respondent has issued a notice under section 148 of the Income Tax Act to the petitioner

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

143(3) of the Income Tax Act, 1961 by adopting the above adjustments to the value of the international transactions and the income of the assessee came to be upwardly revised by an amount of Rs.112,20,92,081/-. The assessee filed an appeal before the ‘Dispute Resolution Panel' (DRP) Bengaluru, which by its order dated 29.11.2013, upheld the adjustments

THE COMMISSIONER OF INCOME TAX vs. M/S ALLOY STEELS,

Accordingly, the appeal filed by the appellant is allowed

Bench: N.K.PATIL,B.MANOHAR

TDS provisions are applicable to the assessee in respect of Labour Charges, Felting Charges and Moulding Charges whereas, prima facie, no examination was done by the Assessing Officer? iv) Whether the ITAT is right in law and on facts in allowing the deduction claimed on account of Keyman Insurance Premium in the name of partner which is against the requirement

COMMISSIONER OF INCOME TAX TDS vs. M/S BHARAT HOTELS LIMITED

Appeal stands dismissed

Bench: S.SUJATHA,VINEET SARAN

143(3) of the Act on 28.2.2005, which was within the period prescribed under Section 153 of the Act. Besides this, the return of income of the assessee for the relevant assessment year 2002-03 was also filed and accepted by the Revenue, in which the aforesaid payments to KKFHPL were reflected. At no stage the question of deduction

MPHASIS LTD vs. DEPUTY COMMISSIONER OF INCOME TAX

Bench: The Hon'Ble Mr. Justice Krishna S.Dixit

143 or this section has been made for the relevant assessment year, no action shall be taken 4 under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment for such assessment year by reason of the failure on the part of the assessee

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S. PUMA SPORTS INDIA P., LTD.,

The appeal stands dismissed

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

143(3) read with Section 144(C)(13) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’) by making transfer pricing adjustment for Rs.4,16,65,106/- on the basis of the order passed under Section 92CA of the Act dated 24.10.2016. The assessing authority also made other additions. The assessee’s objections were not considered

PR COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY SOLUTIONS PVT LTD

In the result, the appeals fail and are hereby

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

TDS on payments made in respect of purchase of intellectual property rights by following its earlier order which has not reached finality and even when the ingredients of 7 section 40(a)(ia) of the Act are satisfied in case of assessee? 4. Facts leading to filing of these appeals briefly stated are that assessee is engaged in business