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

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

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

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

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 INCOME TAX vs. SMT. G. LAKSHMI ARUNA

Bench: K.SOMASHEKAR,UMESH M ADIGA

153 C of the Act will taken as the year of search for the purpose of clause(a) and (b) of sub-section 1 of Section 153A by making reference to proviso to sub-section 1 of Section 153C despite the fact that the first proviso to sub-section 1 of Section 153C refers to second proviso to sub-section

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

153 C of the Act will taken as the year of search for the purpose of clause(a) and (b) of sub-section 1 of Section 153A by making reference to proviso to sub-section 1 of Section 153C despite the fact that the first proviso to sub-section 1 of Section 153C refers to second proviso to sub-section

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

TDS of Rs.6,02,14,066/- and advance tax payment of Rs.59,50,80,000/-. The assessee claimed refund of Rs.17,12,21,725/-. The return of income was processed u/s 143(1) on 31.01.2005 and the case was selected for scrutiny and notice u/s 143(2) was issued on 14.02.2005. A questionnaire was issued on 27.04.2006 calling for certain

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

TDS of Rs.6,02,14,066/- and advance tax payment of Rs.59,50,80,000/-. The assessee claimed refund of Rs.17,12,21,725/-. The return of income was processed u/s 143(1) on 31.01.2005 and the case was selected for scrutiny and notice u/s 143(2) was issued on 14.02.2005. A questionnaire was issued on 27.04.2006 calling for certain

THE COMMISSIONER OF vs. M/S UNITED SPIRITS LTD

Appeal is allowed

Bench: P.S.DINESH KUMAR,M G UMA

153(2A) is applicable only in relation to passing of fresh assessments/re-assessments and not orders passed under section 201(1) and 201(1A) of the Act? " 2. Heard Shri. K.V. Aravind learned standing Counsel for the appellant/Revenue, Shri. T. Suryanarayana, learned Senior Advocate I.T.A No. 366/2017 3 and Smt. Tanmayee Rajkumar, learned Advocate for the respondent. 3. Brief facts

THE COMMISSIONER OF vs. M/S UNITED SPIRITS LTD

Appeal is allowed

Bench: P.S.DINESH KUMAR,M G UMA

TDS) CIRCLE-18(2) NO.59, HMT BHAVAN 4TH FLOOR, BALLARI ROAD GANGANAGAR BENGALURU-560 032 .…APPELLANTS (BY SHRI. K.V. ARAVIND, ADVOCATE) AND: M/s UNITED SPIRITS LTD. (SUCCESSOR TO SHOW WALLACE & CO. LTD.) 6TH FLOOR, UB TOWERS UB CITY, 24, VITTAL MALLYA ROAD I.T.A No.359/2017 2 BENGALURU-560 001 PAN: AACCM 8043J …RESPONDENT (BY SHRI. T. SURYANARAYANA, SENIOR ADVOCATE FOR SHRI

THE COMMISSIONER OF vs. M/S UNITED SPIRITS LTD

Appeal is allowed

Bench: P.S.DINESH KUMAR,M G UMA

TDS) CIRCLE-18(2) NO.59, HMT BHAVAN 4TH FLOOR, BALLARI ROAD GANGANAGAR BENGALURU-560 032 .…APPELLANTS (BY SHRI. K.V. ARAVIND, ADVOCATE) AND: M/s UNITED SPIRITS LTD. (SUCCESSOR TO SHOW WALLACE & CO. LTD.) 6TH FLOOR, UB TOWERS UB CITY, 24, VITTAL MALLYA ROAD I.T.A No.360/2017 2 BENGALURU-560 001 PAN: AACCM 8043J …RESPONDENT (BY SHRI. T. SURYANARAYANA, SENIOR ADVOCATE FOR SHRI

M/S HAJEE A.P.BAVA & COMPANY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

In the result, the appeal is

Bench: ALOK ARADHE,M.NAGAPRASANNA

TDS recoveries. It was further held that as on the end of the accounting year ending on 31.03.2014 a sum of Rs.3,79,64,917.38/- was debited by passing a journal entry and therefore, it 7 is not clear whether the aforesaid amount was offered to tax. It was also held that mere wrong entry in the books of account

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

153(3) of the Act, an order giving effect to the order under Section 263 of the Act is required to be passed by the Assessing Officer within a period of 12 months from the end of the financial year in which the order under Section 263 is - 18 - ITA No.53 of 2024 passed by the Commissioner of Income