M/S EMBASSY BRINDAVAN DEVELOPERS vs. THE COMMISSIONER OF INCOME TAX

Appeal is allowed

Bench: P.S.DINESH KUMAR,UMESH M ADIGA

Section 263 of the IT Act is correct or not, we have perused the order passed by the Assessing Officer. In his view, he has recorded that the property in question was purchased to construct a Tech Park and for paucity of funds, it could not be developed and the land was ultimately sold. This factual aspect is not disputed

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

section 263 of the Act. To substantiate his contention, he has taken us through paragraph 9 of the reasoning given by the Tribunal wherein it is stated that in respect of applicability of TDS

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

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

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 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 PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

TDS, stated that they have not rendered any services to the assessee. It was found that some of them never owned any transportation vehicles and some of them did not have any means. Further, some of the vehicles were not transport vehicles but were autos, scooters, ambulances and school buses etc. However, on an examination of the bank accounts

TIMES VPL LIMITED vs. THE COMMISSIONR OF INCOME TAX

In the result, the order passed by the

Bench: ALOK ARADHE,P.G.M.PATIL

263(1) of the Act, which reads as under: “It is quite manifest from the above that the VPL has to make the payment on monthly basis, therefore the ownership of the space does not pass on to the assessee company forever. Therefore, the transaction cannot be termed as purchase as contended by the assessee company and the same

M/S. ANSYS SOFTWARE PRIVATE LIMITED vs. THE COMMISSIONER OF INCOME-TAX

In the result, the appeal is allowed

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

section 263 of the Act on the facts and circumstances of the case? 2. Whether the Tribunal was justified in holding that the learned assessing officer before completing the assessment, has failed to make proper and adequate enquiry as regard to the TDS

THE COMMISSIONER OF INCOME TAX, vs. SHRIDHAR SHANTINATH PATRAVALI,

Bench: This Court : I. Whether On Facts & In Law The Tribunal Is Right In Ignoring The Provisions Of Second & Third Provisos To Section 194C(3), As Per Which The Assessee Respondent Was Under Obligation To Furnish Particulars Of The Declaration Filed By The Sub-Contractors In Form No.15-I Within Due Date I.E., 30.06.2008, In The Manner Prescribed I.E., Form No. 15J, To The Prescribed Authority & Failure To Do So, Attracts Violation Of Provisions Of Section 194C(3) Viz., Disallowance Under Section 40(A)(Ia)?

263 of the Act by determining the revised income at Rs.57,56,290/- , along with other additions, an addition of Rs.48,61,154/- was also made to the total income of the assessee. The latter amount is the amount of disallowance under Section 40(a)(ia) of the Act. By order dated 21.01.2013, the Assessing Authority observed that since

THE COMMISSIONER OF INCOME TAX vs. M/S VIJAYA BANK

Bench: The Tribunal Which Has Been Allowed. Aggrieved By The Same, This Appeal Has Been Filed By The Revenue On The Following Two Questions Of Law: “I. Whether The Tribunal Was Correct In Holding That Disallowance Under Section

TDS by the assessee-respondent (Vijaya Bank), suo moto revisional power under Section 263 of the Income Tax Act, 1961 (for short

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

TDS 28,20,543 Balance Tax 14,76,04,186 Less: Advance Tax 7,50,00,000 Balance Tax 7,26,04,186 Add: Interest u/s234A – 1,30,68,753 12 235B – 1,59,97,806 2,90,66,559 Total Tax 10,16,70,745 Less: 140A paid 2,00,00,000 Net Amount Payable