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7 results for “reassessment”+ Permanent Establishmentclear

Sorted by relevance

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Key Topics

Addition to Income5Section 1484Section 173(1)4Deduction4Section 201(1)3Reassessment3Section 1472Section 2602TDS2

MPHASIS CORPORATION vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

WP/45709/2017HC Karnataka21 Nov 2017

Bench: The Hon'Ble Dr.Justice Vineet Kothari

Section 148Section 9(1)(vii)

Permanent Establishment (P.E.) in India and therefore, the impugned notice is without jurisdiction. Date of Order -21-11-2017 W.P.No.45709/2017 Mphasis Corporation vs. The Assistant Commissioner of Income Tax and Others. 8/12 (iv) Learned counsel for the petitioner submitted that all these objections have been raised before the Respondent-Assessing Authority and he has not yet decided the same

MPHASIS UK LIMITED vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

WP/46009/2017HC Karnataka15 Dec 2017

Bench: The Hon'Ble Dr.Justice Vineet Kothari

Section 147
Section 148

Permanent Establishment Date of Order 15-12-2017 W.P.No.46009/2017 Mphasis U K Limited Vs. The Assistant Commissioner of Income Tax, International Taxation & others. 5/7 in India or not is certainly a mixed question of fact and law and that depends upon several facts to be established by the assessee upon being questioned by the Respondent – Assessing Authority. The process

MPHASIS DEUTSCHLAND GMBH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

WP/45710/2017HC Karnataka15 Dec 2017

Bench: The Hon'Ble Dr.Justice Vineet Kothari

Section 147Section 148

Permanent Establishment Date of Order 15-12-2017 W.P.No.45710/2017 Mphasis Deutschland GMBH Ltd. Vs. The Assistant Commissioner of Income Tax, International Taxation & others. 5/7 in India or not is certainly a mixed question of fact and law and that depends upon several facts to be established by the assessee upon being questioned by the Respondent – Assessing Authority. The process

THE DIRECTOR OF INCOME TAX vs. THE EXECUTIVE ENGINEER

ITA/166/2011HC Karnataka24 Aug 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 201(1)Section 201(3)Section 231Section 260Section 260A

permanent establishment in India and therefore, the payment would be subject to tax at the maximum rate of 40% applicable to any foreign company and the assessee action in remitting tax at the rate of 40% had resulted in short remittance. The assessee was held as an assessee in default in terms of Section

M/S KAYPEE ELECTRONICS & ASSOCIATES PVT LTD vs. THE DEPUTY COMMISSIONER

Appeal are disposed of

ITA/65/2018HC Karnataka29 May 2018

Bench: The Hon'Ble Mr.Justice S. Sunil Dutt Yadav

Section 173(1)

permanent disability of 50%. According to the established procedure and that the certificates given by him are not reflective of true facts, but in the evidence that has been led by the claimant, there is an averment at para 6 of the affidavit that there is difficulty to walk properly and there is a limp, difficulty to climb stairs, drive

THE COMMISSIONER OF INCOME TAX vs. SMT. SUNITA TONY

In the result, all the appeals which are filed by

ITA/163/2014HC Karnataka31 Aug 2015

Bench: B.MANOHAR,VINEET SARAN

Section 173(1)

established the fact that the KSRTC bus had to take a diversion on account of the closure of the road on its side and had to proceed on the opposite side of the National Highway. Judicial notice could also be taken of the fact that at the relevant point of time NH 4 was being formed and therefore inevitably

THE COMMISSIONER OF INCOME TAX vs. M/S IBM GLOBAL SERVICES INDIA PVT LTD

Appeals are dismissed

ITA/443/2008HC Karnataka19 Nov 2018

Bench: The Hon'Ble Mr. Justice H.P. Sandesh

Section 100

permanent injunction and the said suit was compromised on 30.07.1983. The defendant No.1 agreed to purchase the said properties for Rs.1,08,000/- towards the share of the plaintiffs. On 06.06.1983, the defendant with the aid of the police forced the plaintiff No.1 to sell his share in the schedule property for 14 Rs.85,000/- even though the consideration