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9 results for “reassessment”+ Section 10A(5)clear

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Key Topics

Section 115J21Section 143(3)12Section 45(2)12Section 26011Section 10A8Section 1476Section 244A5Section 260A4Deduction4Reassessment

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/20040/2019HC Karnataka25 Aug 2021

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

Section 1Section 143(2)Section 143(3)Section 244ASection 254Section 92C

section 244A(1A) would apply to cases covered u/s 153(5); thus where, in respect of certain issues, order giving effect to be passed u/s 153(5), otherwise than by making a fresh assessment or reassessment is passed beyond the prescribed 42 time-limit, interest u/s 244A(1A) has to be granted in respect of refund arising on such issues

THE COMMISSIONER OF INCOME TAX, CIT(A) vs. M/S HEWLETT PACKARD GLOBALSOFT PVT LTD

Appeals are hereby dismissed by

3
Capital Gains2
Depreciation2
ITA/65/2014HC Karnataka14 Aug 2015

Bench: ARAVIND KUMAR,VINEET SARAN

Section 10Section 10ASection 143(3)Section 148Section 260

5. It is the contention of Sri K.V.Aravind, learned Advocate for the revenue that Tribunal erred in holding that assessing Officer sought to initiate the re-assessment proceedings by mere change of opinion, without considering the fact that the 7 expenditure related to onsite development of computer software and same had not been examined in the original assessment

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

ITA/107/2025HC Karnataka12 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 10ASection 14ASection 260Section 260A

5) The advance pricing agreement entered into shall be binding— (a) on the person in whose case, and in respect of the transaction in relation to which, the agreement has been entered into; and (b) on the Principal Commissioner or Commissioner, and the income-tax authorities subordinate to him, in respect of the said person and the said transaction

M/S SANKHLA POLYMERS (P) LTD vs. THE INCOME TAX OFFICER WARD-12(2)

In the result, the appeal relating to the assessment

ITA/1100/2006HC Karnataka29 Jan 2013

Bench: D.V.SHYLENDRA KUMAR,B.SREENIVASE GOWDA

Section 115JSection 148Section 260ASection 80

reassessing the income for the assessment year 2002-03 by issue of notice under Section 148 of the Act and tax liability had been determined as per the amendment to Section 115JB. 5 7. For the subsequent two assessment years, the assessee being fully aware of the provisions of this Section and having filed returns, they had been assessed

M/S YOKOGAWA INDIA LTD vs. THE DEPUTY COMMISSIONER

In the result, the appeal is disposed of

ITA/87/2012HC Karnataka04 Jun 2020

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 115JSection 143(1)Section 143(2)Section 260Section 260A

5. Learned counsel for the assessee submitted that loss brought forward and unabsorbed depreciation has to be taken as per books of accounts and not as per balance sheet. It is further submitted that tribunal ought to have reduced the lower of the brought forward loss and unabsorbed depreciation as per books of account relating to non 10A unit while

THE COMMISSIONER OF INCOME TAX vs. SYNDICATE BANK

ITA/97/2010HC Karnataka17 Jan 2020

Bench: ALOK ARADHE,RAVI V HOSMANI

Section 115JSection 143(1)Section 14ASection 260

10A, 10B 11 or 12 of the Act? 6 3. On account of similarity of the issues involved in the substantial questions of law, they were heard analogously and are being decided by this common judgment. For the facility of reference, facts from ITA No.97/2010 are being referred to. 4. The assessee filed a return of income on 28.11.2000 declaring

THE COMMISSIONER OF INCOME TAX vs. M/S CHAITANYA PROPERTIES PVT LTD.,

The appeal is dismissed

ITA/205/2015HC Karnataka16 Feb 2016

Bench: S.SUJATHA,JAYANT PATEL

Section 143(3)Section 147Section 260Section 45(2)

10A, even that nexus is manifest. The Assessing 14 Authority has not properly applied his mind towards the statutory provisions and has not taken into consideration that the original assessment passed under Section 143(3) which was also reopened once and adjustment was made. It is for the second time, he was raising all these objections. When admittedly the second

COMMISSIONER OF INCOME TAX (APPEALS) vs. M/S POST & BSNL EMPLOYEES

The appeal is dismissed

RP/205/2015HC Karnataka24 Jul 2015

Bench: N.KUMAR,RATHNAKALA

Section 143(3)Section 147Section 260Section 45(2)

10A, even that nexus is manifest. The Assessing 14 Authority has not properly applied his mind towards the statutory provisions and has not taken into consideration that the original assessment passed under Section 143(3) which was also reopened once and adjustment was made. It is for the second time, he was raising all these objections. When admittedly the second

PR. COMMISSIONER OF vs. M/S SASKEN

ITA/450/2016HC Karnataka23 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 148Section 260Section 292B

reassessment proceedings and had filed return in response to 147 notice and contested the proceedings actively and decisions relied upon by Tribunal have not been reached finality, further without taking note of section 292BB of the Act?” 3. The learned Tribunal, after discussing the rival contentions of both the Appellants-Revenue and Respondent-Assessee, has returned the findings as under