M/S KARNATAKA STATE INDUSTRIAL AND INFRASTRUCTURE DEVELOPMENT CORPORATION LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeal is allowed and the impugned

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 39(1) of the Karnataka Value Added Tax Act, 2003 [for short, 'the KVAT Act'] for the tax- period between April 2013 and March 2014. The appellant has failed in the reassessment proceedings on two issues viz., [i] the disallowance of Input Tax Credit [ITC] of Rs.36,600/- claimed by the appellant on the purchase from

AZIM PREMJI TRUSTEE COMPANY PVT LTD vs. DEPUTY COMMISSIONER OF INCOME TAX

In the result, I pass the following:-

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

6. It cannot be disputed that by substitution of sections 147 to 151 of the Income Tax Act (IT Act) by the Finance Act, 2021, radical and reformative changes are made governing the procedure for reassessment proceedings. Amended sections 147 to 149 and section 151 of the IT Act prescribe the procedure governing initiation of reassessment proceedings. However, for several

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

reassessment under Section 147 read with Section 144 by bringing to tax all the income which formed part of 6 total income under the original assessment order passed. However, it was noticed that though the assessment proceedings was initiated by issue of notice under Section 143(2), The Tribunal vide said order also knocked down the assessment proceedings completed under

THE PR COMMISSIONER OF INCOME TAX vs. M/S ATRIA WIND (KADAMBUR) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

6 - HC-KAR NC: 2025:KHC:34452-DB ITA No. 103 of 2025 jurisdiction of the AO to make assessment is confined to incriminating material found during the course of search under Section 132 or requisition under Section 132-A or not i.e. whether any addition can be made by the AO in absence of any incriminating material found during

THE COMMISSIONER OF INCOME TAX vs. KENNAMETAL INC,USA

Bench: KRISHNA S DIXIT,RAMACHANDRA D. HUDDAR

reassessment or recomputation could be made at any time. The amended sub-section (3) of Section 153 introduced by the Finance Act, 2016 is not applicable to the present case in view of sub-section (9) of the said provision. As per sub-section (9) of Section 153, inserted by the Finance Act, 2016, the assessment pursuant to an order

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

reassessment under Section 147 read with Section 144 by bringing to tax all the income which formed part of 5 total income under the original assessment order passed. However, it was noticed that though the assessment proceedings was initiated by issue of notice under Section 143(2), The Tribunal vide said order also knocked down the assessment proceedings completed under

M/S B L KASHYAP & SONS LTD vs. JOINT COMMISSIONER OF COMMERCIAL

Bench: S.SUJATHA

6. In support of his contentions, learned Counsel for the petitioner placed reliance on the following Judgments: [a] ‘THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES v. H.R. SRI RAMULU’ reported in 1977 [39] STC 177. [b] ‘V. JAGANMOHAN RAO v. COMMISSIONER OF COMMERCIAL TAX AND EXCESS PROFITS TAX, ANDHRA PRADESH’ reported in 1970 [75] ITR 373. [c] ‘M/s. KUNDAN LAL SRIKISHAN

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

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

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153A of the Act the Assessing Officer shall assess or reassess the "total income" of six assessment years which means the said total income includes income which was returned in the earlier return, the income which was unearthed during search and income which is not the subject matter of aforesaid two income….” - 28 - 11. In M/s Lancy Constructions supra

MR. JITENDRA VIRWANI vs. JOINT COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr. Justice B. M. Shyam Prasad

6 Or, from any other authority under any law for the time being in force, or on coming to know of information 18 production of documents or accounts or evidence as may be required for the purposes of the BM Act with jurisdiction to issue further notices. The provisions of Section 10[2] of the BM Act confers jurisdiction