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

reassessment proceedings as per the substituted provisions of sections 147 to 151 of the IT Act as per the Finance Act, 2021, subject to compliance of all the procedural requirements and the defences, which may be available to the assessee under the substituted provisions of sections 147 to 151 of the IT Act and which may be available under

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

Bench: CHIEF JUSTICE,C M JOSHI

reassessment under Section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the assessing officer could have passed under Section 147 of the Act as well as under Section 153-A of the Act.” 28. For the reasons stated hereinbelow, we are in complete agreement with

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

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 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

Section 153(A)(1) is annulled, the assessment or reassessment that stood abated shall stand revived. 12. Once it is held

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

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

Bench: S.SUJATHA

reassessment arises because of turnover escaping assessment in a limited field or only - 11 - with respect to a part of the matter covered by the initial assessment order.” 12. Similarly, in the case of JAGANMOHAN RAO supra, the Hon’ble Apex Court has observed as under: “Section

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

COMMISSIONER OF INCOME vs. M/S C RAMAIAH REDDY

In the result, we do not find any merit in the appeal

Bench: ALOK ARADHE,M.NAGAPRASANNA

reassessment or recomputation as specified in sub-section (2) of section 153, every such notice referred to in this clause shall be deemed to be a valid notice. Explanation.—For the removal of doubts, it is hereby declared that nothing contained in the first proviso or the second proviso shall apply to any return which has 12

COMMISSIONER OF INCOME TAX TDS vs. M/S BHARAT HOTELS LIMITED

Appeal stands dismissed

Bench: S.SUJATHA,VINEET SARAN

12 Court, as well as the Delhi, Kerala, Punjab & Haryana High Courts, held that the proceedings having been initiated by the Revenue beyond the period of four years from the end of the relevant financial year, would be barred by limitation. Challenging the same, Sri K V Aravind, learned counsel for the Revenue has vehemently argued that when there

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

Appeals are hereby dismissed by

Bench: ARAVIND KUMAR,VINEET SARAN

reassessment was passed under Section 143(3) read with Section 147 on 31.12.2007. 12 This was carried in appeal by the assessee