PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

reassess the total income of the assessment years in question in separate assessment orders. Consequently, there would be only one assessment order in respect of six assessment years in which total disclosed or undisclosed income would be brought to tax. Consequently, even though an assessment order has been passed under Section 143(1) (a) or under Section 143(3

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

reassess the total income of the assessment years in question in separate assessment orders. Consequently, there would be only one assessment order in respect of six assessment years in which total disclosed or undisclosed income would be brought to tax. Consequently, even though an assessment order has been passed under Section 143(1) (a) or under Section 143(3

THE PR COMMISSIONER OF INCOME TAX vs. M/S VSL MINING COMPANY PVT LTD

Appeal is dismissed as being

Bench: S.G.PANDIT,C.M. POONACHA

143(3) and 153C of the Act are quite different. In that view of the matter, we hold that the protective additions made by the AO in the impugned order of assessment for Assessment Year 2008-09 dated 31.12.2009, are contrary to the provisions of the Act and are therefore to be deleted. Similarly, the addition sustained

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

reassessments without any fetters, if need be. Therefore, it is clear even if an assessment order is passed under Section 143(1) or 143(3

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

reassessments without any fetters, if need be. Therefore, it is clear even if an assessment order is passed under Section 143(1) or 143(3

PR. COMMISSIONER OF INCOME TAX (CENTRAL) vs. SHRI. CHERIAN ABRAHAM

In the result, the appeal stands dismissed

Bench: S.SUJATHA,RAVI V HOSMANI

3. Aravali Engineers [P.] Ltd., V/s. Commissioner of Income-tax [(2011) 11 taxmann.com 291 (Punjab & Haryana)] 4. Commissioner of Income-tax, Bathinda V/s. Panchvati Motors [P.] Ltd., [(2011) 12 taxmann.com 111 (Punjab & Haryana)] 5. Learned counsel Sri.Chythanya.K.K., appearing for the respondent – assessee would submit that reply dated 08.10.2013 was submitted by the assessee pursuant to the notice issued

M/S. MFAR HOLDINGS PVT LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals are allowed in part setting aside

Bench: B M SHYAM PRASAD,T.M.NADAF

Section 143(3) of the IT Act. - 6 - HC-KAR NC: 2025:KHC:43164-DB ITA No. 81 of 2025 5. The appellant contends that it was not aware of the order dated 02.02.2022 No. CIT(A)- 11/BNG/Tr.10103/2010-11 until it received an email communication from its consultant on 08.03.2024 and that the appeal in ITA No.1670/2024 is filed immediately thereafter

THE PR. COMMISSIONER OF INCOME TAX, vs. BASHIR AHMED ABDIRRAJ AM MATTE

The appeal is hereby dismissed

Bench: M.I.ARUN,B. MURALIDHARA PAI

143(3) read with Section 263 of the Act on 27.12.2017, as he did not receive the valuation report from the Departmental Valuation Officer within the time limit. He further contended that irrespective of the number of days of delay in receiving the valuation report, the Assessing Officer gets 60 days time to pass an order under Section

THE COMMISSIONER OF INCOME TAX vs. KENNAMETAL INC,USA

Bench: KRISHNA S DIXIT,RAMACHANDRA D. HUDDAR

143(3) of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’ for short) on 31.12.2009 assessing the tax payable. Aggrieved by the said assessment order, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals) [‘CIT(A)’], which came to be dismissed by order dated 06.10.2010. Being further aggrieved, the assessee preferred an appeal before

M/S THE KARNATAKA STATE CO-OPERATIVE APEX BANK vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, the appeal is disposed of

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

3) read with Section 147 of the Act determined the income of the assessee at Rs.51,71,70,670/- and made following additions: (a) disallowance of contributions made to funds -Rs.10,86,43,782/-. (b) additional loss claimed on sale of securities - Rs.8,28,65,052/-. Being aggrieved, the assessee filed an appeal before the Commissioner of Income Tax (Appeals

PR.COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY INDIA PVT LTD

In the result, we do not find

Bench: ALOK ARADHE,M.G.S. KAMAL

3) of the Act, which reads as under: 153. Time limit for completion of assessments and reassessments. (1) No order of assessment shall be made under Section 143

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

Bench: CHIEF JUSTICE,C M JOSHI

143(3) of the Act in respect of the AY 2017-18. The assessment made was premised on a search conducted in the office premises of the assessee [M/s. Atria Wind (Kadambur) Pvt. Ltd.], on 17.12.2020, under Section 132 of the Act. It was noted that thereafter notice under Section 153A of the Act was issued. The Assessing Officer

M/S MAHESH INVESTMENTS vs. THE ASST. COMMISSIONER OF INCOME-TAX

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

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

reassessment Section 2(40) "regular assessment" means the assessment made under sub- section (3) of] section 143 or section 144. 234A

THE PR.COMMISSIONER OF INCOME TAX vs. M/S. YOKOGAWA INDIA LTD

The appeal is dismissed

Bench: S.G.PANDIT,K. V. ARAVIND

143(2) of the Act. In view of the international transactions, the Assessing Officer referred the matter to the Transfer Pricing Officer (TPO) for determination of the arm’s length price. The TPO, by order dated 29.01.2016 passed under Section 92CA of the Act, determined the adjustment. Thereafter, the Assessing Officer passed a draft assessment order on 10.03.2016. The assessee

SRI. M.R.ANANDARAM (HUF) vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

In the result, the appeal is disposed of

Bench: ALOK ARADHE,R. NATARAJ

3 (ii) Whether the Tribunal ought to have held that the mandatory conditions to assume jurisdiction under section 148 does not exist and consequently ought to have also quashed the reassessment proceedings on the facts of the case. (iii) Whether the Tribunal was justified in law in not adjudicating the legal ground of reopening which goes to the root

THE COMMISSIONER OF vs. M/S ABB INDIA LTD

Bench: P.S.DINESH KUMAR,M G UMA

143(3) of the Act, the AO had sent a questionnaire vide his communication dated 04.05.2011 calling for explanation from the assessee. In response, the assessee submitted its reply on 04.07.2011 and 05.10.2011 and explained that provisions were created with regard to the technical fees for the A.Y.2003-04 to 2007-08 and had not deducted the tax during the respective

ABB INDIA LTD vs. JOINT COMMISSIONER OF

Bench: P.S.DINESH KUMAR,M G UMA

143(3) of the Act, the AO had sent a questionnaire vide his communication dated 04.05.2011 calling for explanation from the assessee. In response, the assessee submitted its reply on 04.07.2011 and 05.10.2011 and explained that provisions were created with regard to the technical fees for the A.Y.2003-04 to 2007-08 and had not deducted the tax during the respective

THE COMMISSIONER OF INCOME TAX vs. M/S. ASTRA ZENECA PHARMA

In the result, the order passed by the

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

143(1) to the assessee. The assessing officer by an order dated 26.03.1999 passed an order of assessment and inter alia quantified the total taxable income at Rs.8,38,38,080/-. 100% Depreciation claimed by the assessee on pollution control equipment worth Rs.4,93,00,000/- was 6 disallowed and 80% interest on the amount advanced to Madhya Pradesh State