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13 results for “reassessment”+ Section 144C(2)clear

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Key Topics

Section 26034Section 143(3)5Section 143(2)5Section 92C5Section 1475Section 1485Section 244A5Transfer Pricing5Addition to Income4

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

The appeal is dismissed

ITA/431/2022HC Karnataka26 Sept 2025

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

Section 143(2)Section 143(3)Section 144C(13)Section 144C(4)Section 260Section 92C

2) by the eligible assessee. (14A) The provisions of this section shall not apply to any assessment or reassessment order passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner as provided in sub-section (12) of section 144BA.] (14B) The Central Government may make a scheme, by notification in the Official Gazette

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

Section 144C(13)3
Limitation/Time-bar2
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

144C(1), to which petitioner filed his Objections before the Dispute Resolution Panel (hereafter 'DRP'); in terms of DRP order dated 17.09.2012, the JCIT assessed the income at Rs.2389,89,57,307/- against the original amount of Rs.588,08,04,584/- supra. (b) Both the Assessee and the Revenue having appealed against the above, the Income Tax Appellate Tribunal (hereafter

DEVAS MULTIMEDIA PRIVATE LIMITED vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX

WP/11618/2016HC Karnataka27 Sept 2019

Bench: The Hon’Ble Mr.Justice P.B. Bajanthri Writ Petition No.11618 Of 2016 (T-It) Between:

Section 142(4)Section 143(2)Section 143(3)Section 144Section 144CSection 263Section 92C

144C of the Act, the Commissioner loses his jurisdiction to 14 exercise power under Section 263 of the Act. Consequently, the Commissioner cannot issue a show cause notice under Section 263 exercising his revisionary powers, especially when the legislature has specifically (a) created a separate mechanism of DRP; and (b) has barred any statutory appeal against the order. Therefore

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/514/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/512/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/513/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/509/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

ITA/515/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

M/S. HIMALAYA DRUG COMPANY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

ITA/441/2014HC Karnataka15 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding

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

In the result, we do not find

ITA/307/2018HC Karnataka06 Apr 2021

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

Section 143(2)Section 153(1)(a)Section 153(3)(ii)Section 260Section 260ASection 92C

144C of the Act and therefore, the order passed by the tribunal deserves to be quashed. In support of aforesaid submissions, reliance has been placed on decision of this court in 'COMMISSIONER OF INCOME TAX, LTU VS. ASTRA ZENECA PHARMA INDIA LTD.,(2020) 117 TAXMANN.COM 533 (KARNATAKA). 5. On the other hand, learned Senior counsel for the assessee submitted that

PR COMMISSIONER OF vs. M/S QUANTECH GLOBAL SERVICES LTD

ITA/439/2018HC Karnataka04 Feb 2021

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 143(2)Section 260Section 268

144C of the IT Act. The undisputed facts also reveal that the respondent company pursuant to the scheme of amalgamation stood merged with the Wipro Limited, the Scheme of amalgamation was approved by the High Court of Andhra Pradesh vide order dated 21.02.2008 and by the High Court of Karnataka vide order dated 10.01.2008 with effect from

DELL INDIA PVT LTD vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/8901/2015HC Karnataka23 Mar 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

Section 143(3)Section 144CSection 147Section 148

reassessment and order passed by first respondent holding that there is no error of jurisdiction. In order to examine the issue involved in this present petition facts relevant for the said purpose requires to be noticed which are as under. 2. Petitioner is engaged in the manufacture and sale of computer hardware and related products. For the assessment year

XIAOMI TECHNOLOGY INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

In the result, I pass the following:

WP/16692/2022HC Karnataka16 Dec 2022

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

Section 281BSection 281ESection 92C

2. CITI Bank-Tech 521656018 1100,00,00,000 Total 3700,00,00,000 8. In view of the above stated reasons, I am of the opinion that for purpose of protecting the interest of revenue it is necessary to provisionally attach the fixed deposits tot he extent of Rs. 3,700 crores held by the assessee as mentioned