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 taking notice of undisclosed income even found during the search and seizure operation. The fetter imposed upon the Assessing Officer under Sections 147

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

reassess the total income taking notice of undisclosed income even found during the search and seizure operation. The fetter imposed upon the Assessing Officer under Sections 147

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

reassess the total income taking notice of undisclosed income even found during the search and seizure operation. The fetter imposed upon the Assessing Officer under Sections 147

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

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

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

PR. COMMISSIONER OF INCOME TAX-4 vs. RAJKUMAR C (HUF)

In the result, the order passed by the

Bench: ALOK ARADHE,R. NATARAJ

147, Section 150 and clause (a) and (b) to Explanation 2 to Section 153, which read as under: Explanation 2 - For the purposes of this section, the following shall also be deemed to be cases where income chargeable to tax has escaped assessment, namely:- 13 Clause (a) where no return of income has been furnished by the assessee although

THE COMMISSIONER OF INCOME TAX vs. SHRI H E PANDURANGA

The appeal is disposed of

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

reassessment made protectively under Section 147 for the assessment years 1996-97 and 1997-98 by holding them as infructuous

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

147 or section 153A, the assessment so made shall be regarded as a regular assessment for the purposes of this section. 8. From perusal of the aforesaid provisions, it is axiomatic that the expression ‘assessment’ has a wide connotation and includes reassessment

ABB INDIA LTD vs. JOINT COMMISSIONER OF

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

section 147 would give arbitrary powers to the Assessing Officer to re-open assessments on the basis of "mere change of opinion", which cannot be per se reason to reopen. We must also keep in mind the conceptual difference between power to review and power to re-assess. The Assessing Officer has no power to review; he has the power

THE COMMISSIONER OF vs. M/S ABB INDIA LTD

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

section 147 would give arbitrary powers to the Assessing Officer to re-open assessments on the basis of "mere change of opinion", which cannot be per se reason to reopen. We must also keep in mind the conceptual difference between power to review and power to re-assess. The Assessing Officer has no power to review; he has the power

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

reassessment under Sections 139, 147, 148, 149, 151 & 153. 32. The argument that Section 153C can be invoked in case

THE COMMISSIONER OF INCOME TAX vs. KENNAMETAL INC,USA

Bench: KRISHNA S DIXIT,RAMACHANDRA D. HUDDAR

reassessment, or recomputation is to be made under Section 147 of the Act, pursuant to reopening under Section 148, such

THE PR COMMISSIONER OF vs. M/S MAJESTIC DEVELOPERS

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing

THE PR. COMMISSIONER OF INCOME TAX CIT(A) vs. M/S MICRO FOCUS SOFTWARE INDIA PVT LTD

The appeal is dismissed;

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

reassessment passed under 2 Assessing Officer 3 Commissioner of Income Tax(Appeals) - 4 - ITA No. 759 of 2018 Section 143 (3) r/w Section 147

PRINCIPAL COMMISSIONER OF INCOME TAX vs. MESSERS THE ARCHDIOCESAN BOARD OF

Bench: P.S.DINESH KUMAR,G BASAVARAJA

reassessment or recomputation shall be made under section 147 after the expiry of one year from the end of the financial

M/S GOKULDAS EXPORTS vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Appeal is allowed

Bench: P.S.DINESH KUMAR,C.M. POONACHA

147 of the Act in the name of the partnership firm which was not in existence is valid in law on the facts and circumstances of the case? 7. Whether the Tribunal was justified in law in holding that the provisions of section 45(4) of the Act are applicable in respect of the assets allotted to the partners

SHRI G VENKATESH vs. THE INCOME TAX OFFICER

The appeal stands dismissed

Bench: S.SUJATHA,S VISHWAJITH SHETTY

reassess’ the income of the Appellant and consequently the order passed under section 144 r/w section 147 of the Act on an invalid