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17 results for “reassessment”+ Section 153(3)clear

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Key Topics

Section 26025Section 143(3)11Section 15311Section 260A10Section 143(2)10Section 14710Section 1487Limitation/Time-bar6Section 1325Reassessment

THE COMMISSIONER OF INCOME TAX vs. KENNAMETAL INC,USA

ITA/68/2024HC Karnataka02 Apr 2025

Bench: KRISHNA S DIXIT,RAMACHANDRA D. HUDDAR

Section 153Section 153(7)Section 4

reassessment or recomputation could be made at any time. The amended sub-section (3) of Section 153 introduced by the Finance

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

ITA/103/2025HC Karnataka03 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 132Section 143(3)
5
Addition to Income5
Deduction3
Section 153A
Section 2
Section 260
Section 260A
Section 47

3. The assessee controverted the said contention and had asserted that all conditions as specified in Section 47 (xiii) of the Act were duly complied with. And, appealed the re-assessment order. However, the CIT(A) had rejected the assessee's appeal. This led the assessee to file an appeal before the learned ITAT. 4. The learned ITAT has allowed

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

Appeals stand disposed of accordingly

ITA/197/2021HC Karnataka29 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

153 has also been - 24 - done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

ITA/381/2018HC Karnataka29 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

153 has also been - 24 - done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

ITA/382/2018HC Karnataka29 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260

153 has also been - 24 - done away with in a case covered by Section 153A. With all the stops having been pulled out, the Assessing Officer under Section 153A has been entrusted with the duty of bringing to tax the total income of an assessee whose case is covered by Section 153A, by even making reassessments without any fetters

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

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

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

In the result, the order passed by the

ITA/370/2011HC Karnataka12 Jun 2020

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 143Section 143(2)Section 153Section 153(3)Section 154Section 260Section 260ASection 80I

Section 153(3) of the Act, the assessment, reassessment or recomputation has to be made on the assessee or any person

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

In the result, the order passed by the

ITA/503/2016HC Karnataka11 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(3)Section 147Section 148Section 150Section 153Section 260Section 260A

3) read with Section 153(c) in the hands of the individual by making several additions mainly with regard to sale of properties. 4. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals). In 5 the appeal also the assessee again contended that the income belongs to HUF. It was held that the land belongs

COMMISSIONER OF INCOME vs. M/S C RAMAIAH REDDY

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

ITA/192/2012HC Karnataka24 Jun 2020

Bench: ALOK ARADHE,M.NAGAPRASANNA

Section 143(2)Section 143(3)Section 147Section 260Section 260ASection 292BSection 45(2)

3) read with Section 147 of the Act. It is contended that substantial compliance has been made even though in the notice issued under Section 147 there is no reference to Section 143(2) of the Act. It is submitted that the defect is a curable defect and in this connection, our attention has been invited to provisions contained

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

Appeal is dismissed as being

ITA/32/2020HC Karnataka20 Sept 2024

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

Section 10BSection 132Section 133ASection 142(1)Section 143(2)Section 260Section 260A

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

ITA/705/2018HC Karnataka31 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 132Section 143(3)Section 144Section 153CSection 153DSection 260A

153 C of the Act will taken as the year of search for the purpose of clause(a) and (b) of sub-section 1 of Section 153A by making reference to proviso to sub-section 1 of Section 153C despite the fact that the first proviso to sub-section 1 of Section 153C refers to second proviso to sub-section

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

ITA/704/2018HC Karnataka31 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 132Section 143(3)Section 144Section 148Section 153CSection 153DSection 260A

153 C of the Act will taken as the year of search for the purpose of clause(a) and (b) of sub-section 1 of Section 153A by making reference to proviso to sub-section 1 of Section 153C despite the fact that the first proviso to sub-section 1 of Section 153C refers to second proviso to sub-section

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

The appeal is hereby dismissed

ITA/100039/2023HC Karnataka27 Jan 2026

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

Section 142A(6)Section 143Section 143(3)Section 153Section 260ASection 263

reassessment or recomputation. 11. Section 153(3) of the Act reads as under: “(3) Notwithstanding anything contained in sub-sections

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

3) within one month from the end of the month in which,- (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub- section (2), issue such directions, as it thinks fit, for the guidance

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

ITA/50/2020HC Karnataka24 Jan 2023

Bench: P.S.DINESH KUMAR,G BASAVARAJA

Section 143Section 143(3)Section 147Section 148Section 153Section 153(2)Section 260

reassessment proceedings got initiated only on 31-3-2015 and hence, both are distinct and not parallel? 2. Heard Shri.E.I.Sanmathi, learned standing counsel for the Revenue and Shri.B.R.Sudheendra, learned Advocate for the assessee. 3. Undisputed facts of the case are, assessee filed return of income for the Assessment Year2 2008-09 on 30.09.2008. Assessment under Section 143(3

THE DIRECTOR OF INCOME TAX vs. THE EXECUTIVE ENGINEER

ITA/166/2011HC Karnataka24 Aug 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 201(1)Section 201(3)Section 231Section 260Section 260A

3. I.T.A.No.148/2011 was admitted by a bench of this court vide order dated 29.08.2011 on the following substantial question of law: (i) What is the reasonable time within which the proceedings have to be initiated under Section 201(1) of the Income Tax Act, as during the relevant period, the statute did not prescribe any period of limitation

PRL., COMMISSIONER OF INCOME TAX-3 vs. M/S I B C KNOWLEDGE PARK PVT LTD

The appeal is dismissed as the

ITA/721/2023HC Karnataka09 Dec 2024

Bench: V KAMESWAR RAO,S RACHAIAH

Section 158BSection 260

reassessment is altered by a different assessment in respect of searched person or in respect of third party. In this regard, reference may be made to the decision of the apex court in the case of Calcutta Knitwears (supra) and based on the said decision, the Central Board of Direct Taxes has also issued circular dated December 31, 2015, vide