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 Section 143 & 147/148. 27. Section 153A and 153C starts with non-obstante clause. The procedure for assessment/reassessment in Section

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

reassessment could be done. The returns filed under Section 139 of the Act gets replaced by the returns filed under Section 153A[1] of the Act. Pending proceedings in appeal, revision/application shall not abate subsequent to initiation of Section 153A proceedings. Further, recording of satisfaction under Section 153A may not be necessary unlike Section 153C

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

reassessment could be done. The returns filed under Section 139 of the Act gets replaced by the returns filed under Section 153A[1] of the Act. Pending proceedings in appeal, revision/application shall not abate subsequent to initiation of Section 153A proceedings. Further, recording of satisfaction under Section 153A may not be necessary unlike Section 153C

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

reassessment could be done. The returns filed under Section 139 of the Act gets replaced by the returns filed under Section 153A[1] of the Act. Pending proceedings in appeal, revision/application shall not abate subsequent to initiation of Section 153A proceedings. Further, recording of satisfaction under Section 153A may not be necessary unlike Section 153C

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

Bench: S.SUJATHA,RAVI V HOSMANI

reassessment proceedings under Section 147/148 of the Act is concerned. The issue being purely one of law, the Income Tax Appellate Tribunal was not in error in permitting the assessee to raise such a point before it. 18. The Hon’ble High Court of Bombay in the case of Commissioner of Income tax-1, Nagpur vs. Lalitkumar Bardia reported

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

Bench: S.SUJATHA,RAVI V HOSMANI

reassessment proceedings under Section 147/148 of the Act is concerned. The issue being purely one of law, the Income Tax Appellate Tribunal was not in error in permitting the assessee to raise such a point before it. 18. The Hon’ble High Court of Bombay in the case of Commissioner of Income tax-1, Nagpur vs. Lalitkumar Bardia reported

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

Bench: S.SUJATHA,RAVI V HOSMANI

reassessment proceedings under Section 147/148 of the Act is concerned. The issue being purely one of law, the Income Tax Appellate Tribunal was not in error in permitting the assessee to raise such a point before it. 18. The Hon’ble High Court of Bombay in the case of Commissioner of Income tax-1, Nagpur vs. Lalitkumar Bardia reported

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

Bench: CHIEF JUSTICE,C M JOSHI

reassessment under Section 153A or 153C could be done in absence of any incriminating material found in a search under

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

The appeal is dismissed as the

Bench: V KAMESWAR RAO,S RACHAIAH

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

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

153C read with 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

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

In the result, the appeal stands dismissed

Bench: S.SUJATHA,RAVI V HOSMANI

153C proceedings were initiated against the assessee. Notice under Section 142[1] was issued on 12.09.2013 calling the assessee to file the return. Reply was filed on 08.10.2013 by the assessee stating that the return of income for the assessment year 2012-13 was already filed on 26.09.2012 enclosing the copy of the same for ready reference. Subsequently, notice under

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 proceedings are required to be completed within one year from the end of the financial year in which the notice under Section 148 was served. Further, in cases of assessment under Sections 153A or 153C