THE COMMISSIONER OF INCOME-TAX vs. M/S. IBC KNOWLEDGE PARK PVT. LTD.,

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

2) of Section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or valuable assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue notice and assess or reassess total income of such other - 47 - person

THE COMMISIONER OF INCOME-TAX vs. M/S IBC KNOWLEDGE PARK PVT LTD

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

2) of Section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or valuable assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue notice and assess or reassess total income of such other - 47 - person

THE COMMISSIONER OF INCOME-TAX vs. M/S. IBC KNOWLEDGE PARK PVT. LTD.,

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

2) of Section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date of receiving the books of account or documents or valuable assets seized or requisitioned by the Assessing Officer having jurisdiction over such other person, such Assessing Officer shall issue notice and assess or reassess total income of such other - 47 - person

AZIM PREMJI TRUSTEE COMPANY PVT LTD vs. DEPUTY COMMISSIONER OF INCOME TAX

In the result, I pass the following:-

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

153C read with section 153A, is required to be issued in relation to a search initiated under section 132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: Provided also that for the purposes of computing the period of limitation as per this section, the time

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

2. Whether on the facts and in the circumstances of the case, the Tribunal is right in law in holding that the assessing authority cannot take cognizance of the seized material in the proceedings under section 143(3) of the Act without invoking provisions of Section 153C of the Act by ignoring that there is no bar section

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 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 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

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

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

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 of the Act which mandates

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 of the Act which mandates

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 of the Act which mandates

THE PR. COMMISIONER OF 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 of the Act which mandates

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 of the Act which mandates

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 of the Act which mandates