HEWLETT PACKARD FINANCIAL SERVICES INDIA PRIVATE vs. THE STATE OF KARNATAKA

Bench: S.SUJATHA,JAYANT PATEL

43 buyer and on the mutual understanding between the local buyer and the local seller that the goods so imported by the local seller will be purchased by the local buyer. There is in such cases, a direct link between the local sale and the import. In fact it is this mutual understanding between the local buyer and the local

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

5. We have heard Shri N. Venkataraman, learned ASG appearing on behalf of the Revenue and Shri C.A. Sundaram and Shri S. Ganesh, learned Senior Advocates and other learned counsel appearing on behalf of the respective assessee. 6. It cannot be disputed that by substitution of sections 147 to 151 of the Income Tax Act (IT Act) by the Finance

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 income under the original assessment order passed. However, it was noticed that though the assessment proceedings was initiated by issue of notice under Section 143(2), The Tribunal vide said order also knocked down the assessment proceedings completed under

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 income under the original assessment order passed. However, it was noticed that though the assessment proceedings was initiated by issue of notice under Section 143(2), The Tribunal vide said order also knocked down the assessment proceedings completed under

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

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

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

PR. COMMISSIONER OF INCOME TAX (CENTRAL) vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD.,

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

5. We agree with the opinion of the Tribunal that additions could not have been made by the Assessing Officer without rejecting the books of account of the assessee, and also without there being any adverse comment made by the Assessing Officer with regard to the books of account that were maintained by the assessee, which were duly audited

SRI AVINASH LALA CHANDANI vs. SRI P A NIRANJAN

Bench: The Hon'Ble Mr. Justice A.V.Chandrashekara

reassess the evidence placed before the Court if material evidence is either ignored or misinterpreted or law has been misapplied to the facts of the case. 13. The Hon’ble Apex Court in the case of M/s.Bhoolchand and Anr. vs. M/s.Kay Pee Cee Investments and Anr. (AIR 1991 SC 2053) has held 15 that the power of revision under Section

M/S T T K PRESTIGE LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mrs.Justice S.Sujatha

reassessment. - 34 - In view of the above observations we must add one caveat. There may be cases where the Assessing Officer does not and may not raise any written query but still the Assessing Officer in the first round/ original proceedings may have examined the subject matter, claim etc, because the aspect or question may be too apparent and obvious

THE PR. COMMISSIONER OF INCOME TAX vs. M/S BIOPLUS LIFE SCIENCES PVT LTD

In the result, I pass the following:-

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar Writ Petition No.1014 Of 2017 (T-Kst) Between: M/S. Rainbow Colour Lab, No.13, D.J.C. Complex, Hudson Circle, Bengaluru – 560 027. A Partnership Firm Represented By Its Partner Sri.G.K.Madan Mohan, Aged About 62 Years, S/O Sri.G.V.Krishna Reddy. ...Petitioner (By Sri. M.Thirumalesh, Advocate ) And: 1. State Of Karnataka

reassessment of any person other than the assessee beyond the period of limitation specified in section 34 in consequence of or to give effect to a finding or direction given in an appeal, revision or reference arising out of proceedings in relation to the assessee, violated the provisions of article 14 of the Constitution of India and were invalid

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

43,60,79,542 - 7 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 Add: Voluntary TP adjustment 36,90,62,637 Income from business of the undertaking after voluntary TP adjustment 80,51,42,179 7. The AO had denied the exemption under Section 10AA on the TP pricing adjustment