THE COMMISSIONER OF INCOME TAX, CIT(A) vs. M/S HEWLETT PACKARD GLOBALSOFT PVT LTD

Appeals are hereby dismissed by

Bench: ARAVIND KUMAR,VINEET SARAN

deduction u/s 10A. Consequent short levy of tax and surcharge works out to Rs.1,76,39,326/-. Therefore, I have reasons to believe that income chargeable to tax has escaped assessment for the Ay 2003-04”. 14 As per Section 147 of the Act, if the Assessing Officer has reason to believe that any income chargeable to tax has escaped

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

U/S 148A(d) OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2014-15 ANNEXURE-A AND ETC. THIS W.P. COMING ON FOR FURTHER HEARING, THIS DsAY, THE COURT MADE THE FOLLOWING:- ORDER In this petition, petitioner has sought for the following reliefs: “ (i) Quashing the impugned order dated: 28.07.2022 bearing ITBA/COM/F/17/2022- 23/1044214522(1) passed by Respondent No.1 under

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

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

deductions claimed by the petitioner in the said return and computation was a sum of Rs.1.99 Crores representing the licence fee paid to M/s.TT Krishnamachari & Company [TTK & Company] for use of the logo ‘ttk’ owned by the Licensor. The consideration was fixed at 0.5% of the net sales value. The Agreements dated 27.04.2007 and 15.01.2009 were entered into between

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

Bench: CHIEF JUSTICE,C M JOSHI

u/s 10AA Profit of the undertaking as per computation statement 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

COMMISSIONER OF INCOME TAX TDS vs. M/S BHARAT HOTELS LIMITED

Appeal stands dismissed

Bench: S.SUJATHA,VINEET SARAN

u/s 201 and 201(1A). However, this is without prejudice to our earlier finding that the order for the asst. years 2002-03 and 2003-04 are barred by limitation.” 7 Challenging the said order of the Tribunal, this appeal has been filed by the Revenue. Though the appeal has been admitted on the questions of law, as mentioned

PR. COMMISSIONER OF vs. M/S SASKEN

Bench: S.SUJATHA,VINEET KOTHARI

reassessment proceedings and had filed return in response to 147 notice and contested the proceedings actively and decisions relied upon by Tribunal have not been reached finality, further without taking note of section 292BB of the Act?” 3. The learned Tribunal, after discussing the rival contentions of both the Appellants-Revenue and Respondent-Assessee, has returned the findings as under

P VIKRAM MAIYA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Accordingly, writ petition is allowed

Bench: S.SUJATHA

deduction u/s. 54EC. The balance amount of Rs.3,50,00,000/- is admitted as income from long term capital gain after availing the indexation benefit. The amount of Rs.4,00,00,000/- received by the assessee from M/s. MTR Food Product for patent right is chargeable to tax as income from business as stipulated u/s

P ARVIND MAIYA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Accordingly, writ petition is allowed

Bench: S.SUJATHA

deduction u/s. 54EC. The balance amount of Rs.3,50,00,000/- is admitted as income from long term capital gain after availing the indexation benefit. The amount of Rs.4,00,00,000/- received by the assessee from M/s. MTR Food Product for patent right is chargeable to tax as income from business as stipulated u/s

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

deduction or allowance claimed under this Act which is found to be false]”. 22. Section 158BC speaks of procedure for assessment of a person searched under Section 132 of the Act or books of accounts, other documents or assets are requisitioned under section 132A. The limitation for the purpose of completion of the block assessments for the purpose of Section

PR. COMMISSIONER OF INCOME TAX vs. SMT. G. LAKSHMI ARUNA

Bench: K.SOMASHEKAR,UMESH M ADIGA

deduction or allowance claimed under this Act which is found to be false]”. 22. Section 158BC speaks of procedure for assessment of a person searched under Section 132 of the Act or books of accounts, other documents or assets are requisitioned under section 132A. The limitation for the purpose of completion of the block assessments for the purpose of Section

THE COMMISSIONER OF INCOME TAX-III vs. SMT.KAMAKSHI DEVI

In the result, the appeal of the assessee is

Bench: S.SUJATHA,VINEET KOTHARI

u/s. 147 is bad in law without appreciating the fact that the department has not accepted the relied upon decision and the same has also been challenged before this Hon'ble High Court of Karnataka in ITA NO.244/2013? 2. Facts leading to filing of this appeal briefly stated are that the assessee is engaged in the business of conducting chits

THE COMMISSIONER OF INCOME TAX vs. M/S.MILLENNIA DEVELOPERS (P) LTD

Bench: The Hon'Ble Mr. Justice Ravi Malimath

u/s. 171 of the Act), where this amount is settled among the HUF members, 5 when the assessee company is a separate entity from that of the share holders? ii) Whether the Appellate Authorities were correct in accepting a family arrangement and partition among the share holders and their relatives vis a vie the assessee company and four accounting entries

THE COMMISSIONER OF INCOME TAX vs. M/S.MILLENNIA DEVELOPERS (P) LTD

Bench: The Hon'Ble Mr. Justice Ravi Malimath

u/s. 171 of the Act), where this amount is settled among the HUF members, 5 when the assessee company is a separate entity from that of the share holders? ii) Whether the Appellate Authorities were correct in accepting a family arrangement and partition among the share holders and their relatives vis a vie the assessee company and four accounting entries

M/S THE KARNATAKA STATE CO-OPERATIVE APEX BANK vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, the appeal is disposed of

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

u/s 148 of the Act on the facts and circumstances of the case? (3) Whether the Tribunal is justified in law in holding that the appellant is not entitled to make additional claim of loss incurred of Rs.8,28,65,052/- in the re- assessment proceedings under section 147 of the Act on the facts and circumstances of the case

KARNATAKA BANK LTD vs. THE ASSISTANT COMMISSIONER OF INCOME -TAX

Accordingly, the petition is allowed in

Bench: The Hon’Ble Mr. Justice Anand Byrareddy

reassessment proceedings having been initiated on a mere change of opinion, according to the learned Senior Advocate, was not permissible under Section 147 of the Act. All the details regarding investment portfolio of the petitioner for the year in question, including the annual report of the petitioner for the year ended 31.03.2010, necessary for one to have to come

CORPORATION BANK vs. THE ASSISTANT COMMISSIONER

Accordingly, the petitions are allowed

Bench: The Hon’Ble Mr. Justice Anand Byrareddy

reassessment proceedings having been initiated on a mere change of opinion, according to the learned Senior Advocate, was not permissible under Section 147 of the Act. All the details 5 regarding investment portfolio of the petitioner for the year in question, including the annual report of the petitioner for the year ended 31.03.2010, necessary for one to have to come

CORPORATION BANK vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Accordingly, the petitions are allowed

Bench: The Hon’Ble Mr. Justice Anand Byrareddy

reassessment proceedings having been initiated on a mere change of opinion, according to the learned Senior Advocate, was not permissible under Section 147 of the Act. All the details 5 regarding investment portfolio of the petitioner for the year in question, including the annual report of the petitioner for the year ended 31.03.2010, necessary for one to have to come

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. It was also held that it was not open for the assessee to seek deduction or claim expenditure, which had not - 64 - been claimed in the original assessment, which assessment already stood completed, only because a assessment under Section 153A of the Act in pursuance of search