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17 results for “reassessment u/s 147”+ Disallowanceclear

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Mumbai2,542Delhi1,399Chennai658Bangalore512Kolkata439Jaipur297Ahmedabad284Hyderabad220Chandigarh154Surat150Pune147Raipur128Indore103Rajkot69Amritsar65Lucknow56Nagpur52Cuttack49Guwahati48Visakhapatnam44Cochin38Agra36Jodhpur35Allahabad35Patna27Karnataka17Panaji16Dehradun9Jabalpur5Telangana5Calcutta5Kerala4Varanasi3SC2Gauhati2Orissa2Ranchi1Punjab & Haryana1

Key Topics

Section 26031Section 14826Section 14719Section 260A7Reopening of Assessment7Disallowance7Section 143(3)6Addition to Income6Deduction

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

WP/30388/2015HC Karnataka10 Aug 2018

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

Section 143Section 147Section 148

reassessment proceedings under Section 147 of the Act are quoted hereunder for ready reference: “The assessee company has filed its return of income for the relevant assessment year on 30.09.2009 declaring total income of Rs.26,61,99,014/-. The case was assessed u/s 143(3) on 18.04.2011 determining total income at Rs.25,59,90,979/-. Subsequently it is noticed that

DELL INDIA PVT LTD vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/8901/2015HC Karnataka23 Mar 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

Section 143(3)
5
Reassessment5
Section 153C4
Section 1444
Section 144C
Section 147
Section 148

u/s 148 in your case for the AY 2009-10 is not based on a mere change of opinion 7 but is based on the fact an amount of Rs.216,89,00,773/- which was deferred in AY 2009-10 has not been offered in the subsequent assessment year. 3. Regarding deferment of revenue, the DRP in its order

PR. COMMISSIONER OF vs. M/S SASKEN

ITA/450/2016HC Karnataka23 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 148Section 260Section 292B

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

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

disallowed(Rs) (I) (II) (III) 2009-10 28,76,23,325 9,95,82,217 2010-11 2,29,05,056 1,46,91,363 15. Of these the assessing officer found that to the extent given in column (III) above, the appellant was unable to substantiate the said expenses claimed before the assessing officer. 16.In respect of assessment

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

Disallowed (Rs.) (I) (II) (III) 2009-10 28,76,23,325 9,95,82,217 2010-11 2,29,05,056 1,46,91,363 Of these, the Assessing Officer found that to the extent given in column 3 above, the appellant was unable to substantiate the said expense claimed before the Assessing Officer. 16. In respect of assessment

CORPORATION BANK vs. THE ASSISTANT COMMISSIONER

Accordingly, the petitions are allowed

WP/30820/2015HC Karnataka11 Jan 2016

Bench: The Hon’Ble Mr. Justice Anand Byrareddy

Section 147Section 148Section 57

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

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

Accordingly, the petition is allowed in

WP/40511/2015HC Karnataka11 Jan 2016

Bench: The Hon’Ble Mr. Justice Anand Byrareddy

Section 147Section 148Section 56Section 57Section 80P(2)(a)

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 OF INCOME TAX

Accordingly, the petitions are allowed

WP/27355/2015HC Karnataka11 Jan 2016

Bench: The Hon’Ble Mr. Justice Anand Byrareddy

Section 147Section 148Section 57

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

In the result, the appeal of the assessee is

WTA/1/2014HC Karnataka30 Aug 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 143(1)Section 143(2)Section 147Section 148Section 260Section 260A

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

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

ITA/107/2025HC Karnataka12 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 10ASection 14ASection 260Section 260A

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

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

ITA/735/2009HC Karnataka19 Nov 2018

Bench: The Hon'Ble Mr. Justice Ravi Malimath

Section 171Section 260

disallowed the claim for bad debts. Aggrieved by the same, an appeal was filed before the CIT (Appeals)-VI, Bangalore, which was allowed. The claim of the assessee was allowed and the addition was deleted. Aggrieved by the same, the Revenue filed the appeal before the Tribunal, wherein the appeal was dismissed. Hence, the present appeal. 4 2. ITA No.734

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

ITA/734/2009HC Karnataka19 Nov 2018

Bench: The Hon'Ble Mr. Justice Ravi Malimath

Section 171Section 260

disallowed the claim for bad debts. Aggrieved by the same, an appeal was filed before the CIT (Appeals)-VI, Bangalore, which was allowed. The claim of the assessee was allowed and the addition was deleted. Aggrieved by the same, the Revenue filed the appeal before the Tribunal, wherein the appeal was dismissed. Hence, the present appeal. 4 2. ITA No.734

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

In the result, the appeal is disposed of

ITA/392/2016HC Karnataka06 Jul 2021

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 143(1)Section 143(3)Section 147Section 148Section 260Section 260A

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

THE COMMISSIONER OF INCOME TAX GULBARGA vs. M/S MANJUNATHA COTTON AND GINNING FACTORY

The appeals are dismissed

ITA/2564/2005HC Karnataka13 Dec 2012

Bench: ARAVIND KUMAR,N.KUMAR

Section 260Section 260A

147 deals with income escaping assessment. Chapter XXI deals with penalties imposable. 37 Section 271 deals with failure to furnish returns, comply with notices, concealment of income, etc., It reads as under:- “271. FAILURE TO FURNISH RETURNS, COMPLY WITH NOTICES, CONCEALMENT OF INCOME, ETC. (1) If the Assessing Officer or the Commissioner (Appeals) in the course of any proceedings under

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

In the result, the appeals filed by the Revenue

ITA/402/2009HC Karnataka28 Apr 2016

Bench: B.V.NAGARATHNA,JAYANT PATEL

Section 260

disallowed as it was not meant for management of construction, but on other expenses, such as advertisement, sales promotion etc. Therefore, the income had to be assessed under the head income from other sources. The Tribunal held that the income had to be assessed as business income and the assessee could not have received a sum of Rs.78.25 lakh without

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

In the result, the appeals filed by the Revenue

ITA/402/2014HC Karnataka28 Apr 2016

Bench: B.V.NAGARATHNA,JAYANT PATEL

Section 260

disallowed as it was not meant for management of construction, but on other expenses, such as advertisement, sales promotion etc. Therefore, the income had to be assessed under the head income from other sources. The Tribunal held that the income had to be assessed as business income and the assessee could not have received a sum of Rs.78.25 lakh without

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

In the result, the appeals filed by the Revenue

ITA/403/2009HC Karnataka28 Apr 2016

Bench: B.V.NAGARATHNA,JAYANT PATEL

Section 260

disallowed as it was not meant for management of construction, but on other expenses, such as advertisement, sales promotion etc. Therefore, the income had to be assessed under the head income from other sources. The Tribunal held that the income had to be assessed as business income and the assessee could not have received a sum of Rs.78.25 lakh without