WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

26 4 issues Revenue Appeal in respect of 1 issue held against assesseee OGE to be passed u/s. 153(5) within 3 months from the end of the month in which the order of Tribunal u/s. 254 is received by PCCIT or CCIT or PCIT or CIT. Where the order is passed beyond such time limit, additional interest u/s. 244A

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

Bench: The Hon’Ble Mr.Justice Aravind Kumar

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

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

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 assessment

THE COMMISSIONER OF INCOME TAX vs. M/S CHAITANYA PROPERTIES PVT LTD.,

The appeal is dismissed

Bench: S.SUJATHA,JAYANT PATEL

26 as under: “12. It could be seen from the facts narrated as above that the proceeding u/s. 147 of the Act were sought to be initiated after a period of four years from the end of the relevant assessment year. It is also clear from the facts narrated as above that in the case of assessee

COMMISSIONER OF INCOME TAX (APPEALS) vs. M/S POST & BSNL EMPLOYEES

The appeal is dismissed

Bench: N.KUMAR,RATHNAKALA

26 as under: “12. It could be seen from the facts narrated as above that the proceeding u/s. 147 of the Act were sought to be initiated after a period of four years from the end of the relevant assessment year. It is also clear from the facts narrated as above that in the case of assessee

THE SRI KANNIKAPARAMESWARI CO OP BANK LIMITED vs. THE INCOME TAX OFFICER

The appeal stands allowed

Bench: S.SUJATHA,HANCHATE SANJEEVKUMAR

u/s 80P of the Act in respect of profit from sale of securities is justified. In view of the above, the objection raised by the Audit my please dropped.” It appears, subsequently, the notice under Section 148 of the Act was issued on 06.07.2009 by the assessing officer. 10. In the case of Commissioner of Income-tax v. Kelvinator

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

10 and 2010-11, the assessing officer has brought on record that the appellant has claimed transportation expenses for the years in question. The same was indicated in the below tabular form. 15 A.Y Total Transportation Expenses claimed (Rs.) Transport Expenses Disallowed

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

10 and 2010-11, the assessing officer has brought on record that the appellant has claimed transportation expenses for the years in question. The same was indicated in a tabular form. 14 A.Y. Total Transportation Expenses claimed (Rs) Transport Expenses disallowed

SRI C M MAHADEVA S/O SRI MANCHE GOWDA vs. THE COMMISSIONER OF INCOME TAX

The appeal stands allowed

Bench: B.MANOHAR,VINEET SARAN

u/s 148 for A.Y.2004-05.” (emphasis supplied) 10. From a bare perusal of the aforesaid reasons recorded for reopening the concluded assessment for the assessment year 2004-05, what we notice is that the Assessing Officer was of the opinion that further investigation was required for proceeding to commence for the assessment year 2004-05, and on such basis he opined

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 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

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

10. Against the order of the Appellate Commissioner, Revenue had filed appeals before the Tribunal for three assessment years in question, which - 14 - were numbered as ITA.Nos.903-905/2013. As regards the initiation of proceedings under Section 153C of the Act, the assessee filed cross-objections before the Tribunal and the same were numbered as C.O.Nos.103-105/Bang/2013

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

10. Against the order of the Appellate Commissioner, Revenue had filed appeals before the Tribunal for three assessment years in question, which - 14 - were numbered as ITA.Nos.903-905/2013. As regards the initiation of proceedings under Section 153C of the Act, the assessee filed cross-objections before the Tribunal and the same were numbered as C.O.Nos.103-105/Bang/2013

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

10. Against the order of the Appellate Commissioner, Revenue had filed appeals before the Tribunal for three assessment years in question, which - 14 - were numbered as ITA.Nos.903-905/2013. As regards the initiation of proceedings under Section 153C of the Act, the assessee filed cross-objections before the Tribunal and the same were numbered as C.O.Nos.103-105/Bang/2013

THE ASST. COMMISSIONER OF INCOME TAX vs. M/S KOTARKI CONSTRUCTIONS PVT LTD

Bench: B.V.NAGARATHNA,J.M.KHAZI

U/S 4 of the Karnataka High Court Act praying to set aside the order dated 2.1.2018 in Writ Petition No.61671/2016 (T-IT) passed by the learned Single Judge. This appeal coming on for hearing this day, NAGARATHNA J., delivered the following: -: 2 :- J U D G M E N T The Revenue has preferred this appeal being aggrieved

PR.COMMISSIONER vs. M/S ESTEEM CLASSIC

Bench: ALOK ARADHE,M.G.S. KAMAL

U/S 4 of the Karnataka High Court Act praying to set aside the order dated 2.1.2018 in Writ Petition No.61671/2016 (T-IT) passed by the learned Single Judge. This appeal coming on for hearing this day, NAGARATHNA J., delivered the following: -: 2 :- J U D G M E N T The Revenue has preferred this appeal being aggrieved

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

The appeals are dismissed

Bench: ARAVIND KUMAR,N.KUMAR

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 MAKINO ASIA PVT LTD

Bench: B.MANOHAR,DILIP B.BHOSALE

reassessment for A.Y.98-99 vide its 10 subsequent letter and the claim for set off of loss of A.Y.98-99 was based on its return as well as original intimation which had not been rectified. Having regard to the facts of the case, I do not see any justification for levy of penalty u/s 271(1)(c). There is merit