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15 results for “reassessment u/s 147”+ Section 10(29)clear

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Key Topics

Section 26027Section 143(3)19Section 14817Section 14716Section 45(2)12Section 260A6Section 244A5Section 153C4Deduction

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

u/s. 114[e] of the Indian Evidence Act, 1872 would be that the AO has looked into all the aspects of the matter made available in the return filed and the documents supplied along with the return. If an opinion is framed by the AO concluding the assessment order under section 143[3] of the Act, reopening the same without

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

In the result, I pass the following:-

WP/15910/2022HC Karnataka28 Oct 2022

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

3
Reopening of Assessment3
Reassessment3
Addition to Income3
Section 143(3)Section 148Section 148ASection 56(2)

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

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/20040/2019HC Karnataka25 Aug 2021

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

Section 1Section 143(2)Section 143(3)Section 244ASection 254Section 92C

29 • Section 153(2A) prior to substitution by Finance Act, 2016 with effect from 01.06.2016. • Section 153(3) post substitution by Finance Act, 2016 with effect from 01.06.2016. The term ‘fresh assessment’ as employed in the above sections is accompanied by the term ‘setting aside or cancelling an assessment’; it may further be noted that section 153(6) is subject

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)Section 144CSection 147Section 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

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

The appeal is dismissed

ITA/205/2015HC Karnataka16 Feb 2016

Bench: S.SUJATHA,JAYANT PATEL

Section 143(3)Section 147Section 260Section 45(2)

10,06,617/- and the 10A unit. The disclosure has to be full and true. Both the criteria have to be met. In the assessee’s case, by failing to bring out the nexus between the 10A unit and the interest income, the assessee has not discharged its responsibility of furnishing full disclosure of facts. As set out above

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

The appeal is dismissed

RP/205/2015HC Karnataka24 Jul 2015

Bench: N.KUMAR,RATHNAKALA

Section 143(3)Section 147Section 260Section 45(2)

10,06,617/- and the 10A unit. The disclosure has to be full and true. Both the criteria have to be met. In the assessee’s case, by failing to bring out the nexus between the 10A unit and the interest income, the assessee has not discharged its responsibility of furnishing full disclosure of facts. As set out above

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

The appeal stands allowed

ITA/65/2017HC Karnataka23 Nov 2021

Bench: S.SUJATHA,HANCHATE SANJEEVKUMAR

Section 143(1)Section 143(3)Section 147Section 148Section 260Section 260ASection 80P(2)Section 80P(2)(a)

10. In the case of Commissioner of Income-tax v. Kelvinator of India Ltd., reported in (2010) 320 ITR 561, the Hon’ble Apex Court has held thus: “A short question which arises for determination in this batch of civil appeals is, whether the concept of "change of opinion" stands obliterated with effect from 1st April, 1989, i.e., after substitution

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

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 (Rs.) (I) (II) (III) 2009-10 28,76,23,325 9,95,82,217 2010-11 2,29

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

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(Rs) (I) (II) (III) 2009-10 28,76,23,325 9,95,82,217 2010-11 2,29

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

Appeal stands dismissed

ITA/393/2009HC Karnataka02 Dec 2015

Bench: S.SUJATHA,VINEET SARAN

Section 143(3)Section 153Section 154Section 194Section 201Section 201(1)Section 206

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

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

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 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

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

ITA/402/2009HC Karnataka28 Apr 2016

Bench: B.V.NAGARATHNA,JAYANT PATEL

Section 260

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

ITA/403/2009HC Karnataka28 Apr 2016

Bench: B.V.NAGARATHNA,JAYANT PATEL

Section 260

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