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

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

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

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

The appeal stands allowed

Bench: S.SUJATHA,HANCHATE SANJEEVKUMAR

14 - of sections 148 to 153, assess or reassess such income or recompute the loss or the depreciation allowance, as the case may be, for the assessment year concerned (hereafter in sections 148 to 153 referred to as the relevant assessment year)." After enactment of Direct Tax Laws (Amendment) Act, 1987, i.e., prior to 1st April, 1989, Section 147

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

iii) Replika Press Private Limited & Another vs. Deputy Commissioner of Income Tax Circle (W.P.(C) 7452/2010 dated 5th August, 2013) 11 (iv) (2014) 363 ITR 603 (Bom) NDT Systems and another vs. Income-Tax Officer and others (v) (2014) 366 ITR 134 (Guj) Deepakbhai Ramjibhai Patel vs. Income- Tax Officer 8. Assessee is in the business of software development

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

14. The proviso to Section 153C(1) of the Act expressly indicates that reference to the date of initiation of search for the purposes of second proviso to Section 153A shall be construed as a reference to the date on which valuable assets or documents are received by the AO of an Assessee (other than a searched person). Thus

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

14. Now there can be a situation when during the search conducted on one person under Section 132, some documents or valuable assets or books of account belonging to some other person, in whose case the search is not conducted, may be found. In such case, the Assessing Officer has to first be satisfied under Section 153C, which provides

SHRI. SUMIR J. HINDUJA vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, appeal is disposed of

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

III. PASS SUCH OTHER SUITABLE ORDER AS THIS HON'BLE COURT DEEMS FIT TO GRANT IN THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE IN THE INTEREST OF JUSTICE AND EQUITY. THIS I.T.A. COMING ON FOR FINAL HEARING, THIS DAY, ALOK ARADHE J., DELIVERED THE FOLLOWING: JUDGMENT This appeal under Section 260-A of the Income

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. IBC KNOWLEDGE PARK PVT. LTD.,

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

14,354/- paid during the previous years. The Tribunal held that there was no infirmity in the order of the Appellate Commissioner in granting relief to the assessee. Therefore, the same was confirmed. 24. Learned counsel for the Revenue, however, contended that the Appellate Authorities were not right in holding that a sum of Rs.1.91 crore cannot be disallowed

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

14,354/- paid during the previous years. The Tribunal held that there was no infirmity in the order of the Appellate Commissioner in granting relief to the assessee. Therefore, the same was confirmed. 24. Learned counsel for the Revenue, however, contended that the Appellate Authorities were not right in holding that a sum of Rs.1.91 crore cannot be disallowed

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

14,354/- paid during the previous years. The Tribunal held that there was no infirmity in the order of the Appellate Commissioner in granting relief to the assessee. Therefore, the same was confirmed. 24. Learned counsel for the Revenue, however, contended that the Appellate Authorities were not right in holding that a sum of Rs.1.91 crore cannot be disallowed

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

P ARVIND MAIYA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Accordingly, writ petition is allowed

Bench: S.SUJATHA

147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course

P VIKRAM MAIYA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Accordingly, writ petition is allowed

Bench: S.SUJATHA

147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions of sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course

THE COMMISSIONER OF INCOME TAX vs. M/S MAKINO ASIA PVT LTD

Bench: B.MANOHAR,DILIP B.BHOSALE

2) and 143(3) were initiated/taken by the Assessing Officer in respect of the regular assessment for the Assessment year 1998-99. Subsequently, the Assessing Officer initiated reassessment proceedings under Section 148 for reassessing “commission attributable to the branch”. The assessee, pursuant to the notice under Section 148, filed revised return of income for the Assessment year

THE COMMISSIONER OF INCOME TAX vs. M/S PRAKASH ELECTRIC COMPANY

Bench: S.SUJATHA,VINEET KOTHARI

iii)M Harish Rs.23,58,226 (iv)M Suresh Rs.21,17,341 (v) M Rajesh Rs.19,27,253 These 5 partners who became the shareholders of the successor company were however, allotted only 1210 equity shares of Rs.10/- each on 01.05.1999 and remaining shares were allotted to them subsequently in a phased manner. The first allotment came to the extent

KIDS CLINIC INDIA PRIVATE LIMITED

Bench: KRISHNA S DIXIT

iii)M Harish Rs.23,58,226 (iv)M Suresh Rs.21,17,341 (v) M Rajesh Rs.19,27,253 These 5 partners who became the shareholders of the successor company were however, allotted only 1210 equity shares of Rs.10/- each on 01.05.1999 and remaining shares were allotted to them subsequently in a phased manner. The first allotment came to the extent