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

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

reassess was brought to the notice - 8 - of the Court, arguing that, on concluding the assessment under section 143[3] of the Act, with all the material facts available on record, the presumption 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

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 vs. M/S CHAITANYA PROPERTIES PVT LTD.,

The appeal is dismissed

Bench: S.SUJATHA,JAYANT PATEL

section 147 was not satisfied. Secondly, in absence of any satisfaction having been recorded by the Assessing Officer that the income has escaped by reason of the failure on the part of the assessee to disclose fully and truly all mater ial facts necessary for its assessment for the Assessment Year under consideration, assumption of jurisdiction u/s 147

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

The appeal is dismissed

Bench: N.KUMAR,RATHNAKALA

section 147 was not satisfied. Secondly, in absence of any satisfaction having been recorded by the Assessing Officer that the income has escaped by reason of the failure on the part of the assessee to disclose fully and truly all mater ial facts necessary for its assessment for the Assessment Year under consideration, assumption of jurisdiction u/s 147

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

The appeal stands allowed

Bench: S.SUJATHA,HANCHATE SANJEEVKUMAR

15 - depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in Sections 148 to 153 referred to as the relevant assessment year)." After the Amending Act, 1989, Section 147 reads as under: "147. Income escaping assessment. – If the Assessing Officer has reason to believe that any income chargeable

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

15,00,92,060/- after claiming deduction of ` 99,67,71,161/- under Section 10A of the Act. Assessment order came to be framed under Section 143(3) of the Act on 27.03.2006. The Assessing Officer reduced the claim of deduction from ` 99,67,71,161/- to ` 89,08,86,778/-. Notice under Section 148 of the Act was issued

NOVO NORDISK INDIA PRIVATE LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 12 (2

Bench: S.SUJATHA

u/s 143(3) of the Act inter alia accepting the conclusions of the TPO. It appears after lapse of close to six years from the end of relevant Assessment Year, by the impugned notice dated 28.3.2013 issued under Section 148 of the Act respondent No.1 initiated re-assessment proceedings for the subject Assessment Year on the ground that the income

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

15. The controversy in this regard is no longer res integra. A Coordinate Bench of this Court in SSP Aviation Ltd. v. Deputy Commissioner of Income Tax: (2012) 346 ITR 177 has held that: "in case of the searched person, the date with reference to which proceedings for assessment or reassessment of any assessment year within a period

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

15 is that this income, if any, is share income from partnership firm and is not taxable. However, in absence of any further details or evidences furnished either before the assessing officer(who has provided sufficient opportunity) or during the course of appeal, the findings of the assessing officer and the inference drawn do not deserve any interference and therefore

THE COMMISSIONER OF INCOME TAX vs. M/S SHASTHA PHARMA LABORATORIES

The appeal is dismissed

Bench: N.KUMAR,RATHNAKALA

U/s 147 11. Section 147 of the Act empowers the assessing officer to assess or reassess such income which is chargeable to tax as escaped assessment for any assessment year, if he has reason to believe that such income has escaped assessment. The proviso to Section 147 of the Act, however, provides that where an assessment under Section

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

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

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

15,222/= per month if the bridge area is authorized for commercial use, and being an amount of Rs,. 6,43,715/- per month if the bridge - 23 - area is not authorized for commercial use. The LESSORS shall not be entitled to any escalation during the three years of the first term, for any reason whatsoever. The said amounts

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

15,222/= per month if the bridge area is authorized for commercial use, and being an amount of Rs,. 6,43,715/- per month if the bridge - 23 - area is not authorized for commercial use. The LESSORS shall not be entitled to any escalation during the three years of the first term, for any reason whatsoever. The said amounts

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

15,222/= per month if the bridge area is authorized for commercial use, and being an amount of Rs,. 6,43,715/- per month if the bridge - 23 - area is not authorized for commercial use. The LESSORS shall not be entitled to any escalation during the three years of the first term, for any reason whatsoever. The said amounts

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-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