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20 results for “reassessment u/s 147”+ Section 260clear

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Key Topics

Section 26028Section 14723Section 143(3)20Section 14818Section 45(2)12Section 260A9Reopening of Assessment9Section 2(22)(e)8Reassessment

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

147 deals with re assessment orders. • Sub-section(3) deals with time-limit for making order of fresh assessment in pursuance of an order under section 254 or section 264, by virtue of which the original assessment is either set aside or cancelled. 23 • Sub-section (4) states that where a reference under section 92CA(1) is made during

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

8
Section 148(2)7
Addition to Income6
Set Off of Losses3

The appeal is dismissed

ITA/205/2015HC Karnataka16 Feb 2016

Bench: S.SUJATHA,JAYANT PATEL

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

147 would give arbitrary powers to the AO to reopen assessments on the basis of "mere change of opinion", which cannot be per se reason to reopen. We must also keep in mind the conceptual difference between power to review and power to reassess. The AO has no power to review; he has the power to reassess. But reassessment

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)

147 would give arbitrary powers to the AO to reopen assessments on the basis of "mere change of opinion", which cannot be per se reason to reopen. We must also keep in mind the conceptual difference between power to review and power to reassess. The AO has no power to review; he has the power to reassess. But reassessment

THE COMMISSIONER OF INCOME TAX, CIT(A) vs. M/S HEWLETT PACKARD GLOBALSOFT PVT LTD

Appeals are hereby dismissed by

ITA/65/2014HC Karnataka14 Aug 2015

Bench: ARAVIND KUMAR,VINEET SARAN

Section 10Section 10ASection 143(3)Section 148Section 260

260-A OF INCOME TAX ACT, 1961 PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE AND ALLOW THE APPEAL AND SET ASIDE THE ORDERS PASSED BY THE ITAT, BANGALORE IN ITA NO.267/BANG/2012, DATED 30.09.2013, CONFIRMING THE ORDER OF THE APPELLATE COMMISSIONER AND CONFIRM THE ORDER PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(4), BANGALORE. THESE

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)

260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 23.09.2016 PASSED IN ITA NO.1364/BANG/2016, FOR THE ASSESSMENT YEAR 2004-2005 PRAYING TO A) TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW AS STATED ABOVE AND THE ANSWER THE SAME IN FAVOUR OF - 2 - THE APPELLANT. B) TO ALLOW THE APPEAL AND SET ASIDE THE FINDINGS TO THE EXTENT

COMMISSIONER OF INCOME TAX vs. M/S GMR HOLDINGS PVT LTD.,

The appeal is dismissed

ITA/58/2012HC Karnataka31 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 143(3)Section 147Section 148Section 154Section 260Section 260A

260-A of the Income Tax Act, 1961 arising from the order of learned Tribunal dated 31.10.2011 in ITA No.1006/Bang/2010 for the Assessment Year 2003- Date of Judgment 31-07-2018 I.T.A.No.58/2012 Commissioner of Income-tax & Anr. vs. M/s. GMR Holdings Pvt. Ltd. 3/16 2004 M/s.GMR Holdings Pvt. Ltd., vs. The Deputy Commissioner of Income Tax, Bengaluru

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

260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 29.02.2016 PASSED IN ITA NO.1372/BANG/2014 FOR THE ASSESSMENT YEAR 2007- 08, PRAYING TO: 2 (i) FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE AND ANSWER THE SAME IN FAVOUR OF THE APPELLANT. (ii) ALLOW THE APPEAL AND SET ASIDE THE FINDINGS TO THE EXTENT AGAINST THE APPELLANT

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

Section 153A. At the time of initiation of such proceedings against the 'searched person' or during the assessment proceedings against him or even after the completion of the assessment proceedings against him, the Assessing Officer of such a 'searched person', may, if he is satisfied, that any money, document etc. belongs to a person other than the searched person, then

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

Section 153C against the assessee for the assessment years 2005-2006 to 2010-2011 and a notice under Section 143(3) for the assessment year 2011- 2012. Therefore, keeping in view the aforesaid search and seizure which was carried under Section 132 of the IT Act, 1961 is concerned, it is relevant to refer to Section 153C

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

260-A OF I.T. ACT, 1961 ARISING OUT OF ORDER DATED 14.08.2013 PASSED IN ITA NO.1314/BANG/2012 AND 1281/BANG/2012, FOR THE ASSESSMENT YEAR 2003-04. (I) DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW AS MAY FORMULATED BY THE HON'BLE COURT AS DEEMED FIT. (II) SET ASIDE THE APPELLATE ORDER DATED 14-8-2013 PASSED

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

260-A of the Income Tax Act, 1961, against the order dated 30.11.2009 passed in I.T.A. No.136/PNJ/2008 on the file of the Income Tax Appellate Tribunal, Panaji Bench, Panaji, dismissing the appeal filed under Section 271(1)(c). These ITAs coming on for further hearing this day, N. KUMAR J delivered the following

M/S MAHESH INVESTMENTS vs. THE ASST. COMMISSIONER OF INCOME-TAX

In the result, we do not find any merit in this

ITA/254/2014HC Karnataka06 Oct 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 234Section 234ASection 234A(1)Section 260Section 260A

260-A OF I.T. ACT, 1961 ARISING OUT OF ORDER DATED 07.02.2014 PASSED IN ITA NO.1339/BANG/2012, ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS) DATED 31.07.2012 AND ASSESSMENT ORDER DATED 25.11.2010, FOR THE ASSESSMENT YEAR 1992-93, PRAYING THAT THIS HON’BLE COURT MAY BE PLEASED TO: (I) FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN. (II) ALLOW THE APPEAL

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

In the result, appeal is disposed of

ITA/7/2017HC Karnataka02 Aug 2021

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 147Section 148(2)Section 2(22)(e)Section 260

Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’, for short) has been filed by the assessee. The subject matter of the appeal pertains to the Assessment Year 2006-07. The appeal was admitted by a Bench of this Court on the following substantial questions of law: 1) Whether the Assessing Officer to justify

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

260-A OF I.T.ACT, 1961, ARISING OUT OF ORDER DATED 05.06.2009 PASSED IN I.T.A No.726/BNG/2008, FOR THE ASSESSMENT YEAR 2004- 2005, PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN AND ALLOW THE APPEAL AND SET ASIDE THE ORDER PASSED BY THE INCOME-TAX APPELLATE TRIBUNAL, BANGALORE IN ITA No.726/BNG/2008, DATED 05.06.2009, CONFIRMING THE ORDER OF THE APPELLATE COMMISSIONER

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

260-A OF I.T.ACT, 1961, ARISING OUT OF ORDER DATED 05.06.2009 PASSED IN I.T.A No.726/BNG/2008, FOR THE ASSESSMENT YEAR 2004- 2005, PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN AND ALLOW THE APPEAL AND SET ASIDE THE ORDER PASSED BY THE INCOME-TAX APPELLATE TRIBUNAL, BANGALORE IN ITA No.726/BNG/2008, DATED 05.06.2009, CONFIRMING THE ORDER OF THE APPELLATE COMMISSIONER

SHRI. JAGADISH. N. HINDUJA vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, appeal is disposed of

ITA/9/2017HC Karnataka02 Aug 2021

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 147Section 148(2)Section 2(22)(e)Section 260

Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’, for short) has been filed by the assessee. The subject matter of the appeal pertains to the Assessment Year 2006-07. The appeal was admitted by a Bench of this Court on the following substantial questions of law: 1) Whether on the facts

PR COMMISSIONER OF WEALTH TAX-6 vs. SRI. M. R. JAYARAM (INDL)

In the result, appeal is disposed of

WTA/9/2017HC Karnataka24 Oct 2019

Bench: RAVI MALIMATH,ASHOK S.KINAGI

Section 147Section 148(2)Section 2(22)(e)Section 260

Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’, for short) has been filed by the assessee. The subject matter of the appeal pertains to the Assessment Year 2006-07. The appeal was admitted by a Bench of this Court on the following substantial questions of law: 1) Whether on the facts

THE PR COMMISSIONER OF INCOME TAX vs. M/S KWALITY BISCUITS PVT LTD

The appeal is disposed of with liberty as prayed for by the learned

ITA/155/2023HC Karnataka30 Sept 2024

Bench: S.G.PANDIT,C.M. POONACHA

Section 147Section 260

260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 17.10.2022 passed by the Income Tax Appellate Tribunal, ‘C’ Bench, Bengaluru (for short, ‘Appellate Authority’) in ITA.No.675/Bang/2020 for the assessment year 2006-07, raising the following substantial questions

PR. COMMISSIONER OF vs. M/S SASKEN

ITA/450/2016HC Karnataka23 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 148Section 260Section 292B

260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 11/12/2015, PASSED IN ITA No.901/BANG/2014, FOR THE ASSESSMENT YEAR 2002-2003, ANNEXURE-A, PRAYING TO: (A) DECIDE THE FOREGOING QUESTION OF LAW AND / OR Date of Judgment 23-07-2018, ITA No.450/2016 Pr. Commissioner of Income Tax-6 & Another Vs. M/s. Sasken Communication Technologies Ltd., 2/11 SUCH OTHER

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

ITA/340/2007HC Karnataka25 Sept 2013

Bench: B.MANOHAR,DILIP B.BHOSALE

Section 143(1)Section 143(2)Section 143(3)Section 148Section 260Section 271(1)(c)Section 72

260-A of the Income Tax Act, 1961, is directed against the order dated 15.09.2006 rendered by the Income Tax Appellate Tribunal, Bangalore, (for short ‘the Tribunal’) in ITA No.3026/Bang/2004. By this order, the Tribunal confirmed the order dated 23.07.2004 passed by the Commissioner of Income Tax (Appeals)-IV, Bangalore, (for short “the Appellate Authority”) in penalty proceedings under Section