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:

reassessment in terms of Section 153(2); it would simply mean that the orders of the higher forum are to be applied & followed by the assessing officer; . it may be borne in mind that longer time limits are provided in Section 153(3) & second proviso to Section 153(5) because it may entail doing the entire process once over

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

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

147 of the Act and the object of reassessment proceedings. Such an interpretation would be reading that judgment totally out of context in which the questions arose for decision in that case. It is neither desirable nor permissible to pick out a word or a sentence from the judgment of this Court, divorced from the context of the question under

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

35. It is also trite that while interpreting a machinery provision, the courts would interpret a provision in such a way that it would give meaning to the charging provisions and that the machinery provisions are liberally construed by the courts. In Mahim Patram 47 Private Ltd. v. Union of India (UOI) and Ors., (2007) 3 SCC 668 this Court

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

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. It was also held that it was not open for the assessee to seek deduction or claim expenditure, which had not - 64 - been claimed in the original assessment, which assessment already stood completed, only because a assessment under Section 153A of the Act in pursuance of search

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. It was also held that it was not open for the assessee to seek deduction or claim expenditure, which had not - 64 - been claimed in the original assessment, which assessment already stood completed, only because a assessment under Section 153A of the Act in pursuance of search

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. It was also held that it was not open for the assessee to seek deduction or claim expenditure, which had not - 64 - been claimed in the original assessment, which assessment already stood completed, only because a assessment under Section 153A of the Act in pursuance of search

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

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

In the result, appeal is disposed of

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 147 are satisfied? (5) Whether on the facts and in the circumstances of the case, there was any reliable and cogent material in the recording u/s 148(2) of the Assessing Officer to initiate reassessment proceedings? (6) Whether on the facts and circumstances of the case the funds provided to the associate concerns

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 MAKINO ASIA PVT LTD

Bench: B.MANOHAR,DILIP B.BHOSALE

Section 271(1)(c)(iii) of the Act i.e., Rs.41,04,239/-. It would be necessary to notice the observations made by the Assessing officer for levying penalty, which read thus:- “The assessee company had filed its original return of income on 31.10.2002. While filing this return, the assessee company was aware that the return filed for asst.year

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

Bench: S.SUJATHA,VINEET KOTHARI

35,177 (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

KIDS CLINIC INDIA PRIVATE LIMITED

Bench: KRISHNA S DIXIT

35,177 (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