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:

ii) On the other hand, the phrase ‘fresh assessment’ has been used in the following sections: • Proviso (a) to Section 240; • Section 251(1)(a) –words omitted by Finance Act, 2001 with effect from 01.06.2001. • Explanation 1(iii) to section 245A(b). 29 • Section 153(2A) prior to substitution by Finance Act, 2016 with effect from 01.06.2016. • Section

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

II) CIT vs. IBC Knowledge Park(P) Ltd., held as under: “46. 153C is relevant for the purposes of this case. Sub-section (1) of Section 153C begins with a non- obstante clause and it states that notwithstanding anything contained in Sections 139, 147, 148, 149, 151 and 153, where the Assessing Officer is satisfied that any valuable assets, seized

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

II R 2 LARGE TAX PAYERS UNIT (LTU) JSS TOWERS, 100 FEET RING ROAD, BANASHANKARI III STAGE, BENGALURU-560085 ..RESPONDENTS (BY SRI.K.V.ARAVIND, PANEL ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLE 226 OF CONSTITUTION OF INDIA PRAYING TO: DECLARE THAT THE IMPUGNED PROCEEDINGS INITIATED BY THE R-1 UNDER SECTION 147 READ WITH SECTION 148 OF THE ACT ARE WITHOUT

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 vs. M/S MAKINO ASIA PVT LTD

Bench: B.MANOHAR,DILIP B.BHOSALE

II. ALLOW THE APPEAL AND SET ASIDE THE ORDER PASSED BY ITAT BANGALORE, IN ITANO.3026/BANG/2004 DATED 15-09- 2006 & CONFIRM THE ORDER OF THE APPELLATE COMMISSIONER CONFIRMING THE ORDER PASSED BY THE ASST.COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-19(1), BANGALORE, IN THE INTEREST OF JUSTICE AND EQUITY. THIS ITA COMING ON FOR HEARING, THIS DAY, THE COURT DELIVERED

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

ii) Whether on the facts and in the circumstances of the case the Tribunal was justified in law in placing reliance on its own 3 order in the case of DHFL Vysya Housing Finance P Ltd., (DVHF) ITA NO.1416/Bang/2010 for AY 96-97 dated 11-01-2013 and holding that the reopening u/s. 147 is bad in law without appreciating

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

In the result, appeal is disposed of

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

1) Whether the Assessing Officer to justify action u/s 147 can travel beyond his recording u/s 148(2) and the material therein? 2) Whether on the facts and in the circumstances of the case the Appellate Tribunal was right in law in upholding that the action of the Assessing Officer in assuming jurisdiction u/s 147 3 of the Income

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