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:

1) to mean the entire process of assessment; section 153(2) uses the words, ‘assessment’, ‘reassessment’ or ‘recomputation’ but in respect of section 147 which deals with income escaping assessment; section 153(3) uses the term “fresh assessment” in pursuance of the orders passed setting aside or cancelling an assessment; therefore, this term “fresh assessment”, though not defined, contemplates

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

36 order to find out what is the “total income” of each year and then pass the assessment order. Therefore, the Commissioner by virtue of the power conferred under Section 263 of the Act gets no jurisdiction to initiate proceedings under the said provision because the condition precedent for initiating proceedings under Section 263 is any order passed under

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

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

36 - officer has some reason to believe that the income has escaped assessment. The use of the words ‘reason to believe’ in Section 147 has to be interpreted schematically as the liberal interpretation of the word would have the consequence of conferring arbitrary powers on the assessing officer who may even initiate such re-assessment proceedings merely on his change

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

36 Assessing Officer gets reopened, there is no order which can be said to be erroneous insofar as it is prejudicial to the interest of the revenue which confers jurisdiction on the Commissioner to exercise the power of the jurisdiction. II) CIT vs. IBC Knowledge Park(P) Ltd., held as under: “46. 153C is relevant for the purposes of this

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. IBC KNOWLEDGE PARK PVT. LTD.,

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

36 taxmann.com 523 (Rajasthan)], it was held that no doubt the Assessing Officer is free to disturb income, expenditure or deduction de hors any incriminating material, while making an assessment under Section 153A of the Act. But in the context of a search, Section 153A to 153C cannot be interpreted to be a “further innings” for the Assessing Officer and/or

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

36 taxmann.com 523 (Rajasthan)], it was held that no doubt the Assessing Officer is free to disturb income, expenditure or deduction de hors any incriminating material, while making an assessment under Section 153A of the Act. But in the context of a search, Section 153A to 153C cannot be interpreted to be a “further innings” for the Assessing Officer and/or

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

36 taxmann.com 523 (Rajasthan)], it was held that no doubt the Assessing Officer is free to disturb income, expenditure or deduction de hors any incriminating material, while making an assessment under Section 153A of the Act. But in the context of a search, Section 153A to 153C cannot be interpreted to be a “further innings” for the Assessing Officer and/or

THE COMMISSIONER OF INCOME TAX vs. M/S.MILLENNIA DEVELOPERS (P) LTD

Bench: The Hon'Ble Mr. Justice Ravi Malimath

u/s. 171 of the Act), where this amount is settled among the HUF members, 5 when the assessee company is a separate entity from that of the share holders? ii) Whether the Appellate Authorities were correct in accepting a family arrangement and partition among the share holders and their relatives vis a vie the assessee company and four accounting entries

THE COMMISSIONER OF INCOME TAX vs. M/S.MILLENNIA DEVELOPERS (P) LTD

Bench: The Hon'Ble Mr. Justice Ravi Malimath

u/s. 171 of the Act), where this amount is settled among the HUF members, 5 when the assessee company is a separate entity from that of the share holders? ii) Whether the Appellate Authorities were correct in accepting a family arrangement and partition among the share holders and their relatives vis a vie the assessee company and four accounting entries

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