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:

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

DELL INDIA PVT LTD vs. THE JOINT COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr.Justice Aravind Kumar

4 confirmed the proposed addition to the income of the petitioner on the basis of which order under section 143(3) read with Section 144C of the Act came to be passed on 31.01.2014, Annexure-H. Being aggrieved by the same petitioner is said to have filed an appeal and same is filed before first appellate authority and same

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

The appeal is dismissed

Bench: S.SUJATHA,JAYANT PATEL

section 147 of the Act or the question whether reassessment proceedings were initiated merely on change of opinion. 26. We are, therefore, of the view that in the given facts and circumstances of the case, initiation of reassessment proceedings u/s 147 of the Act is held to be illegal and consequently, order passed u/s. 147 of the Act is cancelled

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

The appeal is dismissed

Bench: N.KUMAR,RATHNAKALA

section 147 of the Act or the question whether reassessment proceedings were initiated merely on change of opinion. 26. We are, therefore, of the view that in the given facts and circumstances of the case, initiation of reassessment proceedings u/s 147 of the Act is held to be illegal and consequently, order passed u/s. 147 of the Act is cancelled

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

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

u/s 10A. Consequent short levy of tax and surcharge works out to Rs.1,76,39,326/-. Therefore, I have reasons to believe that income chargeable to tax has escaped assessment for the Ay 2003-04”. 14 As per Section 147 of the Act, if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment

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

The appeal stands allowed

Bench: S.SUJATHA,HANCHATE SANJEEVKUMAR

4) Without prejudice, whether the Tribunal is justified in law in holding that an amount of Rs.44,53,500/- is to be assessed as income under the head Capital Gain and not under income from business and consequently denied the exemption under Section 80P(2)(a)(i) of the Act, 1961 and consequently passed a perverse order on the fact

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

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

Bench: S.SUJATHA

4 - reported by the petitioner during the subject Assessment year. TPO passed a detailed order under Section 92CA(3) of the Act accepting the arm’s length price reported by the petitioner in respect of its international transactions and concluded that no adjustment was required in respect of the same. Pursuant to which respondent No.1 passed order u/s

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

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

The appeal is dismissed

Bench: S.SUJATHA,VINEET KOTHARI

u/s. 147 of the Act on the basis of change of opinion, the Hon’ble High Court of Delhi (Full Bench) in CIT, Delhi v. Kelvinator of India Ltd. [2010] 187 Taxman 312 (SC) held as under: Date of Judgment 31-07-2018 I.T.A.No.58/2012 Commissioner of Income-tax & Anr. vs. M/s. GMR Holdings Pvt. Ltd. 8/16 “In the event

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

4) (2014) 362 ITR 673(SC) - Commissioner of Income Tax – III vs. Calcutta Knitwears held as under: 20. Section 158B of the Act is the dictionary clause. It provides for the definition of “block period” and “undisclosed income”. For the purpose of this case, a reference to the definition of the “undisclosed income” as provided for in Section 158B

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

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

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

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

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

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

u/s 234 A, B & C can be levied as if such an order is a regular assessment which alone attracts such levy of interest. 2. Facts leading to filing of the appeal briefly stated are that assessee on 13.09.1994 filed its return 3 of income as a registered firm for the Assessment Year 1992-93. The Assessing Officer

SRI C M MAHADEVA S/O SRI MANCHE GOWDA vs. THE COMMISSIONER OF INCOME TAX

The appeal stands allowed

Bench: B.MANOHAR,VINEET SARAN

Reassessment made u/s 147 of the Act 1961 on 10.12.2007 for the Asst. year 2004-2005 was valid when the original Return of income involuntarily filed on 21.3.2007 remained undisposed of, when the proceedings u/s 147 were initiated on 27.9.2006? 2) Whether on the facts and in the circumstances of the case and in law, the Tribunal was right

THE ASST. COMMISSIONER OF INCOME TAX vs. M/S KOTARKI CONSTRUCTIONS PVT LTD

Bench: B.V.NAGARATHNA,J.M.KHAZI

U/S 4 of the Karnataka High Court Act praying to set aside the order dated 2.1.2018 in Writ Petition No.61671/2016 (T-IT) passed by the learned Single Judge. This appeal coming on for hearing this day, NAGARATHNA J., delivered the following: -: 2 :- J U D G M E N T The Revenue has preferred this appeal being aggrieved

PR.COMMISSIONER vs. M/S ESTEEM CLASSIC

Bench: ALOK ARADHE,M.G.S. KAMAL

U/S 4 of the Karnataka High Court Act praying to set aside the order dated 2.1.2018 in Writ Petition No.61671/2016 (T-IT) passed by the learned Single Judge. This appeal coming on for hearing this day, NAGARATHNA J., delivered the following: -: 2 :- J U D G M E N T The Revenue has preferred this appeal being aggrieved