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

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

4. It is the contention of the petitioner that the very same issue came up for adjudication for the Assessment Year 2007-08. Submissions were made by the petitioner pertaining to this issue in terms of the letter dated 11.08.2009. The respondent, after considering the same, completed the assessment under section 143[3] of the Act for the Assessment Year

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, CIT(A) vs. M/S HEWLETT PACKARD GLOBALSOFT PVT LTD

Appeals are hereby dismissed by

Bench: ARAVIND KUMAR,VINEET SARAN

4. Briefly stated facts are: Assessee is a company engaged in the business of software development. For the assessment year 2003-04 return of income was filed whereunder the assessee claimed deduction under Section 10A of the Act. The assessee had excluded the expenses incurred in foreign currency for providing technical services. The return of income was processed

THE COMMISSIONER OF INCOME TAX vs. M/S SHASTHA PHARMA LABORATORIES

The appeal is dismissed

Bench: N.KUMAR,RATHNAKALA

5. Aggrieved by the said order of the assessing authority, the assessee preferred an appeal to the Commissioner of Income Tax (Appeals). The appellate authority confirmed the assessment made but for - 7 - statistical purpose the appeal was treated as dismissed, since despite the acceptance of one of the pleadings raised, the end result is the confirmation of the assessment order

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 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

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

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

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

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. SHRI. GALI JANARDHANA REDDY

Bench: K.SOMASHEKAR,UMESH M ADIGA

5 total income under the original assessment order passed. However, it was noticed that though the assessment proceedings was initiated by issue of notice under Section 143(2), The Tribunal vide said order also knocked down the assessment proceedings completed under Section 144 read with Section 153D on similar ground that no satisfaction note was recorded by the assessing officer

COMMISSIONER OF INCOME TAX TDS vs. M/S BHARAT HOTELS LIMITED

Appeal stands dismissed

Bench: S.SUJATHA,VINEET SARAN

5 under sub-section (1), and the amount of interest payable under sub-section (1A) of Section 201 of the Act was quantified. The appeal filed by the assessee was allowed by the Appellate Commissioner on 30.5.2008, holding that the order passed by the Assessing Officer was time barred. However, by subsequent order dated 30.9.2008 passed under Section

MR SUNIL H ASHAR vs. INCOME TAX OFFICER

Bench: The Hon'Ble Mr. Justice Ram Mohan Reddy

5 SECTION 147 OF THE INCOME TAX ACT 1961 DATED 31.7.2014 FOR THE ASSESSMENT YEAR 2007-08, i.e. ANN-C AND CONSEQUENTIAL NOTICE OF DEMAND ISSUED BY THE RESONDENT DATED 31.7.2014 FOR THE ASSESSMENT YEAR 2007-08 i.e. ANN-D & ETC., IN WP NO 7931 OF 2015 BETWEEN M/S. VARDHAMAN METALS OMKAR HOUSE, NO. 8/1 4TH CROSS, KALASIPALYAM NEW EXTENSION

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

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