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

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

48(SC) and Ispat Industries Ltd. v. Commissioner of Customs, Mumbai, 2006(202)ELT561(SC).In Gursahai Saigal (supra), the question which fell for consideration before this Court was construction of the machinery provisions vis-à-vis the charging provisions. Schedule appended to the Motor Vehicles Act is not machinery provision. It is a part of the charging provision

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

48 38. Having said that, let us revert to discussion of Section 158BD of the Act. The said provision is a machinery provision and inserted in the statute book for the purpose of carrying out assessments of a person other than the searched person under Sections 132 or 132A of the Act. Under Section 158BD

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 vs. M/S. IBC KNOWLEDGE PARK PVT. LTD.,

In the result, the appeals filed by the Revenue

Bench: B.V.NAGARATHNA,JAYANT PATEL

48. Section 158BD is relevant for the present case and it states that where the Assessing Officer is satisfied that any undisclosed income belongs to any person, other than the person with respect to whom search was made under Section 132 or whose books of account or other documents or any assets were requisitioned under Section 132A, then the books

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

48. Section 158BD is relevant for the present case and it states that where the Assessing Officer is satisfied that any undisclosed income belongs to any person, other than the person with respect to whom search was made under Section 132 or whose books of account or other documents or any assets were requisitioned under Section 132A, then the books

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

48. Section 158BD is relevant for the present case and it states that where the Assessing Officer is satisfied that any undisclosed income belongs to any person, other than the person with respect to whom search was made under Section 132 or whose books of account or other documents or any assets were requisitioned under Section 132A, then the books

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

48,36,10,916/- for AY 2016-17 on account of APA. 6. The voluntary TP adjustment pursuant to the APA, included ₹11,96,94,000 for the SEZ unit (which is eligible for deduction under Section 10AA of the Act) for the Assessment year 2015-16 and ₹36,90,62,637/- for AY 2016-17. Tabular statements setting

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

CORPORATION BANK vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Accordingly, the petitions are allowed

Bench: The Hon’Ble Mr. Justice Anand Byrareddy

reassessment proceedings having been initiated on a mere change of opinion, according to the learned Senior Advocate, was not permissible under Section 147 of the Act. All the details 5 regarding investment portfolio of the petitioner for the year in question, including the annual report of the petitioner for the year ended 31.03.2010, necessary for one to have to come

CORPORATION BANK vs. THE ASSISTANT COMMISSIONER

Accordingly, the petitions are allowed

Bench: The Hon’Ble Mr. Justice Anand Byrareddy

reassessment proceedings having been initiated on a mere change of opinion, according to the learned Senior Advocate, was not permissible under Section 147 of the Act. All the details 5 regarding investment portfolio of the petitioner for the year in question, including the annual report of the petitioner for the year ended 31.03.2010, necessary for one to have to come

KARNATAKA BANK LTD vs. THE ASSISTANT COMMISSIONER OF INCOME -TAX

Accordingly, the petition is allowed in

Bench: The Hon’Ble Mr. Justice Anand Byrareddy

reassessment proceedings having been initiated on a mere change of opinion, according to the learned Senior Advocate, was not permissible under Section 147 of the Act. All the details regarding investment portfolio of the petitioner for the year in question, including the annual report of the petitioner for the year ended 31.03.2010, necessary for one to have to come

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

Bench: S.SUJATHA,VINEET KOTHARI

147 of the Act for Assessment Year 2000-01 and tax liability on the capital gains of Rs.1,33,43,710/- to the extent of Rs.51,37,329/- and with interest under Sections 234A and 234B of the Act, a total demand of Rs.93,17,550/- was raised against the Assessee-firm. 7. The First Appellate Authority

KIDS CLINIC INDIA PRIVATE LIMITED

Bench: KRISHNA S DIXIT

147 of the Act for Assessment Year 2000-01 and tax liability on the capital gains of Rs.1,33,43,710/- to the extent of Rs.51,37,329/- and with interest under Sections 234A and 234B of the Act, a total demand of Rs.93,17,550/- was raised against the Assessee-firm. 7. The First Appellate Authority