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

Bench: K.SOMASHEKAR,UMESH M ADIGA

68,753 235B – 1,59,97,806 2,90,66,559 13 Total Tax 10,16,70,745 Less: 140A paid 2,00,00,000 Net Amount Payable 8,16,70,745 13. It is further contended by the standing counsel for the appellant, that against the order passed by the Deputy Commissioner of Income Tax, Central Circle 1

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

1) The first stage comprises of a search and seizure operation under Section 132 or proceeding under Section 132A against a person, who may be referred as 'the searched person'. Based on such search and seizure, assessment proceedings are initiated against the 67 'searched person' under Section 153A. At the time of initiation of such proceedings against

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

68. What follows is, if the provisions contained in Section 90 is more beneficial to the assessee as compared to the - 85 - terms in the agreement by India with the Government of any country outside India then, notwithstanding such agreement, the provisions of the Act to the extent they are beneficial to that assesseee apply. The benefit claimed

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

68. What follows is, if the provisions contained in Section 90 is more beneficial to the assessee as compared to the - 85 - terms in the agreement by India with the Government of any country outside India then, notwithstanding such agreement, the provisions of the Act to the extent they are beneficial to that assesseee apply. The benefit claimed

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

132 of the Act, notice under Section 153A(1) will have to be mandatorily issued to the person in respect of whom search was conducted requiring him to file returns for six assessment years immediately proceeding the previous year relevant to the assessment year in which the search takes place. (ii) Assessment and re-assessments pending on the date

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

132 of the Act, notice under Section 153A(1) will have to be mandatorily issued to the person in respect of whom search was conducted requiring him to file returns for six assessment years immediately proceeding the previous year relevant to the assessment year in which the search takes place. (ii) Assessment and re-assessments pending on the date

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

132 of the Act, notice under Section 153A(1) will have to be mandatorily issued to the person in respect of whom search was conducted requiring him to file returns for six assessment years immediately proceeding the previous year relevant to the assessment year in which the search takes place. (ii) Assessment and re-assessments pending on the date

THE COMMISSIONER OF INCOME TAX vs. SRI N LEELA KUMAR

Bench: N.KUMAR,RATHNAKALA

1) or sub-section (1B) of section 143.. (2) In computing the undisclosed income of the block period, the provisions of sections 68, 69, 69A, 69B and 69C shall, so far as may be, - 12 - apply and references to "financial year" in those sections shall be construed as references to the relevant previous year falling

THE PR COMMISSIONER OF INCOME TAX vs. M/S ATRIA WIND (KADAMBUR) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

132 of the Act. It was noted that thereafter notice under Section 153A of the Act was issued. The Assessing Officer [AO] determined the total income of the assessee at ₹1,89,11,81,757/-. The said determination was based on an addition of a sum of ₹1,91,95,68

SHRI S THIMMARAJU vs. THE DEPUTY DIRECTOR

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.38642/2016 C/W W.P. Nos.15917/2013, 15918/2013, 39889/2014, 17894/2015, 24444/2015, 19313/2016, 23176/2016, 33740/2016, 42157/2016, 57756/2016, 62102/2016, 4215/2017, 5269/2017, 6159/2017, 6173/2017, 8261/2017, 13160/2017, 14158/2017, 18557/2017, 36309/2017, 36310/2017, 41176/2017, 46318/2017, 48031/2017, 24480/2018, 27705/2018, 27744/2018, 28027/2018, 35991/2018 (Gm-Res) In W.P. No.38642/2016: Between: 1 . Mr. Dyani Antony Paul S/O Late Joseph Paul Aged About 33 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore - 575 008. 2 . Mr. Lawence Paul S/O Late Joseph Paul Aged About 42 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore – 575 008. ®

Section 60 of PML Act would indicate that whatever orders that are passed under the PML Act, would be applicable in a contracting state or in India. He would submit by interpreting Chapter IX that it cannot be said that order of attachment is vitiated though reciprocal agreement provides otherwise. He would submit that where an order of attachment

M/S. JSW STEEL LIMITED vs. DEPUTY DIRECTOR

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.38642/2016 C/W W.P. Nos.15917/2013, 15918/2013, 39889/2014, 17894/2015, 24444/2015, 19313/2016, 23176/2016, 33740/2016, 42157/2016, 57756/2016, 62102/2016, 4215/2017, 5269/2017, 6159/2017, 6173/2017, 8261/2017, 13160/2017, 14158/2017, 18557/2017, 36309/2017, 36310/2017, 41176/2017, 46318/2017, 48031/2017, 24480/2018, 27705/2018, 27744/2018, 28027/2018, 35991/2018 (Gm-Res) In W.P. No.38642/2016: Between: 1 . Mr. Dyani Antony Paul S/O Late Joseph Paul Aged About 33 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore - 575 008. 2 . Mr. Lawence Paul S/O Late Joseph Paul Aged About 42 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore – 575 008. ®

Section 60 of PML Act would indicate that whatever orders that are passed under the PML Act, would be applicable in a contracting state or in India. He would submit by interpreting Chapter IX that it cannot be said that order of attachment is vitiated though reciprocal agreement provides otherwise. He would submit that where an order of attachment

M GOPI vs. THE JOINT DIRECTOR

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.38642/2016 C/W W.P. Nos.15917/2013, 15918/2013, 39889/2014, 17894/2015, 24444/2015, 19313/2016, 23176/2016, 33740/2016, 42157/2016, 57756/2016, 62102/2016, 4215/2017, 5269/2017, 6159/2017, 6173/2017, 8261/2017, 13160/2017, 14158/2017, 18557/2017, 36309/2017, 36310/2017, 41176/2017, 46318/2017, 48031/2017, 24480/2018, 27705/2018, 27744/2018, 28027/2018, 35991/2018 (Gm-Res) In W.P. No.38642/2016: Between: 1 . Mr. Dyani Antony Paul S/O Late Joseph Paul Aged About 33 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore - 575 008. 2 . Mr. Lawence Paul S/O Late Joseph Paul Aged About 42 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore – 575 008. ®

Section 60 of PML Act would indicate that whatever orders that are passed under the PML Act, would be applicable in a contracting state or in India. He would submit by interpreting Chapter IX that it cannot be said that order of attachment is vitiated though reciprocal agreement provides otherwise. He would submit that where an order of attachment

NATARAJ DAKSHINAMURHTY vs. THE ASSISTANT DIRECTOR

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.38642/2016 C/W W.P. Nos.15917/2013, 15918/2013, 39889/2014, 17894/2015, 24444/2015, 19313/2016, 23176/2016, 33740/2016, 42157/2016, 57756/2016, 62102/2016, 4215/2017, 5269/2017, 6159/2017, 6173/2017, 8261/2017, 13160/2017, 14158/2017, 18557/2017, 36309/2017, 36310/2017, 41176/2017, 46318/2017, 48031/2017, 24480/2018, 27705/2018, 27744/2018, 28027/2018, 35991/2018 (Gm-Res) In W.P. No.38642/2016: Between: 1 . Mr. Dyani Antony Paul S/O Late Joseph Paul Aged About 33 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore - 575 008. 2 . Mr. Lawence Paul S/O Late Joseph Paul Aged About 42 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore – 575 008. ®

Section 60 of PML Act would indicate that whatever orders that are passed under the PML Act, would be applicable in a contracting state or in India. He would submit by interpreting Chapter IX that it cannot be said that order of attachment is vitiated though reciprocal agreement provides otherwise. He would submit that where an order of attachment

DESARAJU VENUGOPAL vs. THE ASSISTANT DIRECTOR

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.38642/2016 C/W W.P. Nos.15917/2013, 15918/2013, 39889/2014, 17894/2015, 24444/2015, 19313/2016, 23176/2016, 33740/2016, 42157/2016, 57756/2016, 62102/2016, 4215/2017, 5269/2017, 6159/2017, 6173/2017, 8261/2017, 13160/2017, 14158/2017, 18557/2017, 36309/2017, 36310/2017, 41176/2017, 46318/2017, 48031/2017, 24480/2018, 27705/2018, 27744/2018, 28027/2018, 35991/2018 (Gm-Res) In W.P. No.38642/2016: Between: 1 . Mr. Dyani Antony Paul S/O Late Joseph Paul Aged About 33 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore - 575 008. 2 . Mr. Lawence Paul S/O Late Joseph Paul Aged About 42 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore – 575 008. ®

Section 60 of PML Act would indicate that whatever orders that are passed under the PML Act, would be applicable in a contracting state or in India. He would submit by interpreting Chapter IX that it cannot be said that order of attachment is vitiated though reciprocal agreement provides otherwise. He would submit that where an order of attachment

M GOPI vs. THE JOINT DIRECTOR

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.38642/2016 C/W W.P. Nos.15917/2013, 15918/2013, 39889/2014, 17894/2015, 24444/2015, 19313/2016, 23176/2016, 33740/2016, 42157/2016, 57756/2016, 62102/2016, 4215/2017, 5269/2017, 6159/2017, 6173/2017, 8261/2017, 13160/2017, 14158/2017, 18557/2017, 36309/2017, 36310/2017, 41176/2017, 46318/2017, 48031/2017, 24480/2018, 27705/2018, 27744/2018, 28027/2018, 35991/2018 (Gm-Res) In W.P. No.38642/2016: Between: 1 . Mr. Dyani Antony Paul S/O Late Joseph Paul Aged About 33 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore - 575 008. 2 . Mr. Lawence Paul S/O Late Joseph Paul Aged About 42 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore – 575 008. ®

Section 60 of PML Act would indicate that whatever orders that are passed under the PML Act, would be applicable in a contracting state or in India. He would submit by interpreting Chapter IX that it cannot be said that order of attachment is vitiated though reciprocal agreement provides otherwise. He would submit that where an order of attachment

MR DYANI ANTONY PAUL vs. UNION OF INDIA

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.38642/2016 C/W W.P. Nos.15917/2013, 15918/2013, 39889/2014, 17894/2015, 24444/2015, 19313/2016, 23176/2016, 33740/2016, 42157/2016, 57756/2016, 62102/2016, 4215/2017, 5269/2017, 6159/2017, 6173/2017, 8261/2017, 13160/2017, 14158/2017, 18557/2017, 36309/2017, 36310/2017, 41176/2017, 46318/2017, 48031/2017, 24480/2018, 27705/2018, 27744/2018, 28027/2018, 35991/2018 (Gm-Res) In W.P. No.38642/2016: Between: 1 . Mr. Dyani Antony Paul S/O Late Joseph Paul Aged About 33 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore - 575 008. 2 . Mr. Lawence Paul S/O Late Joseph Paul Aged About 42 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore – 575 008. ®

Section 60 of PML Act would indicate that whatever orders that are passed under the PML Act, would be applicable in a contracting state or in India. He would submit by interpreting Chapter IX that it cannot be said that order of attachment is vitiated though reciprocal agreement provides otherwise. He would submit that where an order of attachment

SHRI C DEVARAJU vs. THE DEPUTY DIRECTOR

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.38642/2016 C/W W.P. Nos.15917/2013, 15918/2013, 39889/2014, 17894/2015, 24444/2015, 19313/2016, 23176/2016, 33740/2016, 42157/2016, 57756/2016, 62102/2016, 4215/2017, 5269/2017, 6159/2017, 6173/2017, 8261/2017, 13160/2017, 14158/2017, 18557/2017, 36309/2017, 36310/2017, 41176/2017, 46318/2017, 48031/2017, 24480/2018, 27705/2018, 27744/2018, 28027/2018, 35991/2018 (Gm-Res) In W.P. No.38642/2016: Between: 1 . Mr. Dyani Antony Paul S/O Late Joseph Paul Aged About 33 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore - 575 008. 2 . Mr. Lawence Paul S/O Late Joseph Paul Aged About 42 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore – 575 008. ®

Section 60 of PML Act would indicate that whatever orders that are passed under the PML Act, would be applicable in a contracting state or in India. He would submit by interpreting Chapter IX that it cannot be said that order of attachment is vitiated though reciprocal agreement provides otherwise. He would submit that where an order of attachment

MEERAMA OVERSEAS PVT LTD vs. THE DEPUTY DIRECTOR

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.38642/2016 C/W W.P. Nos.15917/2013, 15918/2013, 39889/2014, 17894/2015, 24444/2015, 19313/2016, 23176/2016, 33740/2016, 42157/2016, 57756/2016, 62102/2016, 4215/2017, 5269/2017, 6159/2017, 6173/2017, 8261/2017, 13160/2017, 14158/2017, 18557/2017, 36309/2017, 36310/2017, 41176/2017, 46318/2017, 48031/2017, 24480/2018, 27705/2018, 27744/2018, 28027/2018, 35991/2018 (Gm-Res) In W.P. No.38642/2016: Between: 1 . Mr. Dyani Antony Paul S/O Late Joseph Paul Aged About 33 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore - 575 008. 2 . Mr. Lawence Paul S/O Late Joseph Paul Aged About 42 Years No.1/77, Vailankani Cottage Padavinangady, Konchady Mugrody Road Mangalore – 575 008. ®

Section 60 of PML Act would indicate that whatever orders that are passed under the PML Act, would be applicable in a contracting state or in India. He would submit by interpreting Chapter IX that it cannot be said that order of attachment is vitiated though reciprocal agreement provides otherwise. He would submit that where an order of attachment