THE PR. COMMISSIONER OF INCOME-TAX vs. M/S FIBRES AND FABRICS INTERNATIONAL PVT. LTD.,

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

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

147 of the Income Tax cannot be based on mere change of opinion of the Assessing Officer, the third question will have to be answered in the negative. In fact, in view of settled law, framing of question No.3 was not warranted at all." 13 9. The Assessing Officer has recorded the following reasons for re-opening the assessment

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

147 read with Section 144 by bringing to tax all the income which formed part of 6 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

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

147 read with Section 144 by bringing to tax all the income which formed part of 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

THE COMMISSIONER OF INCOME TAX vs. SRI N LEELA KUMAR

Bench: N.KUMAR,RATHNAKALA

147 have been concluded prior to the date of commencement of the search or the date of requisition, on the basis of such assessments; - 9 - (b) where returns of income have been filed under section 139 or in response to a notice issued under sub-section (1) of section 142 or section 148 but assessments have

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

THE COMMISSIONER OF INCOME TAX vs. KENNAMETAL INC,USA

Bench: KRISHNA S DIXIT,RAMACHANDRA D. HUDDAR

68 of 2024 in cases where assessment, reassessment, or recomputation is to be made under Section 147 of the Act, pursuant

SRI G LALANATHA REDDY vs. THE ASST COMMISSIONER OF INCOME TAX

Appeals stand dismissed

Bench: D K SINGH,VENKATESH NAIK T

68 OF 2022 INCOME TAX APPEAL NO. 71 OF 2022 INCOME TAX APPEAL NO. 86 OF 2022 INCOME TAX APPEAL NO. 121 OF 2022 INCOME TAX APPEAL NO. 177 OF 2022 INCOME TAX APPEAL NO. 292 OF 2022 AND INCOME TAX APPEAL NO. 305 OF 2022 IN ITA No. 178/2022: BETWEEN: 1. SRI G LALANATHA REDDY AGED 45 YEARS

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. It was also held that it was not open for the assessee to seek deduction or claim expenditure, which had not - 64 - been claimed in the original assessment, which assessment already stood completed, only because a assessment under Section 153A of the Act in pursuance of search

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. It was also held that it was not open for the assessee to seek deduction or claim expenditure, which had not - 64 - been claimed in the original assessment, which assessment already stood completed, only because a assessment under Section 153A of the Act in pursuance of search

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

147 (income escaping assessment) and 263 (revision of orders) of the Act. It was also held that it was not open for the assessee to seek deduction or claim expenditure, which had not - 64 - been claimed in the original assessment, which assessment already stood completed, only because a assessment under Section 153A of the Act in pursuance of search

M/S SUBEX LTD vs. THE COMMISSIONER OF INCOME TAX-III,

In the result, appeal is partly allowed as indicated

Bench: S.SUJATHA,RAVI V HOSMANI

147 or 263 of the Act had been taken in relation to the said assessment year. Thus, it has been held that once the claim has been granted by the assessing officer in respect of previous years, such claim cannot be disallowed subsequently without disturbing the decision in the initial year. In that context, it was held that the view

M/S KAVERI ASSOCIATES vs. THE ASSISTANT COMMISSIONER

In the result, the appeal is disposed of

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

147 of the Act. Being aggrieved, the assessee filed an appeal before Commissioner of Income Tax (Appeals), which was dismissed by an order dated 29.09.2009. The order of the Commissioner of Income Tax (Appeals) was upheld by the Income Tax Appellate Tribunal (hereinafter referred to as ‘the Tribunal’, for short) vide order dated 29.03.2010. 7 3. The assessee thereupon approached

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

Bench: CHIEF JUSTICE,C M JOSHI

68,251/- made on account of capital gains. During the previous year relevant to AY 2017-18, a partnership firm namely M/s. Perpetual Investments, was converted into a private company [the assessee]. The said conversion entailed the transfer of the entire assets and liabilities from the partnership firm to the assessee company. Whereas the assessee claimed that the conversion

THE COMMISSIONER OF INCOME TAX vs. MRS SHAKUNTALA DEVI

Appeal is hereby dismissed

Bench: ARAVIND KUMAR,JAYANT PATEL

147 and in response to the notice issued under Section 148, reply came to be filed by the assessee stating thereunder that original return filed is to be treated as return filed in response to the notice issued under Section 148. Accordingly, assessment proceedings came to be framed. 3. Assessing officer has noticed that assessee had sold

THE PR. COMMISSIONER OF INCOME TAX-2 vs. M/S LTI MINDTREE LTD

Bench: JAYANT BANERJI,S.G.PANDIT

68,310/- under Section 115JB of the Act. The case was selected for scrutiny and notice under Section 143(2) of the Act was issued on 01.09.2015. The assessment was concluded under Section 143(3) by making certain additions/disallowances to the total income. On conclusion of the assessment, the claim of depreciation of Rs.28

M/S. DEEPAK EXTRUSIONS PVT LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr.Justice Raghvendra S. Chauhan

68 of the Income Tax Act, 1961 (`Act’ for short). 2. Briefly the facts of the case are that the petitioner claims that he had filed his Income Tax Returns on 26.10.2007, under Section 139 of the Act, for the Assessment Year 2007-08. He had declared his income as Rs.46,540/-, the same was processed on 24.12.2008 under

MR H K SAROJAMMA vs. THE INCOME TAX OFFICER

Bench: The Hon'Ble Mr.Justice S. Sunil Dutt Yadav

68 years, Residing at: Paarnavi, Opp. Horticulture Office, VP Extention, Chitradurga. … Petitioner (By Sri Harish V.S., Advocate) AND: The Income Tax Officer, ITO Ward 1, Aayakar Bhavan, Tamatkal Road, Medehally, Chitradurga - 577 502. … Respondent ***** This Writ Petition is filed under Articles 226 & 227 of the Constitution of India, praying to quash the impugned order passed by the respondent disposing

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