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

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

153 referred to as the relevant assessment year): Provided that where an assessment under sub- section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of relevant assessment year, unless any income chargeable

COMMISSIONER OF INCOME TAX vs. S.MADHAVA (HUF)

The appeals are allowed

Bench: N.KUMAR,H.S.KEMPANNA

Section 153(A) of the Act, it was contended that the said search did not reveal the existence of any undisclosed income or assets representing any undisclosed income. The said search is illegal and without jurisdiction. Therefore, he wanted the entire proceedings be dropped. 7. Anyhow, he filed the very same return under protest

COMMISSIONER OF INCOME TAX vs. S.MADHAVA (HUF)

The appeals are allowed

Bench: N.KUMAR,H.S.KEMPANNA

Section 153(A) of the Act, it was contended that the said search did not reveal the existence of any undisclosed income or assets representing any undisclosed income. The said search is illegal and without jurisdiction. Therefore, he wanted the entire proceedings be dropped. 7. Anyhow, he filed the very same return under protest

COMMISSIONER OF INCOME TAX vs. S.MADHAVA, M/S BELLARY STEEL ROLING MILLS,

The appeals are allowed

Bench: N.KUMAR,H.S.KEMPANNA

Section 153(A) of the Act, it was contended that the said search did not reveal the existence of any undisclosed income or assets representing any undisclosed income. The said search is illegal and without jurisdiction. Therefore, he wanted the entire proceedings be dropped. 7. Anyhow, he filed the very same return under protest

COMMISSIONER OF INCOME TAX vs. S.MADHAVA, M/S BELLARY STEEL ROLING MILLS,

The appeals are allowed

Bench: N.KUMAR,H.S.KEMPANNA

Section 153(A) of the Act, it was contended that the said search did not reveal the existence of any undisclosed income or assets representing any undisclosed income. The said search is illegal and without jurisdiction. Therefore, he wanted the entire proceedings be dropped. 7. Anyhow, he filed the very same return under protest

COMMISSIONER OF INCOME TAX vs. S.PARVATHI MADHAVA

The appeals are allowed

Bench: N.KUMAR,H.S.KEMPANNA

Section 153(A) of the Act, it was contended that the said search did not reveal the existence of any undisclosed income or assets representing any undisclosed income. The said search is illegal and without jurisdiction. Therefore, he wanted the entire proceedings be dropped. 7. Anyhow, he filed the very same return under protest

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

68 - against the assessee and seized goods having been released in favour of the assessee, notice could be issued under Section 153C of the Act to file returns for six years. The stand of the Revenue therein was that the Assessing Officer could still proceed under Section 153A of the Act in order to find out the source

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

68 - against the assessee and seized goods having been released in favour of the assessee, notice could be issued under Section 153C of the Act to file returns for six years. The stand of the Revenue therein was that the Assessing Officer could still proceed under Section 153A of the Act in order to find out the source

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

68 - against the assessee and seized goods having been released in favour of the assessee, notice could be issued under Section 153C of the Act to file returns for six years. The stand of the Revenue therein was that the Assessing Officer could still proceed under Section 153A of the Act in order to find out the source

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

153 C of the Act will taken as the year of search for the purpose of clause(a) and (b) of sub-section 1 of Section 153A by making reference to proviso to sub-section 1 of Section 153C despite the fact that the first proviso to sub-section 1 of Section 153C refers

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

Bench: K.SOMASHEKAR,UMESH M ADIGA

153 C of the Act will taken as the year of search for the purpose of clause(a) and (b) of sub-section 1 of Section 153A by making reference to proviso to sub-section 1 of Section 153C despite the fact that the first proviso to sub-section 1 of Section 153C refers

COMMISSIONER OF INCOME vs. M/S C RAMAIAH REDDY

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

Bench: ALOK ARADHE,M.NAGAPRASANNA

68,180/- as long term capital gains and a sum of Rs.61,32,800/- as short term capital gains by invoking Section 45(2) of the Act. 3. The assessee preferred an appeal before the Commissioner of Income Tax (Appeals) on the ground that reopening of assessment is invalid since, no notice under Section

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

153 ITR 11(FB) under the Wealth Tax Act, it was held credit for income tax paid in other country in relation to income under Section 10-A will not be available under Section 90(1)(a). Under Section 90(1)(b), the Central - 32 - Government may enter into an agreement with the Government of any country

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

153 ITR 11(FB) under the Wealth Tax Act, it was held credit for income tax paid in other country in relation to income under Section 10-A will not be available under Section 90(1)(a). Under Section 90(1)(b), the Central - 32 - Government may enter into an agreement with the Government of any country

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S. TE CONNECTIVITY INDIA PVT. LTD.,

Accordingly dispose of the appeal as allowed

Bench: ACTING CHIEF JUSTICE,S RACHAIAH

68 taxmann.com 148 (Karnataka)]; - 14 - ITA No.53 of 2024 iv. CIT and anr. -Vs.- Sun Microsystems India Pvt. Ltd. (Order dated 06.04.2015 passed by this Court in ITA No. 203/2009); v. CIT -Vs.- Chemsworth Pvt. Ltd. [(2020) 119 taxmann.com 358 (Karnataka)]; vi. ACIT -Vs.- Marico Ltd. [(2020) 117 taxmann.com 244 (SC)]; vii. JCIT -Vs.- Cognizant Technology Solutions India

THE COMMISSIONER vs. M/S VIJAYA BANK

Appeals are allowed in part

Bench: ALOK ARADHE,RAVI V HOSMANI

68. The Hon’ble Supreme Court while considering the provisions of Section 162 of the Code of Criminal Procedure and Section 27 of the Evidence Act in the case of 59 Vijender v. State of Delhi reported in (1997) 6 SCC 171 held at paragraph-17 as under: 17. Another elementary statutory breach which we notice in recording

M/S UNITED TELECOM LTD vs. THE DEPUTY COMMISSIONER OF

Appeals are allowed in part

Bench: S.SUJATHA,JAYANT PATEL

68. The Hon’ble Supreme Court while considering the provisions of Section 162 of the Code of Criminal Procedure and Section 27 of the Evidence Act in the case of 59 Vijender v. State of Delhi reported in (1997) 6 SCC 171 held at paragraph-17 as under: 17. Another elementary statutory breach which we notice in recording

M/S. MANDAVI BUILDERS, vs. DY. COMMISSIONER OF INCOME TAX

In the result, the appeal is disposed of

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

153(c) of the Act was issued on 20.06.2011, by which the assessee was asked to file returns of income for Assessment Years 2010-11 and 2011-2012. The assessee filed the return in response to the notice and declared the income as ‘NIL’ for both Assessment Years after claiming deduction under Section 80IB