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5 results for “reassessment u/s 147”+ Permanent Establishmentclear

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Key Topics

Section 14812Section 143(3)8Section 1475Section 151(2)4Reassessment3Reopening of Assessment3Section 144C(13)2

DEPUTY DIRECTOR OF INCOME-TAX vs. SANDVIK A B.,, PUNE

ITA 608/PUN/2014[2006-07]Status: DisposedITAT Pune05 Jun 2018AY 2006-07

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

For Appellant: S/Shri Nikhil Pathak & S. SrinivasFor Respondent: S/Shri Rajeev Kumar, CIT & Ajay Modi, JCIT
Section 143(3)Section 144C(13)Section 148Section 151(2)

permanent establishment of STSA in India, such payments are not considered as taxable in India.” 9. The Auditor in the audit report in Form No.3CEB had also reported in respect of said receipts which is placed at page 14 of Compilation No.I, which read as under:- CO Nos.20 & 28/PUN/2015 Sr. Name and address of Description of Amount paid/received or Method

DEPUTY DIRECTOR OF INCOME-TAX,, PUNE vs. SANDVIK A B.,, PUNE

ITA 623/PUN/2014[2005-06]Status: DisposedITAT Pune05 Jun 2018AY 2005-06

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.608/Pun/2014 यििाारण वषा / Assessment Year :2006-07

For Appellant: S/Shri Nikhil Pathak & S. SrinivasFor Respondent: S/Shri Rajeev Kumar, CIT & Ajay Modi, JCIT
Section 143(3)Section 144C(13)Section 148Section 151(2)

permanent establishment of STSA in India, such payments are not considered as taxable in India.” 9. The Auditor in the audit report in Form No.3CEB had also reported in respect of said receipts which is placed at page 14 of Compilation No.I, which read as under:- CO Nos.20 & 28/PUN/2015 Sr. Name and address of Description of Amount paid/received or Method

BMC SOFTWARE ASIA PACIFIC PTE LTD,SINGAPORE vs. ACIT (INTERNATIONAL TAX) CIRCLE-1, PUNE

In the result, the appeal is allowed

ITA 2048/PUN/2019[2010-11]Status: DisposedITAT Pune03 Sept 2021AY 2010-11

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryनिर्धारण वषा / Assessment Year: 2010-11 Bmc Software Asia Pacific Pte Vs. Acit (International Tax), Ltd., Circle-1, Pune 600, North Bridge Road, 20-01/10 Park View Square, Singapore – 188778 Pan : Aaecb0642A Appellant Respondent

Section 143(3)Section 148

u/s 148 of the Act. On being show caused as to why income from sale of software was not offered for taxation, the assessee submitted that it was not the owner of the software licenses rather it was only permitted to distribute such software licenses in the Asia Pacific region. Relying on the judgment of Hon‟ble Karnataka High Court

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. M/S. SECO TOOLS INDIA PVT. LTD.,, PUNE

In the result, the Cross Objections of assessee are allowed and appeals of Revenue are dismissed

ITA 813/PUN/2017[2003-04]Status: DisposedITAT Pune01 Aug 2019AY 2003-04

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.812 & 813/Pun/2017 यििाारण वषा / Assessment Years : 2002-03 & 2003-04

For Appellant: Shri Nikhil PathakFor Respondent: Shri Sudhendu Das
Section 143(1)Section 143(3)Section 147Section 148Section 36(1)(iii)

permanent establishment of STSA in India, such payments are not considered as taxable in India.” ITA Nos.812 & 813/PUN/2017 9 CO Nos.30 & 31/PUN/2018 M/s. Seco Tools India Pvt. Ltd. 9. The Auditor in the audit report in Form No.3CEB had also reported in respect of said receipts which is placed at page 14 of Compilation No.I, which read as under

M/S. KASTURI RASHI DEVELOPERS,,PUNE vs. INCOME-TAX OFFICER, WARD - 5(3), , PUNE

In the result, the appeal is dismissed

ITA 1961/PUN/2017[2007-08]Status: DisposedITAT Pune07 Mar 2022AY 2007-08

Bench: Shri R.S. Syal

Section 131Section 132(4)Section 147Section 148

147 of the I.T. Act, 1961.” 5. It can be seen from the above reasons that the AO received information from DGIT (Inv.), Pune giving a list of beneficiaries of accommodation entries provided by Mr. Praveen Kumar Jain group of concerns. In the list so received, the name of the assessee appeared along with its address as beneficiary