COMMR OF INCOME TAX [TDS], HYDERABAD vs. M/S JAYADARSHINI HOUSING PVT LTD., HYDERABAD

Appeals are hereby dismissed by

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

153, assess or reassess such income. 10. In the instant case, the Tribunal, while accepting the plea of the assessee that merely on change of opinion, the concluded assessment was being reopened, noticed that the Assessing Officer had already gone into specific issues arising under Section 10A of the Act. It can be noticed that from the reasons recorded

The Commissioner of Income Tax -V, vs. M/S Secunderabad Club

Bench: V.V.S.RAO,RAMESH RANGANATHAN

153 referred to as the relevant assessment year): Provided that where an assessment under sub-section (3) of section 148 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 the relevant assessment year, unless any income chargeable

Commissioner of Income Tax-III vs. S.P.Office Needs Pvt Ltd

The appeals are dismissed

2. The search operation was carried on 7'^ February, 2007 under Section 153Aofthe Act, and the Assessee was called upon to file returns for the six preceding assessment years. It is common ground that as on the date of ITA 634/2015 &Connectedmatters 'Z o/7 search, there was no pending assessment or re-assessment proceedings qua the Assessee. 3. The next

EVEREST ORGANICS LTD vs. THE COMMISSIONER OF I.T., HYDERABAD

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

reassessment on the dictates of the higher authorities sitting at Delhi and Jabalpur. 71. Once having held that the reassessment started at the dictation of the higher authorities and thereafter, during reassessment process too continuous instructions were imparted and even the AO obtained instructions, therefore, the end result would be same as the bias would exist. Decision of reassessment, reassessment

C. SANYASI RAJU vs. THE ASST. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE, VIZAG.

Bench: C.V.NAGARJUNA REDDY,T.AMARNATH GOUD

reassessment on the dictates of the higher authorities sitting at Delhi and Jabalpur. 71. Once having held that the reassessment started at the dictation of the higher authorities and thereafter, during reassessment process too continuous instructions were imparted and even the AO obtained instructions, therefore, the end result would be same as the bias would exist. Decision of reassessment, reassessment

The Commissioner of Income Tax-III vs. M/s.Samrakshna Electricals Ltd

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

reassessment on the dictates of the higher authorities sitting at Delhi and Jabalpur. 71. Once having held that the reassessment started at the dictation of the higher authorities and thereafter, during reassessment process too continuous instructions were imparted and even the AO obtained instructions, therefore, the end result would be same as the bias would exist. Decision of reassessment, reassessment

M/s.GVK Petro Chemicals Private Limited,(Novo Resins AND vs. The Deputy Commissioner of Income Tax,

reassessment on the dictates of the higher authorities sitting at Delhi and Jabalpur. 71. Once having held that the reassessment started at the dictation of the higher authorities and thereafter, during reassessment process too continuous instructions were imparted and even the AO obtained instructions, therefore, the end result would be same as the bias would exist. Decision of reassessment, reassessment

Sunil Kumar Ahuja vs. Assistant Commissioner of Income Tax

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

2 for the assessment year 2012- zure operation was conducted on ice premises of M3M Group of nder Section 153A(1)(a) of the was issued and served upon the erly known as M/s Krishna Flexi urugram on 28.03.2018. In the ts income of ` 3,53,03,79,100/-. e, the assessment order

M/s Kausalya Agro Farms and Developers pvt. ltd vs. Deputy Commissioner of Income Tax

The appeals are allowed

Bench: N.TUKARAMJI,UJJAL BHUYAN

reassessment under Section 147 of the Act overlooking the contention of the appellant that the first proviso to Section 147 of the Act is not applicable since there is full and true disclosure of all material facts necessary for assessment? 2. Whether the Tribunal misdirected itself in dealing with a contention based on Section 153

M/s. Dakshin Infrastructures Private Limited vs. Deputy Commissioner of Income Tax

The appeals are allowed

Bench: N.TUKARAMJI,UJJAL BHUYAN

reassessment under Section 147 of the Act overlooking the contention of the appellant that the first proviso to Section 147 of the Act is not applicable since there is full and true disclosure of all material facts necessary for assessment? 2. Whether the Tribunal misdirected itself in dealing with a contention based on Section 153

The Commissioner of Income Tax-III, vs. Sri. Sudheer Reddy

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

section 153-C of the Income Tax Act was issued after recording requisite satisfaction, calling upon the respondent – assessee to file its returns. The respondent – assessee is a partnership firm, which came into existence on 07.01.2005. The relevant assessment year is 2005-06. On 31.03.2008, the respondent – assessee filed its returns declaring income at Rs. 2

Commissioner of Income Tax-II vs. M/s.Kumar Raja Associates

The appeals stand dismissed

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

2. This Court while admitting the appeal (160/2008) on the following substantial question of law:- “Whether the ITAT was right and justified in dismissing the appeal as having become infructuous and not deciding the same on merits, on the ground that the asseessment order has been quashed on the ground of being barred by limitation?” 3. Another appeal (170/2008

The Pr. Commissioner of Income Tax-2 vs. M/s.ZENOTECH LABORATORIES LIMITED

Appeal is dismissed

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

2 of 4 3. This Court finds that both the CIT(A) and the ITAT have given concurrent findings of fact that no incriminating evidence/material had been found during the search. The ITAT also recorded that the present case of the Respondent was of non-abated assessment. The relevant extract of the impugned order is reproduced herein below

Commissioner of Income Tax, Guntur vs. Agricultural Market Committee, Krosur

Bench: V.V.S.RAO,RAMESH RANGANATHAN

2. I.T.A.No.166/2011 was admitted by a bench of this Court vide order dated 30.01.2012 on the following substantial questions of law: (i) Whether the Tribunal was right in holding that initiation of proceedings under Section 201(1) and 201(1A) of the Act is beyond the period of six years of the short deduction is above one lakh

The Commissioner of Income Tax-III vs. M/S Sri Krishna Drugs Ltd.,

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

153, assess or re-assess any income chargeable to tax which he has reason to believe, has escaped assessment and any other income chargeable to tax which has escaped assessment and which has come to his notice subsequently. The proviso to Section 147 lays down that where an assessment u/s 143(3) has been made, no action shall be taken

Dr.D. Siva Sankara Rao-HUF vs. I.T.O. Ward-2, Eluru

Bench: GODA RAGHURAM,M.S.RAMACHANDRA RAO

reassessment of market value using a fair and just approach. Learned Counsel clarifies that they are seeking compensation based on actual usage and future potentiality of the acquired land. It is submitted that if the land is capable of being used for building purposes in the near future, its valuation must reflect such capability. Reliance is placed on Clause

P.V.S.Raju vs. The Addl. C.I.T.

Bench: V.V.S.RAO,RAMESH RANGANATHAN

reassessment of market value using a fair and just approach. Learned Counsel clarifies that they are seeking compensation based on actual usage and future potentiality of the acquired land. It is submitted that if the land is capable of being used for building purposes in the near future, its valuation must reflect such capability. Reliance is placed on Clause

Pinna Nageswara RAo, vs. Commissioner of Income tax, IV (A.P)

Bench: P.SAM KOSHY,SUDDALA CHALAPATHI RAO

2 (2010) 5 SCC 747 3 (2004) 10 SCC 627 4 2009 (8) SCC 582 Digitally Signed By:RAHUL Signing Date:05.10.2025 11:29:12 Signature Not Verified LA.APP. 59/2007 & connected Page 88 of 171 18.4 Learned Counsel for the Appellant submits that the market value for the acquired land of village, Kilokari cannot be treated differently from the adjacent