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

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

5. According to the learned Attorney-General the assessment proceedings are not of a quasi-judicial nature nor is the Assessing authority a quasi- judicial authority. We are unable to agree. It is apparent from the judgment referred to above and numerous other decisions of this Court delivered in respect of various taxation laws that the Assessing authorities exercise quasi

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

5. According to the learned Attorney-General the assessment proceedings are not of a quasi-judicial nature nor is the Assessing authority a quasi- judicial authority. We are unable to agree. It is apparent from the judgment referred to above and numerous other decisions of this Court delivered in respect of various taxation laws that the Assessing authorities exercise quasi

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

5. According to the learned Attorney-General the assessment proceedings are not of a quasi-judicial nature nor is the Assessing authority a quasi- judicial authority. We are unable to agree. It is apparent from the judgment referred to above and numerous other decisions of this Court delivered in respect of various taxation laws that the Assessing authorities exercise quasi

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

5. It is the contention of Sri K.V.Aravind, learned Advocate for the revenue that Tribunal erred in holding that assessing Officer sought to initiate the re-assessment proceedings by mere change of opinion, without considering the fact that the 7 expenditure related to onsite development of computer software and same had not been examined in the original assessment

Sunil Kumar Ahuja vs. Assistant Commissioner of Income Tax

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

5. that additions additions had Private Limi which had m purchase of l ultimate bene o. 97 of 2023 er Section 153A (1)(b) of the 4,292/-. Aggrieved against the re the Commissioner of Incom s order dated 31.03.2022 dismis d the appeal before the ITAT, 2022. Now the Revenue is in ap Learned counsel for the Revenu holding

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

The appeals are dismissed

Section 153 A (1) will have to be mandatorily issued to the • person searched requiring him to file returns for six AYs immediately preceding the previous year relevant ITA 634/2015 & Connected matters Page 5 of7 to the AY in which the search talces place, ii. Assessments and reassessments

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

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

5 of 10 live link between the material coming to the notice of the Income Tax Officer and the formation of his belief that there has been escapement of the income of the assessee from assessment in the particular year because of his failure to disclose fully and truly all material facts. The powers of the Income Tax Officer

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

The appeals are allowed

Bench: N.TUKARAMJI,UJJAL BHUYAN

Section 153- C of the Act as if the reassessment is challenged based on HCJ & NTRJ I.T.T.A.Nos.259 of 2022 & batch 4 the material recovered at the time of search of a group concern? 3. Whether the Tribunal failed to appreciate that the reasoning given in appeal of Indur Developers and Agencies Private Limited (ITA No.672/Hyd/2020 dated 21.3.2022) formed

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

The appeals are allowed

Bench: N.TUKARAMJI,UJJAL BHUYAN

Section 153- C of the Act as if the reassessment is challenged based on HCJ & NTRJ I.T.T.A.Nos.259 of 2022 & batch 4 the material recovered at the time of search of a group concern? 3. Whether the Tribunal failed to appreciate that the reasoning given in appeal of Indur Developers and Agencies Private Limited (ITA No.672/Hyd/2020 dated 21.3.2022) formed

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

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

The appeals stand dismissed

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

5. However, we have gone through the order of the CIT(A) as well as the Tribunal. The Tribunal in para 2.5 observed as under:- “2.5. We have considered the arguments advanced by the parties in view of orders of the lower authorities and the decisions relied upon by the Ld. AR. The proviso to sub-section (2A) to section

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

Appeal is dismissed

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

reassess' to completed assessment proceedings. vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record

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

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

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

5. The Assessing Officer by an order dated 21.11.2006 for all the years under dispute held that the assessee was required to remit tax at the rate of 48% for the financial years upto 2001-2002 (Assessment 7 years 2002-03) and at the rate of 40% for the subsequent years on the ground that the consultant had a permanent

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

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 land

PRL COMMR OF INCOME TAX-7, HYDERABAD vs. M/S SRI VENKATESWARA PADMAVATHI COMPAY, KHAMMAM DIST

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

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 land