Principal Commissioner of Income Tax-2 vs. M/s.Viskha Container Terminal Private Limited

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

reassess the income, all the consequent proceedings were null and void and it was not a case of irregularity. Therefore, Section 292B of the Act had no application. 16. When we apply the ratio of aforesaid cases to the facts of this case, the irresistible conclusion would be provisions of Section 292B of the Act are not applicable in such

Sunil Kumar Ahuja vs. Assistant Commissioner of Income Tax

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

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 that no search was co hereas warrants of authorization It was incorrect in holding that A of the Act as there was no incr interpretation made under

Commissioner of Income Tax-I vs. M/s. BDR Projects Pvt. Ltd.

292 (AP) and Kerala High Court in Sivaramakrishnan v. State of Kerala 1995 (1) ILR 92 (Ker) . (iii) Section 28 (11) would be applicable only in respect of short-levy or non-levy or erroneous refund arising on or after 8th April 2011. It is submitted that the new Section 28 substitutes the previous Section 28 of the Act with

PR COMMR OF INCOME TAX-2, HYDERABAD vs. K RAVINDER REDDY, HYDERABAD

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

reassessment proceedings. The assessees resisted the move to assess them, contending that they were not subjected to income tax laws of India as they had no permanent establishment. The AO by order dated 31.12.2008 held that the appellant has a fixed place PE and DAPE in India. Further, the AO also deemed 10% of the value of supplies made