The Commissioner of Income Tax vs. M/s Kaveri Bar AND Restaurant,

Bench: ABHINAND KUMAR SHAVILI,V RAMASUBRAMANIAN

147 of the Act as appears at page 140 of the writ petition are as follows : “Reasons for the belief that Income has escaped assessment 2 “For the Financial year 2009-10 relevant to the assessment year 2010-11, the assessee had debited a sum of Rs. 21,09,18,000/- to the P & L Account under the head “interest

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

reassessment proceedings under Section 147 of the Act by the Assessing Officer was challenged by the assessee before the Assessing Officer, Appellate Commissioner 13 as well as Tribunal. Perusal of the original records would indicate that Assessing Officer for the reasons recorded in the order sheet dated 05.09.2006 to reopen the concluded assessment for the year 2003- 04. It reads

The Commissioner of Income Tax - III, vs. M/s. Suven Pharmaceuticals Limited,

Appeals are dismissed

147 [or section 153A] on the  amount by which the tax on the total income  determined on the basis of the reassessment  or recomputation exceeds the tax on the total  income determined [under sub­section (1) of  section 143 or] on the basis of the regular  assessment aforesaid. (4) Where,   as   a   result   of   an   order   under  section 154 or section

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

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

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

reassessment on the dictates/directions of the superior authority. The ITAT in its judgment has arrived to the finding considering various material available on record that the AO has passed the order against the assessee on the dictates of his superiors. 56. Learned counsel for the Revenue though argued that since the matter regarding the Jain dairy was pending before

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/directions of the superior authority. The ITAT in its judgment has arrived to the finding considering various material available on record that the AO has passed the order against the assessee on the dictates of his superiors. 56. Learned counsel for the Revenue though argued that since the matter regarding the Jain dairy was pending before

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

reassessment on the dictates/directions of the superior authority. The ITAT in its judgment has arrived to the finding considering various material available on record that the AO has passed the order against the assessee on the dictates of his superiors. 56. Learned counsel for the Revenue though argued that since the matter regarding the Jain dairy was pending before

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

reassessment on the dictates/directions of the superior authority. The ITAT in its judgment has arrived to the finding considering various material available on record that the AO has passed the order against the assessee on the dictates of his superiors. 56. Learned counsel for the Revenue though argued that since the matter regarding the Jain dairy was pending before

The Commissioner of Income Tax-IV vs. M/s. Meghadoot Drillers,

reassessment or recomputation under Section 147, the Income Tax Officer shall serve on the assessee a notice containing all or any of the requirements which may be included in a notice under Sub-section (2) of Section 139; and the provisions of this Act shall, so far as may be, apply accordingly as if the notice were a notice issued

The Director of Income Tax, (Exemptions) vs. Royal Education Society

In the result, the appeal is disposed of

Bench: ANIS,SANJAY KUMAR

u/s 148 of the Act on the facts and circumstances of the case? (3) Whether the Tribunal is justified in law in holding that the appellant is not entitled to make additional claim of loss incurred of Rs.8,28,65,052/- in the re- assessment proceedings under section 147 of the Act on the facts and circumstances of the case

Commissioner of Income Tax-VI vs. Shri Prem Singh

The appeals are dismissed

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 10Th May, 2022. Appearance:- Ms. Chandrani Das, Adv. Ms. Riti Basu, Adv.

147, read with Section 143(3), were put to challenge by the appellants before the Commissioner of Income Tax (Appeals) – Central II, Kolkata [CIT(A)] and all the appeals were dismissed. Challenging the same the assessees preferred appeals before the Tribunal. The Tribunal after considering the factual position noted that before the CIT(A) the assessee had raised the three

Prl. Commissioner of Income Tax-3 vs. M/s. Spectra Shares AND Scripes Pvt. Ltd.,

The appeals are dismissed

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 10Th May, 2022. Appearance:- Ms. Chandrani Das, Adv. Ms. Riti Basu, Adv.

147, read with Section 143(3), were put to challenge by the appellants before the Commissioner of Income Tax (Appeals) – Central II, Kolkata [CIT(A)] and all the appeals were dismissed. Challenging the same the assessees preferred appeals before the Tribunal. The Tribunal after considering the factual position noted that before the CIT(A) the assessee had raised the three

Rachit V Shah vs. The Commissioner of Income Tax-7

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

147) REPLY 148A(C) 08.06.2022 (ANNEXURE P-7 PAGE 148 TO 170) Extended period by which notice u/s 148 could be issued 08.06.2022 (08.06.2022 plus zero day) 148A(D) ORDER & 148 NOTICE UNDER NEW REGIME 26.07.2022 & 28.07.2022(ANNEXURE P-8 & P-9 PAGE 171 to 181 & 182/183) TIME BARRED OUTSIDE 08.06.2022 STATUS TIME BARRED AS PER ILLUSTRATION GIVEN IN RAJEEV

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

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

u/s 80-lB of the Act in respect of any unit though entire profits were taken as eligible for such deduction; (b) The assessee‟s P & L account stated that unit-wise sale was allocated in the ratio of production cost and clearance made by each unit and further, in the Notes that various expenses have been allocated

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

The appeals stand dismissed

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

u/s 254 is received by the chief commissioner or commissioner. After amendment of this sub section with fact from 01.06.2001 this time limit has been reduced to 1 year. Thus in the present case the time limit for passing the assessment order before the AO was upto 31.03.2001. The assessment order however has been passed on 28.03.2002 i.e. much after

The Commissioner of Income Tax -III vs. Sri T.C. Reddy

The appeal stands dismissed

u/s 271(1)(c) r.w 274 of the Income-tax Act for concealment and furnishing of inaccurate particulars are initiated separately. (iv) The assessee has booked various expenses of contractual nature, vide order sheet entry dated 29.12.2009, the assessee was asked to show cause why the same should not disallowed u/s40a(ia). In response thereto the assessee has only filed

The Commissioner of Income Tax-IV vs. Moschip Semiconductor Technology Ltd.,

The appeal stands dismissed

Bench: GODA RAGHURAM,M.S.RAMACHANDRA RAO

u/s 12AA of the Act, hence its application is hereby rejected.” (3 of 11) [ITA-163/2012] 5. However, counsel for the respondent contended that the Commissioner itself in the order which came to be passed subsequently observed as stated hereinabove. 6. He has also relied upon the decision in case of CIT vs. Vijay Vargiya Vani Charitable Trust reported

Commissioner of Income Tax, vs. M/S Foods Fats and Fertilisers Limited,

The appeals stand dismissed

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

147 was bared by limitation and therefore the proceedings are void abinitio. 2.3 The Submissions that the notice was not served is also not acceptable because it is an admitted fact that the notice was served on the business premises of the assessee and therefore it is not acceptable that it was not in the knowledge of the appellant