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73 results for “bogus purchases”+ Section 12clear

Sorted by relevance

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Key Topics

Section 153A80Section 143(3)68Addition to Income53Section 13245Section 143(2)36Section 142(1)26Section 14823Section 12722Section 147

SMT. L SUDHA BALA, L/R OF LATE SRI L.NARSA REDDY,GUNTUR vs. THE DCIT, SPECIAL RANGE GUNTUR, GUNTUR

In the result, the appeals of the assessee are dismissed

ITA 261/VIZ/2012[1985-86]Status: DisposedITAT Visakhapatnam07 Dec 2018AY 1985-86

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.260 & 261/Viz/2012 (धििाारण िर्ा/ Assessment Years :1984-85 & 1985-86 Respectively) L.Sudha Bala Vs. Dy.Commissioner Of L/R Of Late Sri L Narasa Reddy Income Tax Prop.Sri Venkateswara Agro Chemicals Special Range Industries Guntur 2-14-101, Syamala Nagar 2Nd Lane, Guntur [Pan : Acgpl2351P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri C.Subrahmanyam, ARFor Respondent: Smt. Suman Malik, DR
Section 143(3)Section 147Section 148Section 40A(3)

section 148, the previous under assessment stands set aside and the AO has not only the jurisdiction but is also duty bound to levy tax on the entire income which has escaped assessment during the course of original assessment. In the case of CWT vs. D.R. Wadera Lit-I of HansrajWadera, reported in (2000) 163 CTR 251 (Delhi), the Honourable

Showing 1–20 of 73 · Page 1 of 4

21
Search & Seizure21
Disallowance17
Bogus Purchases10

SMT. L SUDHA BALA, L/R OF LATE SRI L.NARSA REDDY,GUNTUR vs. THE DCIT, SPECIAL RANGE GUNTUR, GUNTUR

In the result, the appeals of the assessee are dismissed

ITA 260/VIZ/2012[1984-85]Status: DisposedITAT Visakhapatnam07 Dec 2018AY 1984-85

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.260 & 261/Viz/2012 (धििाारण िर्ा/ Assessment Years :1984-85 & 1985-86 Respectively) L.Sudha Bala Vs. Dy.Commissioner Of L/R Of Late Sri L Narasa Reddy Income Tax Prop.Sri Venkateswara Agro Chemicals Special Range Industries Guntur 2-14-101, Syamala Nagar 2Nd Lane, Guntur [Pan : Acgpl2351P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri C.Subrahmanyam, ARFor Respondent: Smt. Suman Malik, DR
Section 143(3)Section 147Section 148Section 40A(3)

section 148, the previous under assessment stands set aside and the AO has not only the jurisdiction but is also duty bound to levy tax on the entire income which has escaped assessment during the course of original assessment. In the case of CWT vs. D.R. Wadera Lit-I of HansrajWadera, reported in (2000) 163 CTR 251 (Delhi), the Honourable

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 144/VIZ/2025[2012-13]Status: DisposedITAT Visakhapatnam13 May 2025AY 2012-13

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased the capital asset

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 140/VIZ/2025[2008-09]Status: DisposedITAT Visakhapatnam13 May 2025AY 2008-09

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased the capital asset

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 141/VIZ/2025[2009-10]Status: DisposedITAT Visakhapatnam13 May 2025AY 2009-10

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased the capital asset

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 142/VIZ/2025[2010-11]Status: DisposedITAT Visakhapatnam13 May 2025AY 2010-11

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased the capital asset

MAA MAHAMAYA INDUSTRIES LIMITED,CHHATTISGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 143/VIZ/2025[2011-12]Status: DisposedITAT Visakhapatnam13 May 2025AY 2011-12

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Shri MV Prasad, CAFor Respondent: Dr Satyasai Rath, CIT(DR)
Section 127Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 245C(1)Section 245D

12, 13, 21 and 22 are similar in nature with regard to ‘non-purchase of capital asset’. The Ld. DR submitted that the Ld. AO has rightly disallowed the proportionate share of interest U/s.36(1)(iii) of the Act amounting to Rs. 13,98,37,651/- wherein the assessee itself has admitted that it has not purchased the capital asset

ACIT, CIRCLE-1(1),, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 36/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2016-17

Bench: Us:

For Appellant: None
Section 131Section 147

Section 68 of the Act. 8. As a consequence of treating the aforesaid loan transaction as bogus, the A.O disallowed the assessee’s claim for deduction of interest of Rs. 11,83,562/- that the assessee company had claimed to have paid on the same. 9. Also, the A.O. going by the admission of Shri. Rajesh G. Mehta (supra

THE INCOME TAX OFFICER, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 35/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2014-15

Bench: Us:

For Appellant: None
Section 131Section 147

Section 68 of the Act. 8. As a consequence of treating the aforesaid loan transaction as bogus, the A.O disallowed the assessee’s claim for deduction of interest of Rs. 11,83,562/- that the assessee company had claimed to have paid on the same. 9. Also, the A.O. going by the admission of Shri. Rajesh G. Mehta (supra

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 38/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2017-18

Bench: Us:

For Appellant: None
Section 131Section 147

Section 68 of the Act. 8. As a consequence of treating the aforesaid loan transaction as bogus, the A.O disallowed the assessee’s claim for deduction of interest of Rs. 11,83,562/- that the assessee company had claimed to have paid on the same. 9. Also, the A.O. going by the admission of Shri. Rajesh G. Mehta (supra

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 37/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2017-18

Bench: Us:

For Appellant: None
Section 131Section 147

Section 68 of the Act. 8. As a consequence of treating the aforesaid loan transaction as bogus, the A.O disallowed the assessee’s claim for deduction of interest of Rs. 11,83,562/- that the assessee company had claimed to have paid on the same. 9. Also, the A.O. going by the admission of Shri. Rajesh G. Mehta (supra

ACIT, CIRCLE-1(1), VIJAYAWADA, VIJAYAWADA vs. VEDMUTHA ELECTRICALS INDIA PRIVATE LIMITED, VIJAYAWADA

In the result, all the captioned appeals filed by the Revenue are allowed for statistical purposes

ITA 34/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam30 Jun 2025AY 2013-14

Bench: Us:

For Appellant: None
Section 131Section 147

Section 68 of the Act. 8. As a consequence of treating the aforesaid loan transaction as bogus, the A.O disallowed the assessee’s claim for deduction of interest of Rs. 11,83,562/- that the assessee company had claimed to have paid on the same. 9. Also, the A.O. going by the admission of Shri. Rajesh G. Mehta (supra

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), VISAKHAPATNAM vs. DODDI ROOPA, VISAKHAPATNAM

In the result, the appeal filed by the revenue is dismissed in terms of our aforesaid observations

ITA 413/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2019-20

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.413/Viz/2024 (िनधा"रण वष"/Assessment Year: 2019-20) Deputy Commissioner Of Vs. Smt. Doddi Roopa, Income Tax, Visakhapatnam. Circle-3(1), Visakhapatnam. Pan: Atfpr7237N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 15/10/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement:

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Shri Badicala Yadagiri
Section 131Section 133(6)Section 147Section 148Section 148A

bogus. Also, the CIT(A) observed that the provisions of section 194Q had been made applicable from 01/07/2021, i.e., deduction of tax at source on the payments made against the purchases, and the same did not apply to the case of the assessee for the year under consideration, i.e., AY 2019-20. 9. Apart from that, we find that

INCOME TAX OFFICER, INCOME TAX DEPARTMENT, VISAKHAPATNAM vs. QUALITY STEEL SHOPPE PRIVATE LIMITED, VISAKHAPATNAM

In the result, the Cross Objection No

ITA 454/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam14 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.454/Viz/2024 ("नधा"रण वष"/Assessment Year: 2018-19) Income Tax Officer, Vs. Quality Steel Shoppe Ward-2(1), Private Limited, Visakhapatnam. Visakhapatnam. Pan: Aaacq1115D (Appellant) (Respondent) C.O. No. 18/Viz/2024 (In आ.अपी.सं /454/Viz/2024) ("नधा"रण वष"/Assessment Year: 2018-19)

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Sri Badicala Yadagiri
Section 144Section 144BSection 147Section 148Section 148ASection 151A

bogus purchases, the assessee company vide its reply dated 08/01/2024 rebutted the same. It was submitted by the assessee company that during the Financial Year 2017-18, M/s. Steel Exchange India Limited (SEIL) had sold 998.870 mts of MS bars to M/s. Hero Wiretex Private Limited but had not taken the delivery of inventory due to non-payment of sale

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 174/VIZ/2023[2014-15]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

12 months from the end of the FY 2019-20 relevant to the said last Panchnama, which has since been extended to 30.09.2021 in accordance with the notification issued under TOLA, 2020. As the assessments were not concluded by the said date, it is submitted that the assessments have become time barred and bad in law.” 36. We have considered

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 173/VIZ/2023[2013-14]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

12 months from the end of the FY 2019-20 relevant to the said last Panchnama, which has since been extended to 30.09.2021 in accordance with the notification issued under TOLA, 2020. As the assessments were not concluded by the said date, it is submitted that the assessments have become time barred and bad in law.” 36. We have considered

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 172/VIZ/2023[2012-13]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

12 months from the end of the FY 2019-20 relevant to the said last Panchnama, which has since been extended to 30.09.2021 in accordance with the notification issued under TOLA, 2020. As the assessments were not concluded by the said date, it is submitted that the assessments have become time barred and bad in law.” 36. We have considered

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 179/VIZ/2023[2019-20]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

12 months from the end of the FY 2019-20 relevant to the said last Panchnama, which has since been extended to 30.09.2021 in accordance with the notification issued under TOLA, 2020. As the assessments were not concluded by the said date, it is submitted that the assessments have become time barred and bad in law.” 36. We have considered

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 180/VIZ/2023[2020-21]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

12 months from the end of the FY 2019-20 relevant to the said last Panchnama, which has since been extended to 30.09.2021 in accordance with the notification issued under TOLA, 2020. As the assessments were not concluded by the said date, it is submitted that the assessments have become time barred and bad in law.” 36. We have considered

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 178/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

12 months from the end of the FY 2019-20 relevant to the said last Panchnama, which has since been extended to 30.09.2021 in accordance with the notification issued under TOLA, 2020. As the assessments were not concluded by the said date, it is submitted that the assessments have become time barred and bad in law.” 36. We have considered