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Infosys Limited vs The Deputy Commissioner Of Income Tax on 17 June, 2019

27. The Division Bench of this Court in the case of Commissioner of Income Tax & another Vs. Hewlett-Packard Globalsoft Pvt. Limited3, while considering the substantial question of law that, Whether on the facts and circumstances of the case, the Tribunal was correct in holding that the reopening of assessment is by mere change of opinion, without appreciating the fact that the expenditure related to on- site development of computer software was not 3 (2016)380 ITR 386 (Kar)
Karnataka High Court Cites 26 - Cited by 0 - S Sujatha - Full Document

M/S. Biocon Limited, Bengaluru vs Commissioner Of Income Tax, Ltu,, ... on 9 June, 2022

17. The issue that arises for consideration is a legal issue that goes to the root of the case. It is the submissions of the Ld.AR that "reason to believe" in the context of section 147 of the Act cannot be based on a mere change of opinion by the Ld.AO. This issue has been considered by Hon'ble Karnataka High Court in case of CIT vs. Hewlett-Packard Globalsoft (P.) Ltd. reported in [2017] 79 taxmann.com 387.
Income Tax Appellate Tribunal - Bangalore Cites 31 - Cited by 2 - Full Document
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