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Navratna Organisers & Developers Pvt. ... vs Assessee on 27 August, 2014 cites

Signature Hotels (P) Ltd. vs Income Tax Officer-Ward 8(4) & Anr. on 21 July, 2011

5. Assessee has challenged the re-opening u/s. 147,148 of the Act. Before us, the ld. A.R. submitted that the notice u/s. 148 was issued beyond 4 years and the A.O was not having any new material on the basis of which he had proceeded for re-assessment. He further submitted that A.O had examined the material and therefore re-opening was on account of change of opinion and it was not permissible in law. He placed reliance on the decision of Bombay Tribunal in the case of H.V Transmission Ltd. vs. ITO ITA NO. 2230/Mum/2010 order dated 07.10.2011, Signature Hotels P. Ltd vs. ITO (2011) 338 ITR 51 (Del) decision of Delhi High Court in the case of CIT vs. Atul Jain & Others (2008) 299 ITR 383, and also the decision in the case of CIT vs. Kelvinator of India Ltd (2010) 320 ITR 561 (SC).
Delhi High Court Cites 19 - Cited by 224 - S Khanna - Full Document

The Commissioner Of Income Tax vs Shri Atul Jain [Along With Ita No. 1385 Of ... on 23 May, 2007

5. Assessee has challenged the re-opening u/s. 147,148 of the Act. Before us, the ld. A.R. submitted that the notice u/s. 148 was issued beyond 4 years and the A.O was not having any new material on the basis of which he had proceeded for re-assessment. He further submitted that A.O had examined the material and therefore re-opening was on account of change of opinion and it was not permissible in law. He placed reliance on the decision of Bombay Tribunal in the case of H.V Transmission Ltd. vs. ITO ITA NO. 2230/Mum/2010 order dated 07.10.2011, Signature Hotels P. Ltd vs. ITO (2011) 338 ITR 51 (Del) decision of Delhi High Court in the case of CIT vs. Atul Jain & Others (2008) 299 ITR 383, and also the decision in the case of CIT vs. Kelvinator of India Ltd (2010) 320 ITR 561 (SC).
Delhi High Court Cites 9 - Cited by 119 - M B Lokur - Full Document

Commnr. Of Income Tax, Delhi vs M/S. Kelvinator Of India Ltd on 18 January, 2010

5. Assessee has challenged the re-opening u/s. 147,148 of the Act. Before us, the ld. A.R. submitted that the notice u/s. 148 was issued beyond 4 years and the A.O was not having any new material on the basis of which he had proceeded for re-assessment. He further submitted that A.O had examined the material and therefore re-opening was on account of change of opinion and it was not permissible in law. He placed reliance on the decision of Bombay Tribunal in the case of H.V Transmission Ltd. vs. ITO ITA NO. 2230/Mum/2010 order dated 07.10.2011, Signature Hotels P. Ltd vs. ITO (2011) 338 ITR 51 (Del) decision of Delhi High Court in the case of CIT vs. Atul Jain & Others (2008) 299 ITR 383, and also the decision in the case of CIT vs. Kelvinator of India Ltd (2010) 320 ITR 561 (SC).
Supreme Court of India Cites 4 - Cited by 1696 - S H Kapadia - Full Document
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