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1 - 9 of 9 (0.22 seconds)Section 148 in The Income Tax Act, 1961 [Entire Act]
Section 147 in The Income Tax Act, 1961 [Entire Act]
Section 44AD in The Income Tax Act, 1961 [Entire Act]
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).
Section 271 in The Income Tax Act, 1961 [Entire Act]
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).
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).
Section 92E in The Income Tax Act, 1961 [Entire Act]
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