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1 - 10 of 40 (0.44 seconds)Section 153C in The Income Tax Act, 1961 [Entire Act]
Section 153A in The Income Tax Act, 1961 [Entire Act]
Dcit Central (I), Bhopal vs M/S. K L Sharma & Sunita Maheshwari, ... on 11 February, 2022
Following the above principle and considering the fact that the Hon'ble Supreme
Court has dismissed the SLP filed by the Revenue in the case of DCIT vs. Sunil
Kumar Sharma (supra), therefore, we follow the decision of the Hon'ble Karnataka
High Court in the case of DCIT vs. Sunil Kumar Sharma (supra) and hold that the
satisfaction note is required to be recorded u/s 153C for each assessment year and a
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ITA Nos.1262 & 1269/PUN/2024 & Ors
consolidated satisfaction note recorded for different assessment years would vitiate
the entire assessment proceedings. Since in the instant case a consolidated
satisfaction note has been prepared for assessment years 2012-13 to 2018-19,
therefore, such consolidated satisfaction note being not in accordance with law, the
entire assessment proceedings are liable to be quashed. We hold and direct
accordingly.
Section 132 in The Income Tax Act, 1961 [Entire Act]
Section 127 in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
National Payments Corporation Of ... vs Dcit (E) 2(1), Mumbai on 6 July, 2020
62. So far as the decision of the Hon'ble Delhi High Court in the case of Indian
National Congress vs. DCIT (supra) relied on by Ld. DR is concerned, we find no
doubt there is a favourable decision in favour of the Revenue on the issue of
combined satisfaction. However, it has been held in various decisions that when
there are two views possible on an issue and there is no decision of the
jurisdictional High Court on that issue, then the view which is favourable to the
assessee has to be adopted.
Income Tax Settlement Commission vs Agson Global Pvt Ltd on 23 November, 2022
53. Referring to the decision of the Hon'ble Supreme Court in the case of
Income-tax Settlement Commission vs. Agson Global (P.) Ltd. (2022) 145
taxmann.com 606 (SC), the Ld. DR submitted that the Hon'ble Supreme Court has
dismissed the SLP filed against order of High Court where it was held that
Settlement Commission does not have power to direct a special audit under section
142(2A) in course of settlement proceedings under Chapter XIX-A.