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1 - 10 of 22 (0.33 seconds)Section 147 in The Income Tax Act, 1961 [Entire Act]
Article 226 in Constitution of India [Constitution]
Section 148 in The Income Tax Act, 1961 [Entire Act]
Gudwil Housing Limited , Bangalore vs Deputy Commissioner Of Income Tax ... on 18 January, 2021
17. We refer to and rely on decision of Hon'ble Karnataka High
Court in case of Gudwill Housing Ltd. Vs. ITO reported in (2014) 45
taxmann.com 144 wherein the Hon'ble High Court observed and
held as under:
S. Narayanappa & Ors vs Commissioner Of Income-Tax, Bangalore on 27 September, 1966
He
also submitted that, it cannot be merely a pretence as held in case
of S. Narayanappa v. CIT reported in [1967] 63 ITR 219 by Hon'ble
Supreme Court.
Income Tax Officer, Income ... vs Nawab Mir Barkat Ali Khan Bahadur on 16 October, 1974
The Ld.AR pointed out that, the expression 'reason to believe'
occurring in section 147 does not mean a purely subjective
satisfaction on the part of the ITO, but the reasons to believe must
have a rational connection or relevant bearing to the formation of
the belief as held in case of ITO/WTO v. Nawab Mir Barkat Ali
Khan Bahadur reported in [1974] 97 ITR 239 by Hon'ble Supreme
Court.
Srinivasa Rao Vaitla, Hyderabad, ... vs Addl. Cit, Range-13, Hyderabad, ... on 10 November, 2017
a) ACIT vs. Shri Srinivas Rao in ITA Nos. 1154 & 1155/Bang/2015 by
order dated 21.02.2018
New Skies Satellites B. V , Haryana vs Dcit Circle 2(2)(2) Int. Taxation , ... on 22 April, 2022
32. The Ld.AO met with the objections raised by the assessee by
way of independent order dated 27.03.2015 placed at pages 40-42
of paper book. Therefore it cannot be held that the Ld.AO did not
follow the principles laid down by Hon'ble Supreme Court in case of
G.K.N. Driveshaft (supra). For sake of reference, the same is
scanned and reproduced herewith.
The Commissioner Of Income Tax, ... vs Pvs Builders & Developers on 24 October, 2016
"5. It is true that Section 158BD states that where the
Assessing Officer is satisfied that any undisclosed income
belongs to any person, other than the person with respect
to whom search was made under Section 132, then the
books of accounts, other documents or assets seized shall
be handed over to the Assessing Officer having jurisdiction
over such other person and that the Assessing Officer shall
proceed under Section 158BC against such other person
and the provisions of these Chapter shall apply
accordingly. This provision by itself, in our opinion, is not
sufficient to hold that the Assessing Officer, on the facts
and in the circumstances, as occurred in the present case,
could not have proceeded against the assessee under
Section 147 by issuing notice under Section 148 of the Act.
This provision fell for consideration of the Delhi High Court
and the Allahabad High Court. The Allahabad High Court
in CIT v. Abhyudaya Builders (P.) Ltd. [2012] 34o ITR
Page 12 of 26
ITA No. 256/Bang/2020
310/20 taxmann.com 851 was considering not only these
provisions but was examining the same in the light of
similar facts, as fall for our consideration in the present
case.