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1 - 10 of 21 (0.35 seconds)Section 148 in The Income Tax Act, 1961 [Entire Act]
M/S Haryana Acrylic Manufacturing ... vs The Commissioner Of Income-Tax Iv & ... on 3 November, 2008
such assessment year by reason of failure on the part of the
assessee to disclose fully and truly all material facts
necessary for his assessment for that assessment year. The
relevant observations of the Hon'ble Delhi High Court in the
case of Haryana Acrylic Manufacturing Co. vs., CIT (supra)
are as under :
Sai University Act, 2018
Section 153 in The Income Tax Act, 1961 [Entire Act]
Rose Serviced Apartments Pvt. Ltd. & ... vs Dy. Commissioner Of Income Tax on 25 January, 2011
12.Rose Serviced Apartments Pvt. Ltd. v. Deputy
Commissioner of Income-tax [2012] 348 ITR 452 (Del)
(HC).
Mihir Textiles Ltd. vs Commissioner Of Income-Tax on 5 October, 1995
13. Mihir Textiles Ltd. v. Joint Commissioner of Income-tax
[2012] 347 ITR 546 (Guj) (HC).
M/S. Sahney Steel & Press Works Ltd. ... vs Commissioner Of Income Tax.Andhra ... on 19 September, 1997
Therefore, according to the A.O. such subsidy received by
the assessee company is on account of revenue being given
for business purposes and, therefore, the same is taxable in
view of the principles laid down by the Hon'ble Apex Court
in the case of M/s. Sahney Steel and Press Works Ltd., vs.,
CIT 228 ITR 253 (SC). He further noted that assessee
company has revised its return of income under section 148
for the impugned assessment year and has not submitted
any documentary evidence in support of its revised return of
income. Relying on the decision of Hon'ble Supreme Court
in the case of CIT vs., M/s. Sun Engineering Works Pvt.
Ltd., reported in [1992] 1 SCR 732 wherein it has been held
that assessee cannot take advantage of reopening for review
of concluded items, the A.O. rejected the revised return of
income filed by the assessee. Thus, the A.O. determined the
total income of assessee at Rs.5,43,49,450/- by adding the
amount of Rs.1.07 crores to the returned income of
Rs.4,36,49,450/-.
Commnr. Of Income Tax, Delhi vs M/S. Kelvinator Of India Ltd on 18 January, 2010
6.3. We find the Hon'ble Supreme Court in the case of
CIT vs., Kelvinator of India Ltd., [2010] 320 ITR 561 (SC)
has held that after 1st April, 1989 the A.O. has power to
reopen the assessment provided there is tangible material to
come to the conclusion that there was escapement of
income from assessment. The reason must have a link for
the formation of the belief. The relevant observation of the
Hon'ble Supreme Court reads as under :
Bharti Infratel Ltd., New Delhi vs Dcit, New Delhi on 21 April, 2017
6.4. We find the Hon'ble Delhi High Court in the case
of Bharti Infratel Ltd., vs., DCIT & Another [2019] 411 ITR
403 (Del.) has held that proviso to Section 147 of the I.T.
Act, 1961 clearly states that no action under section 147
will be taken by the A.O. unless any income chargeable to
tax has escaped assessment by reason of failure on the part
of the assessee to disclose fully and truly all material facts
31
ITA.No.6022/Del./2016 M/s. Bhartiya
Samruddhi Finance Ltd., New Delhi.