only ground upon
which the action was taken by the Commissioner under section 33B was that
the Income-tax Officer did not apply his mind ... passed by the Income-tax
Officer which can be revised under section 338.
Section 338 contemplates a notice to the assessee. In response
assessment order dated July 15, 2022 under section 143(3) read with
section 144C(13) read with section 1448 of the Act passed ... under Section 143(3) read with Sections 144C(13) and 144B of
the Act, having been passed beyond the time limitation prescribed under
Section
company on 17.10.2014. A reference was
made to sub section (1) of section 153C, which provides that the
assessment or reassessment of income ... assessment year or years).
The careful and conjoint reading of Section 153A(1) and Section 153D leave
no room for doubt that approval with respect
company on 17.10.2014. A reference was
made to sub section (1) of section 153C, which provides that the
assessment or reassessment of income ... assessment year or years).
The careful and conjoint reading of Section 153A(1) and Section 153D leave
no room for doubt that approval with respect
valid
services of notice u/s 148 and u/s 142(1) .
ITA 376/CHD/2014 &
ITA 338/CHD/2017 ... this section is deeming provisions
regarding concealment of income. The section not only covered
ITA 376/CHD/2014 &
ITA 338/CHD/2017
valid
services of notice u/s 148 and u/s 142(1) .
ITA 376/CHD/2014 &
ITA 338/CHD/2017 ... this section is deeming provisions
regarding concealment of income. The section not only covered
ITA 376/CHD/2014 &
ITA 338/CHD/2017
words of the section 338 of 1922 Act enable the Commissioner
to call for and examine the record of any proceeding under ... prejudicial to the interests of the revenue.
Therefore, the Commissioner under section 338 of 1922 Act has
ample jurisdiction to cancel the assessment
filed u/s 153A of the Act in
comparison to return filed u/s 139 (1) and therefore invoking
expl. 1 of section ... returned income under section
139 for purpose of imposition of penalty under section 271 (1)
(c)...........................
...............where returned income filed under section 153A is accepted
that where the person fails to satisfy the
conditions contained in sub-section (2) in any previous year,
the option shall become invalid in respect ... business of any such undertaking as is referred to in section
338, in the circumstances and within the period specified in
the said section
2025
Akry Organics Pvt.Ltd.,
precedes a valid revised return under section 139(5) )--is a
curable procedural defect, not a forfeiture of the underlying ... income. Thus,
provisions of section 10 , section 104 , section 124 , section
324B, section 33AB, section 33ABA, section 35D, section 338,
section 4448, section 44DA, section
