ITA Nos.45, 46, 47, 48/Bang/2020 and ITA No.205/Bang/2022
Parties Involved
Facts Summary
The assessee, Shri. D. K. Shivakumar, filed returns of income for Assessment Years 2006-07 to 2010-11. Searches were conducted in related cases, and incriminating materials indicating undisclosed income were seized. The Assessing Officer (AO) issued notices under section 148 and completed assessments under section 147. The assessee challenged these orders, arguing that the assessments should have been initiated under section 153C instead of section 147. The Commissioner of Income-tax (Appeals) (CIT(A)) allowed the assessee's appeal, holding that the assessments under section 147 were bad in law. The Revenue appealed to the Income Tax Appellate Tribunal (ITAT).…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the AO was correct in assuming jurisdiction under section 147 of the Act and issuing notice under section 148 of the Act.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
4 precedents cited in this judgement.
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