1. Leader v. Duffey

DCIT, Mumbai vs. J Kumar Infraprojects Limited, Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

…herance to the earlier rejoinder, The Asessee submits how the case laws relied (which are not dealt in the rejoinder) on by the Department are not applicable to the present facts of the case: 1. Leader v. Duffey (1888) LR 13 App Cas 294 2. CIT v. Sodra Devi 1957 INSC 50 22 J Kumar Infraprojects Ltd. 3. New Nobel Education Society v. CCIT 2022 INSC 1111 Comments: The Department has relied on the above case laws to interpret the statue. It is not doubted that the words “and” and “or” have separate significance. The Department’s interpretation of section 282A of the Act is misplaced. According to the Departmen…

DCIT CC 5-1, Mumbai vs. J Kumar Infraprojects Limited, Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

…herance to the earlier rejoinder, The Asessee submits how the case laws relied (which are not dealt in the rejoinder) on by the Department are not applicable to the present facts of the case: 1. Leader v. Duffey (1888) LR 13 App Cas 294 2. CIT v. Sodra Devi 1957 INSC 50 22 J Kumar Infraprojects Ltd. 3. New Nobel Education Society v. CCIT 2022 INSC 1111 Comments: The Department has relied on the above case laws to interpret the statue. It is not doubted that the words “and” and “or” have separate significance. The Department’s interpretation of section 282A of the Act is misplaced. According to the Departmen…

DCIT CC 5 1 Mumbai, Mumbai vs. J Kumar Infraprojects Ltd, Mumbai

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

…rtherance to the earlier rejoinder, The Asessee submits how the case laws relied (which are not dealt in the rejoinder) on by the Department are not applicable to the present facts of the case: 1. Leader v. Duffey (1888) LR 13 App Cas 294 2. CIT v. Sodra Devi 1957 INSC 50 22 J Kumar Infraprojects Ltd. 3. New Nobel Education Society v. CCIT 2022 INSC 1111 Comments: The Department has relied on the above case laws to interpret the statue. It is not doubted that the words “and” and “or” have separate significance. The Department’s interpretation of section 282A of the Act is misplaced. According to the Department on…

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

…herance to the earlier rejoinder, The Asessee submits how the case laws relied (which are not dealt in the rejoinder) on by the Department are not applicable to the present facts of the case: 1. Leader v. Duffey (1888) LR 13 App Cas 294 2. CIT v. Sodra Devi 1957 INSC 50 22 J Kumar Infraprojects Ltd. 3. New Nobel Education Society v. CCIT 2022 INSC 1111 Comments: The Department has relied on the above case laws to interpret the statue. It is not doubted that the words “and” and “or” have separate significance. The Department’s interpretation of section 282A of the Act is misplaced. According to the Departmen…

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

…herance to the earlier rejoinder, The Asessee submits how the case laws relied (which are not dealt in the rejoinder) on by the Department are not applicable to the present facts of the case: 1. Leader v. Duffey (1888) LR 13 App Cas 294 2. CIT v. Sodra Devi 1957 INSC 50 22 J Kumar Infraprojects Ltd. 3. New Nobel Education Society v. CCIT 2022 INSC 1111 Comments: The Department has relied on the above case laws to interpret the statue. It is not doubted that the words “and” and “or” have separate significance. The Department’s interpretation of section 282A of the Act is misplaced. According to the Departmen…

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

…herance to the earlier rejoinder, The Asessee submits how the case laws relied (which are not dealt in the rejoinder) on by the Department are not applicable to the present facts of the case: 1. Leader v. Duffey (1888) LR 13 App Cas 294 2. CIT v. Sodra Devi 1957 INSC 50 22 J Kumar Infraprojects Ltd. 3. New Nobel Education Society v. CCIT 2022 INSC 1111 Comments: The Department has relied on the above case laws to interpret the statue. It is not doubted that the words “and” and “or” have separate significance. The Department’s interpretation of section 282A of the Act is misplaced. According to the Departmen…

J Kumar Infraprojects Limited, Mumbai vs. The Dy. Commissioner of Income Tax Central Circle -5(1), Mumbai

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

…rtherance to the earlier rejoinder, The Asessee submits how the case laws relied (which are not dealt in the rejoinder) on by the Department are not applicable to the present facts of the case: 1. Leader v. Duffey (1888) LR 13 App Cas 294 2. CIT v. Sodra Devi 1957 INSC 50 22 J Kumar Infraprojects Ltd. 3. New Nobel Education Society v. CCIT 2022 INSC 1111 Comments: The Department has relied on the above case laws to interpret the statue. It is not doubted that the words “and” and “or” have separate significance. The Department’s interpretation of section 282A of the Act is misplaced. According to the Department on…