1. S. S. Gadgil v. Lal & Co.

53 ITR 231Supreme Court of India1964#621 most cited

What is 1. S. S. Gadgil v. Lal & Co. authority for?

Income-tax assessment proceedings are administrative in nature, not civil disputes or judicial proceedings between contesting parties. Income-tax authorities act as administrative bodies to estimate income and assess tax, and the proper service of notice within the limitation period is foundational for reassessment jurisdiction.

158

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2002 to 2026.

Also referred to as

S. S. Gadgil v. Lal & Co. · income tax assessment · administrative proceedings · not civil dispute · Section 147 · Section 148 · Section 149 · service of notice · limitation period · reassessment jurisdiction

Sections most often in play

Section 147Section 148Section 143(3)Section 153ASection 142(1)Section 149Section 143(2)Section 150

Issues it is cited on

undisclosed foreign income and assetssection 149(1)(c)section 4(2)section 201(3)section 158basection 150(1)section 150section 150(2)unexplained jewellerysection 18section 70section 33(4)

Judgments citing 1. S. S. Gadgil v. Lal & Co.

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

ITA 2954/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SH. C.N. PRASAD, JUDICIAL MEMBER AND SH. M. BALAGANESH, ACCOUNTANT MEMBER ITA No.2953 & 2954/Del/2024 Assessment Year: 2015-16 & 2016-17 Best Bull Stock Trading ACIT Pvt. Ltd. Central Circle – 18 Vs 6/79, WEA, Padam Singh Delhi Road, Karol Bagh, New Delhi PAN No.AACCB7733N (APPELLANT) (RESPONDENT) Appellant by Sh. Ajay Vohra, Sr. Advocate Sh. Arpit Goyal, Advocate Respondent by Sh. Amit Jain, CIT DR Date of hearing: 12/11/2025 Date of Pronouncement: /01/2026 ORDER PER C.N. PRASAD, JM: These two appeals are filed by the assessee again…

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

ITA 2953/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SH. C.N. PRASAD, JUDICIAL MEMBER AND SH. M. BALAGANESH, ACCOUNTANT MEMBER ITA No.2953 & 2954/Del/2024 Assessment Year: 2015-16 & 2016-17 Best Bull Stock Trading ACIT Pvt. Ltd. Central Circle – 18 Vs 6/79, WEA, Padam Singh Delhi Road, Karol Bagh, New Delhi PAN No.AACCB7733N (APPELLANT) (RESPONDENT) Appellant by Sh. Ajay Vohra, Sr. Advocate Sh. Arpit Goyal, Advocate Respondent by Sh. Amit Jain, CIT DR Date of hearing: 12/11/2025 Date of Pronouncement: /01/2026 ORDER PER C.N. PRASAD, JM: These two appeals are filed by the assessee again…

KALPESH RAVJIBHAI SOJITRA,JASDAN vs. THE INCOME TAX OFFICER, WARD 2(1)(2), RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed, in above terms

ITA 487/RJT/2025[2017-18]Status: DisposedITAT Rajkot08 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrid Hearing) Kalpesh Ravjibhai Sojitra, Vs. The Ito, Prop. Sojitra Petrolium, Bypass Ward-2(1)(2), Circle Atkot Road, Jasdan, Rajkot 360050, Rajkot-( Guj) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqmps8120G (/Appellant) (/Respondent)

For Appellant: Shri Brijesh Parekh, Ld ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 133(6)Section 142(1)Section 147Section 148Section 148ASection 68

…er authority. It is a settled proposition I.T.A No. 487/Rjt/2025 A.Y. 2017-18 6 Kalpesh Ravjibhai Sojitra of law that jurisdiction is not a matter of convenience and for that learned Counsel relied on the following judgements: (i)CIT v. S. S. Gadgil (1964) 53 ITR 231 (SC) (ii).Pannalal Binjraj v. Union of India (1957) 31 ITR 565 (SC) The Hon`ble Supreme Court in the above cases held that a notice issued by an officer who does not possess jurisdiction is void, and such jurisdictional defects cannot be cured. 13. The ld.Counsel also states that Hon`ble Gujarat High Court in the case of Rakesh Agarwal vs. UOI (…

SARVODAYA SAMAJ KALYAN SANSTHAN,JAMUI vs. CPC , BANGALURU

In the result, the appeal of the assessee is allowed

ITA 563/PAT/2024[2018-2019]Status: DisposedITAT Patna26 Nov 2025AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 143Section 143(1)Section 154Section 250

…Ltd. [1956] 29 ITR 661 (SC); Parekh Bros. v. CIT [1984] 150 ITR 105 (Ker)). Also see: Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC). Proceedings under the Act, it may be clarified, are not in the nature of a lis (Gadgil (S.S.) v. Lal & Co. [1964] 53 ITR 321 (SC)). 14. For that the appellant is an accredited institution supported by Government, alternate claim for exemption u/s. 10(23C)(iiiad), the same may be appreciated, is not a new claim, but incidental to its activity of running an educational institution, and on which basis it had been claiming exemption in the past. It is true that equitable co…

DCIT, CIRCLE-4(2), NEW DELHI vs. CDS INFRA PROJECTS LTD., NEW DELHI

In the result, the appeal of Revenue and cross-objection of Assessee are dismissed

ITA 1445/DEL/2023[2012-13]Status: DisposedITAT Delhi24 Nov 2025AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2012-13 Deputy Commissioner Of Income Vs. M/S. Cds Infra Projects Ltd., B-94, Tax, Circle 4(2), Okhla Industrial Area, Phase-Ii, New Delhi. New Delhi-110020 Pan :Aadcc0273D (Appellant) (Respondent)

Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)Section 271(1)(b)

…tries recorded and seized material are not correct and assessee further relied on the following judgments: i). Indian & Eastern Newspaper Society v. CIT 119 ITR 996 (SC); ii) Addl. CIT Vs. Jay Engg. Works Ltd. 113 ITR 389 (Del.); iii) S.S. Gadgil v. Lal & Co. 53 ITR 231 (SC); iv ) Dhakeswari Cotton Mills Ltd. v. CIT 26 ITR 775 (SC); v ) Nokia India (P) Ltd. v. DDIT 59 taxmann.com 212, ITAT Delhi; vi) Hersh Win Chadha v DCIT 135 TTJ 513 ITAT Delhi; vii) GTC Industries Ltd. v. ACIT 65 ITD 380, ITAT Mumbai; ix ) Smt. Kusum Lata Thakral v CIT, 150 ITR 714 P & H High Court; x ) M/s. Meghna Towers Pvt. Ltd. 87 taxmann.…

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

In the result, the appeals of the revenue in ITA No

ITA 710/JPR/2025[2014-15]Status: DisposedITAT Jaipur14 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 139(1)Section 153ASection 153CSection 68Section 69C

…permit the\nauthorities to reopen assessments, which have become final and reassessment of\nwhich had become barred by time before 1-4-1989 when section 150(1) was\namended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal &\nCo. [1964] 53 ITR 231\n\n12. The learned counsel appearing on behalf of the department has made an effort\nto persuade this Court to accept his construction of the provisions of section\n150(1) and (2). It is argued that it is for the specific purpose of assessing income,\nwhich might accrue on the basis of any decision of any Court in any proceeding in\nany other law,…

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

In the result, the appeals of the revenue in ITA No

ITA 709/JPR/2025[2013-14]Status: DisposedITAT Jaipur14 Oct 2025AY 2013-14
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 139(1)Section 153ASection 153CSection 68Section 69C

…permit the\nauthorities to reopen assessments, which have become final and reassessment of\nwhich had become barred by time before 1-4-1989 when section 150(1) was\namended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal &\nCo. [1964] 53 ITR 231\n12. The learned counsel appearing on behalf of the department has made an effort\nto persuade this Court to accept his construction of the provisions of section\n150(1) and (2). It is argued that it is for the specific purpose of assessing income,\nwhich might accrue on the basis of any decision of any Court in any proceeding in\nany other law, t…

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. KARNANI SOLVEX PRIVATE LIMITED, JAIPUR

In the result, the appeals of the revenue in ITA No

ITA 480/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: MS. Alka Gautam, CIT
Section 132(4)Section 153ASection 68

…t permit the authorities to reopen\nassessments, which have become final and reassessment of which had become barred\nby time before 1-4-1989 when section 150(1) was amended. Reliance is placed on the\ndecision of this Court in S.S. Gadgil v. Lal & Co. [1964] 53 ITR 231 .\n\n12. The learned counsel appearing on behalf of the department has made an effort to\npersuade this Court to accept his construction of the provisions of section 150(1) and (2).\nIt is argued that it is for the specific purpose of assessing income, which might accrue on\nthe basis of any decision of any Court in any proceeding in any other law…

SH. HARI PRAKASH GUPTA,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

The appeal stands allowed

ITA 772/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

…o-pen an assessment subject to service of notice within the prescribed period. Therefore, service of notice within limitation was the foun dation of jurisdiction. The same view has been taken by this court in/P. Jani, ITO v. Induprasad Devshanker Bhatt [1969] 72 ITR 595 (SO as also in CIT v. Robert J. Sas [1963] 48 IIR (S.C.) 177. The High Court, in our opinion, went wrong in relying upon the ratio of Banarsi Debi v. ITO [1964] 53 ITR 100 (SC) in disposing of the case in hand. The scheme of the 1961 Act so far as notice for reassessment is concerned is quite different. What used to be contained in section 34 of t…

SH. HARI PRAKASH GUPTA,JAIPUR vs. ITO, WARD-1(2), JAIPUR, JAIPUR

The appeal stands allowed

ITA 771/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11
For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

…o-pen an assessment subject to service of notice within the prescribed period. Therefore, service of notice within limitation was the foun dation of jurisdiction. The same view has been taken by this court in/P. Jani, ITO v. Induprasad Devshanker Bhatt [1969] 72 ITR 595 (SO as also in CIT v. Robert J. Sas [1963] 48 IIR (S.C.) 177. The High Court, in our opinion, went wrong in relying upon the ratio of Banarsi Debi v. ITO [1964] 53 ITR 100 (SC) in disposing of the case in hand. The scheme of the 1961 Act so far as notice for reassessment is concerned is quite different. What used to be contained in section 34 of t…

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 500/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

…not permit the authorities to reopen assessments, which have become final and reassessment of which had become barred by time before 1-4-1989 when section 150(1) was amended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal & Co. [1964] 53 ITR 231 . 12. The learned counsel appearing on behalf of the department has made an effort to persuade this Court to accept his construction of the provisions of section 150(1) and (2). It is argued that it is for the specific purpose of assessing income, which might accrue on the basis of any decision of any Court in any proceeding in any other law, that…

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 497/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Sept 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आंकड़ुठरधारी आइटीएए सं.र@ITA Nos.493, 495 to 498, 500/JP/2025 निर्धारण वर्ष@Assessment Years : 2014-15 to 2016-17, 2018-19 to 2020-21 Mahendra Kumar Goyal चुके Vs. ACIT/DCIT Ward No. 2, Shahpura Road Neem Ka Thana, Sikar Central Circle-03, Jaipur लेखा संख्याल्लेय सं.जीआइआर सं.पान@PAN/GIR No.: ACFPG0306G अपीलार्थी@Appellant प्रत्यार्थी@Respondent निर्धारीती की आर से@ Assessee by : Shri P. C. Parwal, CA राजस्व की आर से@ R

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

…not permit the authorities to reopen assessments, which have become final and reassessment of which had become barred by time before 1-4-1989 when section 150(1) was amended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal & Co. [1964] 53 ITR 231 . 12. The learned counsel appearing on behalf of the department has made an effort to persuade this Court to accept his construction of the provisions of section 150(1) and (2). It is argued that it is for the specific purpose of assessing income, which might accrue on the basis of any decision of any Court in any proceeding in any other law, that…

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 496/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

…not permit the authorities to reopen assessments, which have become final and reassessment of which had become barred by time before 1-4-1989 when section 150(1) was amended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal & Co. [1964] 53 ITR 231 . 12. The learned counsel appearing on behalf of the department has made an effort to persuade this Court to accept his construction of the provisions of section 150(1) and (2). It is argued that it is for the specific purpose of assessing income, which might accrue on the basis of any decision of any Court in any proceeding in any other law, that…

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 493/JPR/2025[2014-15]Status: DisposedITAT Jaipur15 Sept 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

…not permit the authorities to reopen assessments, which have become final and reassessment of which had become barred by time before 1-4-1989 when section 150(1) was amended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal & Co. [1964] 53 ITR 231 . 12. The learned counsel appearing on behalf of the department has made an effort to persuade this Court to accept his construction of the provisions of section 150(1) and (2). It is argued that it is for the specific purpose of assessing income, which might accrue on the basis of any decision of any Court in any proceeding in any other law, that…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

…imited vs. ACIT authorities to reopen assessments, which have become final and reassessment of which had become barred by time before 1-4-1989 when section 150(1) was amended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal & Co. [1964] 53 ITR 231 . 12. The learned counsel appearing on behalf of the department has made an effort to persuade this Court to accept his construction of the provisions of section 150(1) and (2). It is argued that it is for the specific purpose of assessing income, which might accrue on the basis of any decision of any Court in any proceeding in any other law, that…

VAKA GHANTA NAGESWARARAO,GUNTUR vs. INCOME TAX OFFICER, WARD - 1, TENALI

In the result, appeal filed by the assessee is allowed

ITA 251/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam10 Jul 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.251/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Vs. Income Tax Officer-Ward – 1 Vaka Ghanta Nageswararao 4-82-A, Gullapalli Tenali -522201 Goudapalem, Cherukapalli Mandal Andhra Pradesh Guntur – 522309 Andhra Pradesh [Pan:Afjpn4315H] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Malladi Muralidhar, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparna Villuri, Sr. Ar

Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 149(1)(b)Section 250(6)Section 69ASection 80C

…ed in issuing show cause notices u/s 148A & 148 etcafter the same is time barred, being issued on 07.04.2022, hence the same arenull & void and without jurisdiction, Last date to initiate notices being31.03.2022. It was held in S.S. Gadgil v. Lal and Co. 1964 53 ITR 231 (SC) “The amended provisions will not re-instate jurisdiction to reassessthe return which is otherwise time barred as per existing provisionsfor the relevant year.” - Also held in CIT v. Pushpak Enterprises - 254 ITR 193 (Del.) (2002) No freshconferment of jurisdiction by amendment unless law is express. 5. ASSESSMENT ERRONEOUS BEING NOT CONDUCTED…

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. TRILOK DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

ITA 302/JPR/2025[2014]Status: DisposedITAT Jaipur08 Jul 2025

…permit the\nauthorities to reopen assessments, which have become final and reassessment of\nwhich had become barred by time before 1-4-1989 when section 150(1) was\namended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal &\nCo. [1964] 53 ITR 231 .\n12. The learned counsel appearing on behalf of the department has made an effort\nto persuade this Court to accept his construction of the provisions of section\n150(1) and (2). It is argued that it is for the specific purpose of assessing income,\nwhich might accrue on the basis of any decision of any Court in any proceeding in\nany other law,…

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. VAIBHAV BANKA, SIKAR

In the result, the appeals of the revenue stands dismissed, and the

ITA 301/JPR/2025[2016]Status: DisposedITAT Jaipur08 Jul 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

…not permit the authorities to reopen assessments, which have become final and reassessment of which had become barred by time before 1-4-1989 when section 150(1) was amended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal & Co. [1964] 53 ITR 231 . 12. The learned counsel appearing on behalf of the department has made an effort to persuade this Court to accept his construction of the provisions of section 150(1) and (2). It is argued that it is for the specific purpose of assessing income, which might accrue on the basis of any decision of any Court in any proceeding in any other law, that…

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

ITA 300/JPR/2025[2016]Status: DisposedITAT Jaipur08 Jul 2025

…permit the\nauthorities to reopen assessments, which have become final and reassessment of\nwhich had become barred by time before 1-4-1989 when section 150(1) was\namended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal &\nCo. [1964] 53 ITR 231 .\n12. The learned counsel appearing on behalf of the department has made an effort\nto persuade this Court to accept his construction of the provisions of section\n150(1) and (2). It is argued that it is for the specific purpose of assessing income,\nwhich might accrue on the basis of any decision of any Court in any proceeding in\nany other law,…

DCIT, CENTRAL CIRCLE-1, JAIPUR, JAIPUR vs. SARITA DEWAN, SIKAR

In the result, the appeals of the revenue in ITA No

ITA 299/JPR/2025[2014]Status: DisposedITAT Jaipur08 Jul 2025

…permit the\nauthorities to reopen assessments, which have become final and reassessment of\nwhich had become barred by time before 1-4-1989 when section 150(1) was\namended. Reliance is placed on the decision of this Court in S.S. Gadgil v. Lal &\nCo. [1964] 53 ITR 231 .\n12. The learned counsel appearing on behalf of the department has made an effort\nto persuade this Court to accept his construction of the provisions of section\n150(1) and (2). It is argued that it is for the specific purpose of assessing income,\nwhich might accrue on the basis of any decision of any Court in any proceeding in\nany other law,…

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