15 to 23…… 24. In M. Janardhana Rao v. Jt. CIT

273 ITR 50Supreme Court of India2005#6958 most cited
16

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also reported as

142 Taxmann 722

Sections most often in play

Section 269SSSection 271DSection 273BSection 143(3)Section 156Section 194IASection 244ASection 250

Issues it is cited on

nfac

Judgments citing 15 to 23…… 24. In M. Janardhana Rao v. Jt. CIT

BOMMARABETTU MADHU SUDHANA ACHARYA ,UDUPI vs. INCOME TAX OFFICER, WARD-1 AND TPS, UDUPI

In the result, appeal filed by the assessee is allowed

ITA 937/BANG/2025[2016-17]Status: DisposedITAT Bangalore12 Feb 2026AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2016-17

For Appellant: Ms. Pratibha R., A.RFor Respondent: Sri Balusamy N., D.R
Section 143(1)Section 143(2)Section 143(3)Section 250Section 269SSection 271DSection 274Section 54E

…auhati High Court in CIT v. Bhagwati Prasad Bajoria (HUF)[2003] 263 ITR 487/133 Taxman 426, Chamundi Granites (P.) Ltd. v. Dy. CIT/Asstt. Director of Inspection v. Kum. A.B. Shanthi [2002] 255 ITR 258/122 Taxman 574 (SC)and M. Janardhana Rao v. Jt. CIT [2005] 273 ITR 50/142 Taxman 722 (SC). Bommarabettu Madhusudhana Acharya, Bengaluru Page 7 of 13 9. In order to appreciate the submission of the learned counsel for the parties, it would be appropriate to refer to a few provisions which will have a bearing to the issue involved in the present case, namely, Sections 269SS, 271D and Section 273B of the Act. For facil…

MAHESHWARAPPA MUNIRAMU,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, RANGE 2(2), BENGALURU, BENGALURU

In the result, appeal filed by the assessee is allowed

ITA 757/BANG/2025[2017-18]Status: DisposedITAT Bangalore26 Sept 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18 Maheshwarappa Muniramu #4261/17, 2Nd Cross, 20Th Main Subramanya Nagar Jcit Vs. Bengaluru 560 021 Range 2(2) Bangalore Pan No :Aempm8290C Appellant Respondent Appellant By : Sri Nagaraj K. H., Ca Respondent By : Sri Subramaniam, Jcit Dr Date Of Hearing : 30.06.2025 Date Of Pronouncement : 26.09.2025

For Appellant: Sri Nagaraj K. H., CAFor Respondent: Sri Subramaniam, JCIT DR
Section 143(3)Section 194ISection 244ASection 250Section 269SSection 271DSection 274

…auhati High Court in CIT v. Bhagwati Prasad Bajoria (HUF)[2003] 263 ITR 487/133 Taxman 426, Chamundi Granites (P.) Ltd. v. Dy. CIT/Asstt. Director of Inspection v. Kum. A.B. Shanthi [2002] 255 ITR 258/122 Taxman 574 (SC)and M. Janardhana Rao v. Jt. CIT [2005] 273 ITR 50/142 Taxman 722 (SC). 9. In order to appreciate the submission of the learned counsel for the parties, it would be appropriate to refer to a few provisions which will have a bearing to the issue involved in the present case, namely, Sections 269SS, 271D and Section 273B of the Act. For facility, the said provisions are extracted hereunder: '269SS.…

KARTAVYA CONSULTANTS PRIVATE LIMITED,BHUBANESWAR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), BHUBANESWAR, BHUBANESWAR

In the result, appeal the assessee is allowed

ITA 346/CTK/2025[2021-22]Status: DisposedITAT Cuttack25 Sept 2025AY 2021-22

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shrii P.K.Mishra & Shri Himanshu Jena &For Respondent: Shri Vijay Singh, Sr.DR
Section 145Section 35

…eld that the income on estimation basis cannot be done without rejecting the books of accounts. This principle has been laid down by the Hon’ble Madras High Court by following the decision of the Hon’ble Supreme Court in the case of Janardhan Rao, reported in 273 ITR 50. It was the submission that as the books of accounts of the assessee has not been rejected, the addition as made by the AO is liable to be deleted. The learned AR has also placed reliance on the decision of the Coordinate Bench of this Tribunal in the case of Sat Inder Construction Pvt. Ltd. in ITA 511/CTK/2024, dated 17-07-25 wherein in Para 5, t…

MEENA THIAGARAJAN,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee is allowed

ITA 3195/CHNY/2018[2013-14]Status: DisposedITAT Chennai04 Aug 2022AY 2013-14

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri N.Arjun Raj, CA for Shri S. Sridhar, AdvocateFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT
Section 143(3)Section 54Section 54F

…ar in the name of his wife is only a question of fact. It is a settled law that the factual findings of the Tribunal cannot be disturbed in exercise of the powers under Section 260A of the Act vide M. Janardhana Rao v. Jt. CIT (2005) 193 CTR (SC) 585 : (2005) 273 ITR 50 (SC). Hence, we do not see any question of law much less, substantial question of law arises for consideration. Accordingly, the first question fails and the same is rejected. 6.1 Similarly, the Hon’ble Delhi High Court in the case of CIT vs. Kamal Wahal, [2013] 351 ITR 4 has also considered the identical issue and held that the assessee can purc…

PR COMMISSIONER OF INCOME TAX vs. M/S ENNOBLE CONSTRUCTION

ITA/383/2016HC Karnataka20 Jul 2022

Bench: KRISHNA S.DIXIT,P.KRISHNA BHAT

Section 260Section 260A

…he statute book; such a question can be answered just by turning the pages of evidentiary record of the Assessment Proceedings concerned. Therefore, the said question is miles away 4 68 ITR 200 (207) 5 273 ITR 50 - 15 - ITA No. 383 of 2016 from the precincts of Section 260A which employs the expression ‘substantial question of law’. C. AS TO BURDEN OF PROOF AND IMPOSSIBILITY OF ITS DISCHARGE: (i) As already mentioned above, the burden of proving the expenditure incurred ‘wholly and exclusively’ for the purpose of business, is on th…

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/20040/2019HC Karnataka25 Aug 2021

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

Section 1Section 143(2)Section 143(3)Section 244ASection 254Section 92C

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 25TH DAY OF AUGUST 2021 BEFORE THE HON’BLE MR. JUSTICE KRISHNA S.DIXIT WRIT PETITION NO.20040/2019 (T-IT) BETWEEN: WIPRO LIMITED, DODDAKANNELLI, SARJAAPUR ROAD, BANGALORE-560 035, REP. BY ITS VICE PRESIDENT – TAXATION, SRI BALASUBRAMANIAN K., SON OF SRI KRISHNAMURTHY, AGED ABOUT 39 YEARS. … PETITIONER (BY SHRI S.GANESH, SR. COUNSEL A/W. SHRI VENKATESH S. ARBATTI, ADVOCATE) AND: 1. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, 2ND FLOOR, INCOME TAX OFFICE, BMTC BUILDING, 8 FEET ROAD, KORAMANGALA,…

INDIAN EXTRUSIONS,MUMBAI vs. ACIT 24(3), MUMBAI

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 1994/MUM/2017[2010-11]Status: DisposedITAT Mumbai23 Jun 2021AY 2010-11

Bench: Shri M.Balaganesh () & Shri Ravish Sood () M/S Indian Extrusions Acit-24(3) B-316/317, Virwani Industrial Vs. Mumbai. Estate,Western Express Highway, Goregaon East, Mumbai – 400 063 (Assessee) (Revenue)

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Ms. Shreekala Pardeshi, D.R
Section 143(1)Section 143(2)Section 143(3)Section 45(4)

…was made by the Division Bench since there was a conflict between the decisions in case of Gurunath Talkies (supra) and CIT v. Mango lore Ganesh Beedi Works (265ITR 658 (Kar). As per the CIT(A), the Hon'ble Supreme Court in case of M Janardhana Rao v. Jt CIT (273 ITR 50) had already set aside the judgment in the case of CIT v. Mangalore Ganesh Beedi Works (supra) even before the Full Bench was constituted. In our considered view, the approach of the CIT(A) is quite wrong. It is evident from the decision of the Hon'ble Supreme Court in case of M. Janardhana Rao v. Jt. CIT (supra) that the decision of the Hon'ble H…

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/536/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

…n. This ground of appeal is allowed”. 14. The appeal is to the limited extent that the TPO has been directed to include M/s. HMT Limited as a comparable and re-work the comparable margin. 15 to 23…… 24. In M. Janardhana Rao v. Jt. CIT [2005] 273 ITR 50/142 Taxman 722 (SC), the Hon’ble Supreme Court held that the principles contemplated under Section 100 of the Code of Civil Procedure would apply to Section 260-A of the IT Act too. Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 69/8…

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/537/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

…n. This ground of appeal is allowed”. 14. The appeal is to the limited extent that the TPO has been directed to include M/s. HMT Limited as a comparable and re-work the comparable margin. 15 to 23…… 24. In M. Janardhana Rao v. Jt. CIT [2005] 273 ITR 50/142 Taxman 722 (SC), the Hon’ble Supreme Court held that the principles contemplated under Section 100 of the Code of Civil Procedure would apply to Section 260-A of the IT Act too. Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 69/8…

Commissioner of Income Tax-II vs. Energy Solutions International India Pvt Ltd.,

ITTA/383/2016HC Telangana17 Feb 2017

Bench: J. UMA DEVI,V RAMASUBRAMANIAN

Section 260Section 260A

…he statute book; such a question can be answered just by turning the pages of evidentiary record of the Assessment Proceedings concerned. Therefore, the said question is miles away 4 68 ITR 200 (207) 5 273 ITR 50 - 15 - ITA No. 383 of 2016 from the precincts of Section 260A which employs the expression ‘substantial question of law’. C. AS TO BURDEN OF PROOF AND IMPOSSIBILITY OF ITS DISCHARGE: (i) As already mentioned above, the burden of proving the expenditure incurred ‘wholly and exclusively’ for the purpose of business, is on th…

THE COMMISSIONER OF INCOME TAX, vs. M/S BAHUBALI NEMINATH MUTTIN,

The appeals are dismissed

ITA/5029/2011HC Karnataka13 Jul 2016

Bench: ANAND BYRAREDDY,RAGHVENDRA S.CHAUHAN

Section 132Section 143Section 153ASection 260ASection 40ASection 41Section 68Section 69B

…on the following authorities by the learned Counsel for the above propositions: 1. 330 ITR 1 (SC) @ 7-9 (Vijay Kumar Talwar vs. Commissioner of Income Tax) 2. 378 ITR 640 (SC) @ 648 (Mangalore Ganesh Beedi Works vs. Commissioner of Income Tax and Another) 3. 273 ITR 50 (SC) @ 55 (M. Janardhan Rao vs. Joint Commissioner of Income Tax) 4. 300 ITR 205 (SC) @ 211,212 (Sudarshan Silks and Sarees vs. Commissioner of Income Tax) 5. 247 ITR 178 @ 180, 181, 182 (K. Ravindranathan Nair vs. Commissioner of Income Tax) 11. Alternatively, and without prejudice to the preliminary objections raised above, he would submit that,…

THE COMMISSIONER OF INCOME TAX, vs. M/S BAHUBALI NEMINATH MUTTIN

The appeals are dismissed

ITA/5028/2011HC Karnataka13 Jul 2016

Bench: ANAND BYRAREDDY,RAGHVENDRA S.CHAUHAN

Section 132Section 260ASection 69B

…ing authorities by the learned Counsel in support of the above proposition: 1. 330 ITR 1 (SC) @ 7-9 (Vijay Kumar Talwar vs. Commissioner of Income Tax) 2. 378 ITR 640 (SC) @ 648 (Mangalore Ganesh Beedi Works vs. Commissioner of Income Tax and Another) 12 3. 273 ITR 50 (SC) @ 55 (M. Janardhan Rao vs. Joint Commissioner of Income Tax) 4. 300 ITR 205 (SC) @ 211,212 (Sudarshan Silks and Sarees vs. Commissioner of Income Tax) 5. 247 ITR 178 @ 180, 181, 182 (K. Ravindranathan Nair vs. Commissioner of Income Tax) 14. Alternatively, and without prejudice to the preliminary objections raised above, he would submit that,…

THE COMMISSIONER OF INCOME TAX vs. M/S BAHUBALI NEMINATH MUTTIN

The appeals are dismissed

ITA/5025/2011HC Karnataka13 Jul 2016

Bench: ANAND BYRAREDDY,RAGHVENDRA S.CHAUHAN

Section 132Section 260ASection 69B

…ng authorities by the learned Counsel in support of the above proposition: 1. 330 ITR 1 (SC) @ 7-9 (Vijay Kumar Talwar vs. Commissioner of Income Tax) 2. 378 ITR 640 (SC) @ 648 (Mangalore Ganesh Beedi Works vs. Commissioner of Income Tax and Another) 13 3. 273 ITR 50 (SC) @ 55 (M. Janardhan Rao vs. Joint Commissioner of Income Tax) 4. 300 ITR 205 (SC) @ 211,212 (Sudarshan Silks and Sarees vs. Commissioner of Income Tax) 5. 247 ITR 178 @ 180, 181, 182 (K. Ravindranathan Nair vs. Commissioner of Income Tax) 15. Alternatively, and without prejudice to the preliminary objections raised above, he would submit that,…

Principal Commissioner of Income Tax-3 vs. M/s Satyasai Bhavani Hsopitals Private Limited

ITTA/537/2015HC Telangana02 Nov 2015

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 260

…n. This ground of appeal is allowed”. 14. The appeal is to the limited extent that the TPO has been directed to include M/s. HMT Limited as a comparable and re-work the comparable margin. 15 to 23…… 24. In M. Janardhana Rao v. Jt. CIT [2005] 273 ITR 50/142 Taxman 722 (SC), the Hon’ble Supreme Court held that the principles contemplated under Section 100 of the Code of Civil Procedure would apply to Section 260-A of the IT Act too. Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 69/8…

COMMISSIONER OF INCOME TAX DELHI vs. SUNAERO LTD.

ITA - 562 / 2008HC Delhi01 Jun 2012
Section 260ASection 4Section 45Section 47

…bstantial questions of law. Findings of facts cannot be re-appreciated. In the present case, there are concurrent findings of both, CIT(Appeal) and the tribunal in favour of the assessee. Reliance is placed on Janardhana Rao (M) vs. Joint CIT, (2005) 273 ITR 50 (SC), CIT vs. P. Mohankala, (2007) 291 ITR 278 (SC) and other decisions on similar lines of the Delhi High Court. (ii) No evidence relating to undisclosed income was found during search and, therefore, block assessment proceedings are void. Block assessment proceedings are not a substitute for regular assessment proceedings. [See Commissi…

Commissioner of Income Tax

ITA/562/2008HC Delhi01 Jun 2012
Section 260ASection 4Section 45Section 47

…bstantial questions of law. Findings of facts cannot be re-appreciated. In the present case, there are concurrent findings of both, CIT(Appeal) and the tribunal in favour of the assessee. Reliance is placed on Janardhana Rao (M) vs. Joint CIT, (2005) 273 ITR 50 (SC), CIT vs. P. Mohankala, (2007) 291 ITR 278 (SC) and other decisions on similar lines of the Delhi High Court. (ii) No evidence relating to undisclosed income was found during search and, therefore, block assessment proceedings are void. Block assessment proceedings are not a substitute for regular assessment proceedings. [See Commissi…

15 to 23…… 24. In M. Janardhana Rao v. Jt. CIT (273 ITR 50) — Cited in 16 Judgments | BharatTax