202 ITR 932, CIT v. Durgawati

31 ITR 603High Court1957#3273 most cited

What is 202 ITR 932, CIT v. Durgawati authority for?

The same income cannot be assessed substantively in multiple hands. However, this principle does not prevent a single consolidated assessment order for multiple legal representatives.

36

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. Durgawati · 202 ITR 932 · substantive assessment · multiple hands · legal heirs · consolidated assessment · income tax law

Sections most often in play

Section 132(4)Section 69ASection 69Section 132Section 143(3)Section 153ASection 156Section 159

Issues it is cited on

commercial substancesection 159substantive assessmentrelated party transactionlegal representativestatement under section 132(4)retracted statementbusiness expediencysection 156protective assessmentsection 292bcolourable device

Judgments citing 202 ITR 932, CIT v. Durgawati

DCIT, Central Circle-1(3), Bengaluru vs. Late Shri V G Siddhartha, Represented by Legal Heir Ms. Malvika Hegde, Bengaluru

ITA 2132/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Jul 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the pr…

DCIT, Central Circle-1(3), Bengaluru vs. Late Shri V G Siddhartha, Represented by Legal Heir Ms. Malvika Hegde, Bengaluru

ITA 2131/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Jul 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…nt tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the pre…

DCIT, Central Circle-1(3), Bengaluru vs. Late Shri V G Siddhartha, Represented by Legal Heir Ms. Malvika Hegde, Bengaluru

In the result the appeal filed by the revenue is hereby dismissed

ITA 2130/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

DCIT, Central Circle-1(3), Bengaluru vs. Late Shri V G Siddhartha, Represented by Legal Heir Ms. Malvika Hegde, Bengaluru

In the result the appeal filed by the revenue is hereby dismissed

ITA 2129/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

Mr. Ishaan Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Incomer Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1459/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Jul 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…nt tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the pre…

Mr. Ishaan Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Incomer Tax, Central Circle-1(3), Bangalore

ITA 1458/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Jul 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…nt tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the pre…

Mr. Ishaan Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Incomer Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1457/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

Mr. Ishaan Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Incomer Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1456/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

Mr. Ishaan Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Incomer Tax, Central Circle-1(3), Bangalore

ITA 1455/BANG/2024[2014-15]Status: DisposedITAT Bangalore16 Jul 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…ependent tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: CIT v. Surat Cotton (202 ITR 932) CIT v. Durgawati (202 ITR 932 Bombay HC) Jagannath Hanumanbux v. ITO (31 ITR 603) Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the prese…

Mr. Ishaan Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 1454/BANG/2024[2013-14]Status: DisposedITAT Bangalore16 Jul 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…nt tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the pre…

Mr. Amarthya Siddhartha L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 1453/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Jul 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…t tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the pr…

Mr. Amarthya Siddhartha L/R of Late Sri. V G . Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 1452/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Jul 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…nt tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the pre…

Mr. Amarthya Siddhartha L/R of Late Sri. V G . Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1451/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

Mr. Amarthya Siddhartha L/R of Late Sri. V G . Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

ITA 1450/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in…

Mr. Amarthya Siddhartha L/R of Late Sri. V G . Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

Appeal of the revenue is hereby dismissed

ITA 1449/BANG/2024[2014-15]Status: DisposedITAT Bangalore16 Jul 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in…

Mr. Amarthya Siddhartha L/R of Late Sri. V G . Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1448/BANG/2024[2013-14]Status: DisposedITAT Bangalore16 Jul 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

Mrs. Malavika Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1447/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Jul 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

Mrs. Malavika Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1446/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Jul 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

Mrs. Malavika Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1445/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

Mrs. Malavika Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1444/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

…tax obligations on each legal heir. 17.4 At the time of hearing, the ld. AR for the assessee has relied on various judicial precedents, including: • CIT v. Surat Cotton (202 ITR 932) • CIT v. Durgawati (202 ITR 932 Bombay HC) • Jagannath Hanumanbux v. ITO (31 ITR 603) • Lalji Haridas v. ITO (1961 43 ITR 387 SC) 17.5 These cases establish the principle that the same income cannot be assessed substantively in multiple hands. However, these rulings primarily deal with situations where the AO assessed multiple legal heirs separately on a substantive basis, resulting in multiple tax demands. In contrast, in the p…

202 ITR 932, CIT v. Durgawati (31 ITR 603) — Cited in 36 Judgments | BharatTax