21. In SB Gurbaksh Singh v. Union of India

2 SCC 181Supreme Court of India2007#243 most cited
318

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2008 to 2026.

Also referred to as

Rajesh Kumar v. Deputy CIT · SB Gurbaksh Singh v. Union of India · 2 SCC 181 · Section 143(3) · Section 144C · Section 153 · interpretation of law · assessment procedure · divergence of opinion · legal uncertainty

Also reported as

37 STC 425

Sections most often in play

Section 143(3)Section 144C(13)Section 153(4)Section 153(1)Section 153Section 144BSection 144CSection 153(2A)

Issues it is cited on

section 144cofsection 158absection 136section 261section 11(3)section 115bbe(b)section 153(4)impermissible avoidance arrangementsection 144c(4)section 193section 196section 43(3)

Judgments citing 21. In SB Gurbaksh Singh v. Union of India

M/S Cosmo Films Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeals of the Assessees are allowed

ITA 4453/DEL/2015[2011-12]Status: DisposedITAT Delhi29 Jan 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaycosmo Films Ltd. Vs Ddit 1008, Dlf Tower-A, Circle-3(1), Jasola District Centre, New Delhi New Delhi Pan: Aaacc1152C Appellant Respondent

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) Cosmo Films Ltd. 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that…

M/S. Cosmo Films Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeals of the Assessees are allowed

ITA 1192/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Jan 2026AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaycosmo Films Ltd. Vs Ddit 1008, Dlf Tower-A, Circle-3(1), Jasola District Centre, New Delhi New Delhi Pan: Aaacc1152C Appellant Respondent

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) Cosmo Films Ltd. 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that…

M/S. Cosmo Films Ltd., New Delhi vs. DDIT, New Delhi

In the result, appeals of the Assessees are allowed

ITA 2348/DEL/2014[2009-10]Status: DisposedITAT Delhi29 Jan 2026AY 2009-10

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaycosmo Films Ltd. Vs Ddit 1008, Dlf Tower-A, Circle-3(1), Jasola District Centre, New Delhi New Delhi Pan: Aaacc1152C Appellant Respondent

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) Cosmo Films Ltd. 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that…

DCIT, New Delhi vs. M/S. Cosmo Films Ltd., New Delhi

In the result, appeals of the Assessees are allowed

ITA 2135/DEL/2014[2009-10]Status: DisposedITAT Delhi29 Jan 2026AY 2009-10

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaycosmo Films Ltd. Vs Ddit 1008, Dlf Tower-A, Circle-3(1), Jasola District Centre, New Delhi New Delhi Pan: Aaacc1152C Appellant Respondent

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) Cosmo Films Ltd. 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that…

Bentley Systems India Private Limited, Delhi vs. DCIT, Circle 4(2), Delhi Assessment Unit, Income Tax Department, Delhi

In the result, appeal of the Assessee is allowed

ITA 4465/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi28 Jan 2026

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbentley Systems India Private V Deputy Commissioner Of Limited. Work Well Suites, 10 Floor, S Income Tax, Circle 4(2), C. Max House, 1516/338,339 340 R. Building, Assessment Village Behapur Adjacent Okhla Unit, Income Tax Railway Station, Okhla Industrial Department, Delhi Estate, S.O. Tehkhand, South East Delhi, Delhi, 110020 Pan: Aabcb5645E Appellant Respondent Assessee By Sh. Nishank Vashistha, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Vivo Mobile India Private Limited, Haryana, India vs. Assistance Commissioner of Income Tax, Central Circle, Delhi

In the result, appeals of the Assessee are allowed

ITA 4408/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Ts Tech Sun India Private Limited, New Delhi vs. The Assistant Commissioner of Income Tax, Circle 25(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 4391/DEL/2024[2020-2021]Status: DisposedITAT Delhi28 Jan 2026AY 2020-2021

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalts Tech Sun India Private Vs The Assistant Commissioner Limited, A-47, Lower Ground Of Income Tax, Circle 25(1), C. Floor, Hauz Khas, New Delhi- R. Building, I. P. Estate, 110016 Delhi-110002, New Delhi Pan: Aaact4324M Appellant Respondent Assessee By Sh. Ankit Sahni, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Jubilant Generics Limited, Gautam Buddha Nagar vs. Assessment Unit, Delhi

In the result, appeal of the Assessee is allowed

ITA 4316/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaljubilant Generics Limited Vs Assessment Unit, Income Tax Plot 1A, Sector-16A Noida H. O. Department, Gautam Buddha Nagar, 201301, Delhi Uttar Pradesh Pan: Aadcj2401L Appellant Respondent Assessee By Ms. Nidhi, Ar (Virutal) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)Section 158A

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 22 Jubilant Generics Ltd. Vs. Assessment Unit 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts…

Toyo Ink India Private Limited, Delhi vs. The Deputy Commissioner of Income Tax, Delhi

In the result, appeal of the Assessee is allowed

ITA 4299/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaltoyo Ink India Private Limited Vs The Deputy Commissioner Of C-151, Naraina Industrial Area, Income Tax, Circle 25(1), Phase-1, Naraina Industrial Range 46, C. R. Building, Estate, South West, Delhi- Delhi-110002, Delhi 110028Pan: Aacct5137A Appellant Respondent Assessee By Sh. Ankitsahni, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Honda Access India Private Limited, Noida, Uttar Pradesh vs. Assessment Unit, Income Tax Department, Gb Nagar, Noida, Uttar Pradesh

In the result, appeal of the Assessee is allowed

ITA 4251/DEL/2024[2020-2021]Status: DisposedITAT Delhi28 Jan 2026AY 2020-2021

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalhonda Access India Private Vs Assessment Unit, Income Limited Plot No. 1-D/5, Tax Department, Circle Udyogvihar, Ecotech-Ii, Alpha 5(1)(1), G B Nagar, Nodia, Greater Noida, Gautam Uttar Pradesh Buddha Nagar, 201308, Uttar Pradesh Pan: Aacch9695K Appellant Respondent Assessee By Sh. Nishank Vashistha, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Adidas India Marketing Private Limited, New Delhi vs. Assistant Commissioner of Income Tax, Circle 1(1), Delhi

In the result, appeal of the Assessee is allowed

ITA 3858/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaladidas India Marketing Private Vs Assistant Commissioner Of Limited. Office No. 6, 2Nd Floor, Income Tax, Circle 1(1), C. R. Sector B Pocket No. 7 Plot No.11, Building, Delhi Vasantkunj South West Delhi Pan: Aaaca5313P Appellant Respondent Assessee By Sh. Ankit Sahni, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Beumer India P.Ltd, New Delhi vs. DCIT, Circle 1(1)(2), New Delhi

In the result, Appeal of the Assessee in ITA No

ITA 1599/DEL/2023[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)Section 154

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Eversub India Private Ltd. (Formely As ' Subway Systems India Private Ltd., Haryana vs. DCIT Circle 22(2), Delhi

In the result, appeals of the Assessee are allowed

ITA 548/DEL/2022[2017-18]Status: DisposedITAT Delhi28 Jan 2026AY 2017-18

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Msd Pharmaceuticals Pvt Ltd, Delhi vs. DCIT Circle -16(1), New Delhi

In the result, appeals of the Assessee are allowed

ITA 2330/DEL/2022[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…be found out from the MSD Pharmaceuticals (P.) Ltd. Vs. DCIT statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Vivo Mobile India Private Limited, Gurgaon vs. ACIT, Circle-25(1), Delhi

In the result, appeals of the Assessee are allowed

ITA 1488/DEL/2022[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Baxter (India) Pvt. Ltd., Gurgaon vs. DCIT Circle-4(2), Delhi

In the result, appeals of the Assessee are allowed

ITA 1361/DEL/2022[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbaxter India Pvt. Ltd. Vs Acit 2Nd Floor, Tower C, Building Circle 4 (1) No. 8, Dlf Cyber City, Dlf C. R. Building, Phase-Ii, Gurgaon New Delhi Pan: Aaacb3906F Appellant Respondent

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Baxter (India) Private Ltd., Gurgaon vs. DCIT Circle-4(2), Delhi

In the result, appeals of the Assessee are allowed

ITA 1360/DEL/2022[2017-18]Status: DisposedITAT Delhi28 Jan 2026AY 2017-18

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbaxter India Pvt. Ltd. Vs Acit 2Nd Floor, Tower C, Building Circle 4 (1) No. 8, Dlf Cyber City, Dlf C. R. Building, Phase-Ii, Gurgaon New Delhi Pan: Aaacb3906F Appellant Respondent

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Inductis (India) Pvt. Ltd., New Delhi vs. ACIT, Circle- 12(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 9713/DEL/2019[2015-16]Status: DisposedITAT Delhi28 Jan 2026AY 2015-16

Bench: Yogesh K Umar, U.S. & Shri Manish Agarwal

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)Section 158A

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Baxter India Pvt. Ltd., Gurgaon vs. ACIT, Circle- 4(1), New Delhi

In the result, appeals of the Assessee are allowed

ITA 7833/DEL/2017[2013-14]Status: DisposedITAT Delhi28 Jan 2026AY 2013-14

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbaxter India Pvt. Ltd. Vs Acit 2Nd Floor, Tower C, Building Circle 4 (1) No. 8, Dlf Cyber City, Dlf C. R. Building, Phase-Ii, Gurgaon New Delhi Pan: Aaacb3906F Appellant Respondent

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…

Oracle India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeals of the Assessee in ITA No

ITA 938/DEL/2016[2007-08]Status: DisposedITAT Delhi28 Jan 2026AY 2007-08

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaloracle India Private Limited Vs Addl. Cit F-01/02, 1St Floor, Salcon Range-13 Rasvilas, D-1, District Centre, New Delhi Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Oracle India Private Limited Vs Dcit F-01/02, 1St Floor, Circle-19(1) Salconrasvilas, D-1, District New Delhi Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Dcit Vs Oracle India Private Limited Circle-19(1) F-01/02, 1St Floor, Salcon New Delhi Rasvilas, D-1, District Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Assessee By Sh. Naveen Dhamija, Ca, Sh. Vishal Aggarwal, Ca& Sh. Rinku Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144CSection 153Section 154

…the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. 21. In SB Gurbaksh Singh v. Union of India ((1976) 2 SCC 181 1976 SCC (Tax) 177: (1976) 37 STC 425] Untwalia, J., speaking for the Bench, opined (SCC p. 188, para 15) 15. Apropos the fourth and the last submission of the appellant, suffice it to say that even assuming that the revisional power cannot be exercised suomotu after an unduly long delay, on the facts of this case it is plain that it was not so don…