How many judgments cite 275 (Mum Trib) (27) Narayan Tatu Rane v. ITO?

31 judgments on BharatTax cite 275 (Mum Trib) (27) Narayan Tatu Rane v. ITO (173 ITD 130), spanning 2019 to 2025.

Which sections of the Income Tax Act does 275 (Mum Trib) (27) Narayan Tatu Rane v. ITO come up under?

It is most often cited in judgments turning on Section 142(1), Section 143(1), Section 143(2), Section 143(3), Section 263, Section 36(1)(vii).

275 (Mum Trib) (27) Narayan Tatu Rane v. ITO

173 ITD 130Income Tax Appellate Tribunal2018#3779 most cited

What is 275 (Mum Trib) (27) Narayan Tatu Rane v. ITO authority for?

Revisionary power under Section 263 cannot be exercised arbitrarily; it has limits and does not apply to every inadequacy in the Assessing Officer's inquiry or verification.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2019 to 2025.

Also referred to as

Narayan Tatu Rane v. ITO · 173 ITD 130 · Section 263 · revisionary power · inadequate enquiry · prejudicial to interest of revenue · assessment order erroneous · lack of enquiry · limits of revision · CIT revision

Sections most often in play

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263 Section 36(1)(vii)Section 36(1)(viia)Section 37

Issues it is cited on

section 44ae prejudicial to interest of revenue inadequate enquiry kelvinator assessment order erroneous lack of enquiry revision u/s 263 section 44a revision under section 263 section 254(1)malabar industrial erroneous and prejudicial

Judgments citing 275 (Mum Trib) (27) Narayan Tatu Rane v. ITO

Avnish Chandra (HUF), Badaun vs. Pr. CIT, Moradabad

In the result, the appeal filed by the Assessee is dismissed

ITA 1149/DEL/2020[2016-17]Status: DisposedITAT Delhi30 Jun 2022AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri N.K. Choudhryassessment Year: 2016-17

For Appellant: ShriVivekAgarwal, CAFor Respondent: Ms.ShefaliSwaroop, CIT/DR

Section 263

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’ NEW DLEHI BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER AND SHRI N.K. CHOUDHRY, JUDICIAL MEMBER Assessment Year: 2016-17 Avnish Chandra (HUF), vs. Pr. C.I.T., Moh. Shree Narayanganj, Moradabad. Ujhani, Budaun. PAN : AAAHA6924M (Appellant) (Respondent) Appellant by : ShriVivekAgarwal, CA Respondent by : Ms.ShefaliSwaroop, CIT/DR Date of hearing : 05.05.2022 Date of order : 30.05.2022 ORDER PER N.K. CHOUDHRY, J.M. This appeal has been preferred by the Assessee against the order dated 31.01.2020impugned herein, passed by the learned Principal Commissio…

Dilip Sangoi, Raipur vs. Dy. Commissioner of Income Tax, Circle-1(1), Raipur

In the result, appeal of the assessee is allowed

ITA 34/RPR/2021[2016-17]Status: DisposedITAT Raipur29 Sept 2021AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri N.K. Choudhryassessment Year: 2016-17

For Respondent: Shri R.K. Singh, CIT D.R

Section 143(3)Section 263

…e Hon’ble Supreme Court in CIT vs. Green World Corporation (2009) 77 CCH 449 was relied upon. A reference was also made to the decision of the Tribunal in the case of Minal Nayan Shah vs. PCIT (2019) 180 ITD 149 (Ahd.), Torrent Pharmaceuticals vs. DCIT (2018) 173 ITD 130 for the proposition that a plausible view taken in exercise of quasi judicial function cannot be dislodged in a light hearted manner in the name of inadequacy in enquiries or verification as perceived in the opinion of the revisional authority and the revisional powers cannot be ITA Nos.34 & 33/RPR/2021 A.Ys. 2016-17 Page 7 of 10 exercised for d…

Arvind Sangoi, Raipur vs. Dy. Commissioner of Income Tax, Circle-1(1), Raipur

In the result, appeal of the assessee is allowed

ITA 33/RPR/2021[2016-17]Status: DisposedITAT Raipur29 Sept 2021AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri N.K. Choudhryassessment Year: 2016-17

For Respondent: Shri R.K. Singh, CIT D.R

Section 143(3)Section 263

Narendra Sharma, Dholpur vs. Pr.CIT, Alwar

In the result, this appeal of the assessee is allowed

ITA 282/JPR/2020[2015-16]Status: DisposedITAT Jaipur15 Sept 2021AY 2015-16

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 282/Jp/2020 Assessment Year: 2015-16 Cuke Shri Narendra Sharma, P.C.I.T. 2 Opp. Midway, Gt Road, Vs. Alwar. Dholpur. Pan No.: Afipn 1992 F Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri P.C. Parwal Parwal (Ca) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 28/06/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 15/09/2021 Vkns'K@ Order

For Appellant: Shri P.C. Parwal Parwal (CA)For Respondent: Shri B.K. Gupta (CIT-DR)

Section 142(1)Section 143(3)Section 263Section 80C

…ect the AO to pass a denovo assessment afresh by raising issues beyond what is permitted in the limited scrutiny. Hence, the direction given by Ld. CIT is also bad in law. He relied on the following case laws: i. Torrent Pharmaceuticals Ltd. Vs. DCIT (2018) 173 ITD 130 (Ahd.) (Trib.) ii. Amira Pure Foods Pvt. Ltd. Vs. PCIT (2017) 63 ITR(Trib.) 355/ 51 CCH 473 (Del.) (Trib.) 6. On the other hand, the ld CIT-DR has vehemently supported the order of the PCIT and also relied on the following case laws: (i) CIT Vs Smt. Saraswati Devi (1995) 212 ITR 445 (Raj) (ii) Baby Memorial Hospital Ltd. Vs ACIT, Circle 1(1),…

Shri Atul Kochar, Jaipur vs. Prcit-2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 211/JPR/2020[2015-16]Status: DisposedITAT Jaipur18 Mar 2021AY 2015-16

For Appellant: Sh. Rajeev Sogani (CA)For Respondent: Sh. Amrish Bedi (CIT)

Section 142(1)Section 143(2)Section 143(3)Section 263Section 54BSection 54F

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES ‘A’ JAIPUR Jh lanhi xkslkbZ] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI SANDEEP GOSAIN, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 211/JP/2020 fu/kZkj.k o"kZ@Assessment Year :2015-16 cuke Atul Kochar Principal Commissioner of Vs. 157, 158, Near Parnami Temple Income Tax-2, Jaipur Raja Park, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No. ADRPK6952H vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Rajeev Sogani (CA) jktLo dh vksj ls@ Revenue by : Sh…

M/S. Rajendra and Ursula Joshi Skill Development P. Ltd, Jaipur vs. Pr.CIT-2, Jaipur

In the result, the appeal of the assessee is dismissed

ITA 288/JPR/2020[2015-16]Status: DisposedITAT Jaipur02 Mar 2021AY 2015-16

Bench: Us.

For Appellant: Sh. Rohan Sogani (CA) &For Respondent: Sh. Amrish Bedi (CIT)

Section 133(6)Section 143(2)Section 143(3)Section 2Section 263

…ting each and every error of the ld. AO. Moreover, the issues as pointed above are not at all relevant for the ld. AO to reach to the conclusion and in support, reliance was placed on decision of Coordinate Bench in case of Torrent Pharmaceuticals Ltd. [2018] 173 ITD 130 (Ahd). 11. It was accordingly submitted that in view of the above factual and legal position, the ld Pr.CIT has grossly erred in assuming jurisdiction under section 263 of the Act and the order so passed therefore may be set-aside. 12. Per contra, the ld. Pr.CIT/DR submitted that the case of the assessee was selected under complete scrutiny und…

Ayub Ali, Churu vs. PCIT-3, Jaipur

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

ITA 262/JPR/2020[2015-16]Status: DisposedITAT Jaipur15 Feb 2021AY 2015-16

Bench: The Pcit On Which No Adverse Finding Was Given.”

For Appellant: Shri P.C. Parwal (CA)For Respondent: Shri Mukesh Verma (CIT) a

Section 263Section 40A(3)

…on required with reference to expenses claimed in the P&L A/c has been made by the AO. Therefore, these clauses are not attracted to the facts of assessee’s case. Reliance was placed on the following decisions:- • Torrent Pharmaceuticals Ltd. Vs. DCIT (2018) 173 ITD 130 (Ahd.) • Amira Pure Foods Pvt. Ltd. Vs. PCIT (2017) 63 ITR(Trib.) 355 • Baby Memorial Hospital Ltd. Vs. ACIT 111 taxmann.com 189. 12. Per contra, the ld. CIT/DR vehemently argued the matter and taken us through the findings of ld Pr CIT which reads as under:- “5. I have considered the facts and circumstances of the case and also examined the cas…

Essar Capital Ltd, Mumbai vs. Pr CIT 6, Mumbai

In the result the appeal of the assessee is allowed

ITA 3759/MUM/2017[2012-13]Status: DisposedITAT Mumbai08 Jan 2021AY 2012-13

Bench: Shri Rajesh Kumar & Shri Ram Lal Negiassessment Year: 2012-13 M/S. Vajresh Consultants Prcit 6, Ltd. (Earlier Known As Aayakar Bhavan, Essar Capital Ltd.), Mumbai - 400020 Vs. 40-B, Ridge Road, Malabar Hill, Mumbai – 400 006 Pan: Aabce 7257R (Appellant) (Respondent) Present For: Assessee By : Shri Nishant Thakkar, A.R. & Shri Hiten Chande, A.R. Revenue By : Shri R. Manjunatha Swamy, D.R. Date Of Hearing : 23.10.2020 Date Of Pronouncement : 08.01.2021 O R D E R

For Appellant: Shri Nishant Thakkar, A.R. &For Respondent: Shri R. Manjunatha Swamy, D.R

Section 143(3)Section 263

…of jurisdiction under section 263 of the Act and the power revision cannot be invoked when the AO has enquired into the matter. In this regard, the appellant relies on the following decision of the Tribunal: i. Torrent Pharmaceutical v. DCIT (Para 9 Pg.285) (173 ITD 130) (Ahd.) ii. Narayan Tatu v. ITO {Para 19 Pg.297} (70 taxmann.com 277) (Mum.) iii. Rallis India Ltd. v. DCIT (Para 9 Pg.312) (1TA No. 3564/M/16) (Mum.) 87 M/s. Vajresh Consultants Ltd. (Earlier known as Essar Capital Ltd.) 9.4. Without prejudice to the foregoing, it was submitted that Explanation -2 to Section 263 of the Act having been inserted…

Play Games 24 X 7 Private Limited, Mumbai vs. Pr. .CIT-(A) 13, Mumbai

In the result, this appeal by the assessee stands allowed for statistical purposes

ITA 3910/MUM/2019[2015-16]Status: DisposedITAT Mumbai05 Jan 2021AY 2015-16

Bench: Shri Shamim Yahya & Shri Ram Lal Negi: A.Y : 2015-16

For Appellant: Shri Percy PardiwalaFor Respondent: Shri Shishir Dhamija

Section 263

…d, following case laws have been relied :- i) Anil L. Todarwal v. PCIT (ITA No. 3498/Mum/2017) (2018) (Mum); ii) Narayan Tatu Rane v. Income Tax Officer (70 taxman 227) (2016) (Mum); and, 12 Play Games 24x7 Private Limited iii) Torrent Pharmaceuticals Ltd. (173 ITD 130) (Ahm. Trib.) 12. We have carefully considered the detailed submissions and perused the records. The first challenge before us is that the learned Commissioner had started the revision proceedings on a different ground and has finally passed a revision order on a different ground for which no opportunity was given to the assessee. 13. It has be…

Sthapthya Buildcon Pvt. Ltd., Ahmedabad vs. The DCIT, Ward-4(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 814/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad25 Nov 2019AY 2013-14

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No. 814/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2013-2014 Sthapathya Buildcon Pvt Ltd., D.C.I.T, Pavan Petroleum, Vs. Circle-4(1)(1), Nutun Mill Compund, Ahmedabad. Near City Gold Cinema, Saraspur, Ahmedabad. Pan: Aalcs8818G

Section 115JSection 143(3)Section 263Section 37

…it is held that merely because the order of the assessment does not discus the issue at length, it would not mean that no inquiry was made. Finding is as per para 13 of the judgment. (h) The decision of Torrent Pharmaceuticals Ltd., Ahmedabad ITAT reported in 173 ITD 130 has also taken similar view regarding change of opinion. Therefore, the action taken v/s 263 is itself bad in law and liable to be quashed. 6.1 The Ld. AR in view of the above submitted that the order passed by the AO cannot be held as erroneous insofar prejudicial to the interest of Revenue on account of non-verification of the facts stated ab…

Sterling Addlife India Private Ltd., Ahmedabad vs. Pr. CIT-4, Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 967/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad27 Mar 2019AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No.967/Ahd/2018 ("नधा"रण वष"/Assessment Year : 2013-14) बनाम/ Sterling Addlife India The Pr.Cit-4 Pvt.Ltd. Ahmedabad Vs. Sterling Hospital Buildings Off Gurukul Road Memnagar Ahmedabad-380 052 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadca 0897 M (अपीलाथ"/Appellant) (""यथ" / Respondent) .. अपीलाथ" ओर से/ Appellant By : Shri Dinal Shah & A.C.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr सुनवाई क" तार"ख/ Date Of Hearing 28/01/2019 घोषणा क" तार"ख /Date Of Pronouncement 27/03/2019 आदेश / O R D E R Per Waseem Ahmed: The Captioned Appeal Has Been Filed At The Instance Of The Assessee Against The Order Of The Commissioner Of Income Tax–4, Ahmedabad [Cit In Short] Dated 28/03/2018 Relevant To Assessment Year (Ay) 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal:-

For Appellant: Shri Dinal Shah & A.C.Shah, ArsFor Respondent: Shri Mahesh Shah, CIT-DR

Section 143(3)Section 14ASection 263

…inserted w.e.f. 1st June, 2015 and therefore the explanation is not applicable for the assessment year under appeal. Sterling Addlife India Pvt. Ltd. vs. Pr.CIT Asst.Year – 2013-14 Further, the Ahmedabad Tribunal in the case of Torrent Pharrnaceuticals Ltd. 173 ITD 130 has laid down the principals in para 9 to 9.3 about the applicability of new explanation. It is held that in adequacy of inquiry cannot be taken as a recourse under this explanation. There is a distinction between lack of inquiry and inadequate inquiry. It is only in case of lack of inquiry, CIT is empowered to exercise his revisional powers u/s.…