448 ITR 594 (SC) New Noble Educational Society v. CCIT

100 ITR 698Supreme Court of India1975#2267 most cited

What is 448 ITR 594 (SC) New Noble Educational Society v. CCIT authority for?

Where a word in a statute is unambiguous and capable of only one meaning, it must be given effect in its own terms, without importing external rules of interpretation.

50

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 1992 to 2025.

Also referred to as

New Noble Educational Society v. CCIT · 448 ITR 594 SC · unambiguous statutory language · unequivocal statutory meaning · rule of interpretation · plain meaning rule · statutory construction

Sections most often in play

Section 143(3)Section 148Section 250Section 147Section 153ASection 153DSection 5Section 68

Issues it is cited on

section 274(2)section 243section 245hacasus omissussection 245csettlement applicationsection 245d(4)section 153(4)section 135asection 144basection 245dsection 244

Judgments citing 448 ITR 594 (SC) New Noble Educational Society v. CCIT

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 38/ALLD/2019[2011-12]Status: DisposedITAT Allahabad30 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…as power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 37/ALLD/2019[2010-11]Status: DisposedITAT Allahabad30 Sept 2025AY 2010-11

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…as power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 36/ALLD/2019[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…as power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 35/ALLD/2019[2008-09]Status: DisposedITAT Allahabad30 Sept 2025AY 2008-09

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…as power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 34/ALLD/2019[2007-08]Status: DisposedITAT Allahabad30 Sept 2025AY 2007-08

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…as power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed…

Minto Developers Pvt. Ltd., Allahabad vs. Assistant Commissioner of Income Tax, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 337/ALLD/2018[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…as power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed…

Brand India Real Estate Private Limited, Jaipur vs. Income Tax Officer Ward 6(1), Jaipur

In the result, appeal of the assessee is allowed

ITA 514/JPR/2025[2012-2013]Status: DisposedITAT Jaipur29 Sept 2025AY 2012-2013
For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Dharam Singh Meena, JCIT
Section 132Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

…to be known in administrative law as the principles of jurisprudence. Compliance with the audi alteram partem rule of natural justice is an indispensable requirement of a valid assessment order. kindly see,Jagadambika Pratap Narain Singh (Raja) v. CBDT (1975) 100 ITR 698 (SC), Government of India v. Maxim A Lobo (1990) 83 CTR (Mad) 103; CIT v. VimladenBhagwandas Patel (Smt.) (1979) 118 ITR 134 (Guj); Gangadharan Pillai (P) v. ACED (1980) 126 ITR 356 (Ker); A Sociedade de Fomento Industrial Pvt. Ltd. v. Lahiri (KC) (1983) Tax LR 2664 (Goa); MallappaKallappaUgare v. Ag ITO (1973) 91 ITR 529 (Mys); State Bank of Pat…

Agriwise Finserv Limited, Andheri, Mumbai vs. DCIT Circle-3(2)(1), Churchgate, Mumbai

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 4381/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Aug 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Om Prakash Kantagriwise Finserv Ltd Vs. Dcit, Circle – 3(2)(1) Aayakar Bhavan, Unit No. 802, 8Th Floor, Churchgate, Mumbai – Sumer Plaza, Marol 400020. Maroshi Road, Jb Nagar, So, Mumbai – 400059. Pan/Gir No. Aabcr0038F (Applicant) (Respondent) Assessee By Shri Bhupendra Shah Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 20.08.2025 Date Of Pronouncement 26.08.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 07.07.2023 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre / Cit(A), Mumbai For The Assessment Year 2012- 13. 2. At The Outset, We Noticed That The Present Appeal Filed By The Assessee Is Time Barred By 611 Days & In This Regard An Application For Seeking Condonation Of Delay Has Been Filed By The Assessee, Wherein It Has Been Mentioned As Under:

Section 143(3)Section 250Section 5

…acts the necessary steps could not be taken, please take a lenient view and condone the delay. 2. This delay is wholly unintentional & beyond the control of the appellant. The word Sufficient cause' has been construed quite liberally in case of Pratap Singh [100 ITR 698 S.C.J. S.N. Ghorpade [48 ITR 54 Mumbai]. 3. The word 'Sufficient' cause is used in section 5 of the Limitation Act, hence equally important relevance is attached to it. The Supreme Court has interpreted this phrase which is binding on all courts and Qu-asi-judicial authorities that decide condonation of delay on sufficient cause bein-g shown. Se…

Pravinkumar Harishchandra Choudhary, Mumbai vs. ITO 24(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1412/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jul 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankarpravinkumar Harishchandra Vs. Ito – 24(3)(1) Choudhary Piramal Chamber 102, Hill Queen Apartment Mumbai Marol, Maroshi Road, Bahvani Nagar, Andheri (E) Pan/Gir No. Aatpc0999D (Applicant) (Respondent)

Section 143(3)Section 250Section 5

…he necessary steps could not be taken, please take a lenient view and condone the delay. 2. This delay is wholly unintentional & beyond the control of the appellant. The word 'Sufficient cause' has been construed quite liberally in case of R.J. Pratap Singh [100 ITR 698 S.C.]. S.N. Ghorpade [48 ITR 54 Mumbai]. 3. The word 'Sufficient' cause is used in section 5 of the Limitation Act, hence equally important relevance is attached to it. The Supreme Court has interpreted this phrase which is binding on all courts and Qu-asi-judicial authorities that decide condonation of delay on sufficient cause being shown. Se…

Deputy Commissioner of Income Tax, Central Circle -5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue stands dismissed

ITA 4872/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 May 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & HON’BLE SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No. 4872, 4878, 4866 & 4865/Mum/2023 (A.Ys: 2017-18, 2020-21, 2021-22 & 2018-19) DCIT, Central Circle – 5(2) Vs. AGV Consultants, Room No. 1908, Air India A-101, Ashoka Tower, Bldg, Nariman Point, Kullupwali Road, Mumbai – 400021 Borivali (E), Mumbai – 400066. PAN/GIR No. AAZFA0780A (Applicant) (Respondent) Assessee by Shri Neelkanth Khandelwal Revenue by DR K.R. Subhash, CIT-Ld.DR & Shri Ram Krishn Kedia, Sr. AR Date of Hearing 08.04.2025 Date of Pro…

Deputy Commissioner of Income Tax, Central Circle- 5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue stands dismissed

ITA 4865/MUM/2023[2018-19]Status: DisposedITAT Mumbai27 May 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & HON’BLE SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No. 4872, 4878, 4866 & 4865/Mum/2023 (A.Ys: 2017-18, 2020-21, 2021-22 & 2018-19) DCIT, Central Circle – 5(2) Vs. AGV Consultants, Room No. 1908, Air India A-101, Ashoka Tower, Bldg, Nariman Point, Kullupwali Road, Mumbai – 400021 Borivali (E), Mumbai – 400066. PAN/GIR No. AAZFA0780A (Applicant) (Respondent) Assessee by Shri Neelkanth Khandelwal Revenue by DR K.R. Subhash, CIT-Ld.DR & Shri Ram Krishn Kedia, Sr. AR Date of Hearing 08.04.2025 Date of Pro…

Fancy Rehabilitation Trust, Mumbai vs. Assistant Director of Income Tax, Mumbai

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 2719/MUM/2024[2019-20]Status: DisposedITAT Mumbai10 Jul 2024AY 2019-20

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhfancyrehabilitationtrust, Vs. I T O (Exem), Ward 2(3), Cumballa Hill,Mtnl Te Sewri Cross Road, Near Building, Pedderroad, Bdd Chawl No. 9, Drgopalrao D Marg, Sewri (W), Mumbai–400026. Mumbai-400015. Pan/Gir No. Aaatf0598C (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 12ASection 143Section 143(1)

…cessary steps, please take a lenient view and condone the delay. This delay is wholly unintentional and beyond the control of the appellant. The word 'Sufficient Cause' has been liberal in the case of: construed qute liberal in the case of R. J. Pratap Singh [100 ITR 698 S. C.] S. N. Ghorpade [48 ITR 54 Mumbai] 6 Fancy Rehabilitation Trust, Mumbai The word 'Sufficient Cause' is used in section 5 of the Limitation Act, hence equally important relevance is attached to it. The Supreme Court has interpreted this phrase which is binding on all courts and Quasi- judicial authorities that decide Condonation of delay o…

H.Narayanlal, Vellore vs. DCIT, Chennai

In the result, all the appeals filed by the assessee are dismissed

ITA 1319/CHNY/2017[2007-2008]Status: DisposedITAT Chennai23 Jul 2018AY 2007-2008

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: NoneFor Respondent: Dr. M. Sreenivasa Rao, CIT-DR
Section 131

…g enormous loss and irreparable injury to the party against whom the lis terminates either by default or inaction and defeating valuable right of such a party to have the decision on merit." Raja Jagdambika Pratap Narain Singh v. Central Board of Direct Taxes 100 ITR 698 SC At the first flush it may seem that the assessee's agricultural income having been taxed illegally, a refund was obligatory and the fanatical insistence on the legal “pound of flesh” based on limitation and finality was not to be expected from a party like the State. Indeed, one might go to the extent of quoting the cynical words of the ancien…

H.Narayanlal, Vellore vs. DCIT, Chennai

In the result, all the appeals filed by the assessee are dismissed

ITA 1318/CHNY/2017[2006-2007]Status: DisposedITAT Chennai23 Jul 2018AY 2006-2007

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: NoneFor Respondent: Dr. M. Sreenivasa Rao, CIT-DR
Section 131

…g enormous loss and irreparable injury to the party against whom the lis terminates either by default or inaction and defeating valuable right of such a party to have the decision on merit." Raja Jagdambika Pratap Narain Singh v. Central Board of Direct Taxes 100 ITR 698 SC At the first flush it may seem that the assessee's agricultural income having been taxed illegally, a refund was obligatory and the fanatical insistence on the legal “pound of flesh” based on limitation and finality was not to be expected from a party like the State. Indeed, one might go to the extent of quoting the cynical words of the ancien…

H.Narayanlal, Vellore vs. DCIT, Chennai

In the result, all the appeals filed by the assessee are dismissed

ITA 1317/CHNY/2017[2005-2006]Status: DisposedITAT Chennai23 Jul 2018AY 2005-2006

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: NoneFor Respondent: Dr. M. Sreenivasa Rao, CIT-DR
Section 131

…g enormous loss and irreparable injury to the party against whom the lis terminates either by default or inaction and defeating valuable right of such a party to have the decision on merit." Raja Jagdambika Pratap Narain Singh v. Central Board of Direct Taxes 100 ITR 698 SC At the first flush it may seem that the assessee's agricultural income having been taxed illegally, a refund was obligatory and the fanatical insistence on the legal “pound of flesh” based on limitation and finality was not to be expected from a party like the State. Indeed, one might go to the extent of quoting the cynical words of the ancien…

H.Narayanlal, Vellore vs. DCIT, Chennai

In the result, all the appeals filed by the assessee are dismissed

ITA 1316/CHNY/2017[2004-2005]Status: DisposedITAT Chennai23 Jul 2018AY 2004-2005

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: NoneFor Respondent: Dr. M. Sreenivasa Rao, CIT-DR
Section 131

…g enormous loss and irreparable injury to the party against whom the lis terminates either by default or inaction and defeating valuable right of such a party to have the decision on merit." Raja Jagdambika Pratap Narain Singh v. Central Board of Direct Taxes 100 ITR 698 SC At the first flush it may seem that the assessee's agricultural income having been taxed illegally, a refund was obligatory and the fanatical insistence on the legal “pound of flesh” based on limitation and finality was not to be expected from a party like the State. Indeed, one might go to the extent of quoting the cynical words of the ancien…

H.Narayanlal, Vellore vs. DCIT, Chennai

In the result, all the appeals filed by the assessee are dismissed

ITA 1315/CHNY/2017[2003-2004]Status: DisposedITAT Chennai23 Jul 2018AY 2003-2004

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: NoneFor Respondent: Dr. M. Sreenivasa Rao, CIT-DR
Section 131

…g enormous loss and irreparable injury to the party against whom the lis terminates either by default or inaction and defeating valuable right of such a party to have the decision on merit." Raja Jagdambika Pratap Narain Singh v. Central Board of Direct Taxes 100 ITR 698 SC At the first flush it may seem that the assessee's agricultural income having been taxed illegally, a refund was obligatory and the fanatical insistence on the legal “pound of flesh” based on limitation and finality was not to be expected from a party like the State. Indeed, one might go to the extent of quoting the cynical words of the ancien…

H.Narayanlal, Vellore vs. DCIT, Chennai

In the result, all the appeals filed by the assessee are dismissed

ITA 1314/CHNY/2017[2002-2003]Status: DisposedITAT Chennai23 Jul 2018AY 2002-2003

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: NoneFor Respondent: Dr. M. Sreenivasa Rao, CIT-DR
Section 131

…g enormous loss and irreparable injury to the party against whom the lis terminates either by default or inaction and defeating valuable right of such a party to have the decision on merit." Raja Jagdambika Pratap Narain Singh v. Central Board of Direct Taxes 100 ITR 698 SC At the first flush it may seem that the assessee's agricultural income having been taxed illegally, a refund was obligatory and the fanatical insistence on the legal “pound of flesh” based on limitation and finality was not to be expected from a party like the State. Indeed, one might go to the extent of quoting the cynical words of the ancien…

H.Narayanlal, Vellore vs. DCIT, Chennai

In the result, all the appeals filed by the assessee are dismissed

ITA 1313/CHNY/2017[2001-2002]Status: DisposedITAT Chennai23 Jul 2018AY 2001-2002

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: NoneFor Respondent: Dr. M. Sreenivasa Rao, CIT-DR
Section 131

…g enormous loss and irreparable injury to the party against whom the lis terminates either by default or inaction and defeating valuable right of such a party to have the decision on merit." Raja Jagdambika Pratap Narain Singh v. Central Board of Direct Taxes 100 ITR 698 SC At the first flush it may seem that the assessee's agricultural income having been taxed illegally, a refund was obligatory and the fanatical insistence on the legal “pound of flesh” based on limitation and finality was not to be expected from a party like the State. Indeed, one might go to the extent of quoting the cynical words of the ancien…

DCIT, Jaipur vs. Shri Prateek Kothari, Jaipur

In the result, the appeal of the Revenue is dismissed

ITA 552/JPR/2017[2013-14]Status: DisposedITAT Jaipur10 Nov 2017AY 2013-14

Bench: The Hon’Ble High Court.”

For Appellant: Shri Vijay Goyal (CA)For Respondent: Prithviraj Meena (Addl. CIT) fu/kZkfjrh dh vksj ls@
Section 132(4)Section 68

…o be known in administrative law as the principles of jurisprudence. Compliance with the audi alteram partem rule of natural justice is an indispensable requirement of a valid assessment order. kindly see, Jagadambika Pratap Narain Singh (Raja) v. CBDT (1975) 100 ITR 698 (SC), Government of India v. Maxim A Lobo (1990) 83 CTR (Mad) 103; CIT v. Vimladen Bhagwandas Patel (Smt.) (1979) 118 ITR 134 (Guj); Gangadharan Pillai (P) v. ACED (1980) 126 ITR 356 (Ker); A Sociedade de Fomento Industrial Pvt. Ltd. v. Lahiri (KC) (1983) Tax LR 2664 (Goa); Mallappa Kallappa Ugare v. Ag ITO (1973) 91 ITR 529 (Mys); State Bank of…