47. In CTO v. Biswanath Jhunjhunwalla

5 SCC 626Reported decision1996#20994 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 341,001 Indian tax judgments — from 2020 to 2026.

Sections most often in play

Section 147 Section 148 Section 148A Section 144C(13)Section 149 Section 69 Section 10(4)Section 10(4)(ii)

Issues it is cited on

within four years section 148 notice section 31 beyond four years section 149(1)(b)section 149(1)specified authority income escaping assessment section 148a(b)section 148a(d)section 149 section 148a

Judgments citing 47. In CTO v. Biswanath Jhunjhunwalla

Arun Duraiswamy, Mysore, Karnataka vs. ITO, Intl. Taxation Ward 1(1), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 193/BANG/2025[2015-16]Status: DisposedITAT Bangalore16 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: CA Deepak Gunashekar, A.RFor Respondent: Dr. Divya K.J, CIT D.R

Section 139Section 147Section 148Section 148ASection 149Section 69Section 69C

…der section 148 of the new regime for assessment year 2021-2022 and before only if the time limit for issuance of such notice continued to exist under section 149(1)(b) of the old regime. 47. In CTO v. Biswanath Jhunjhunwalla 1996 taxmann.com 1141 (SC)/[1996] 5 SCC 626 the Bengal Sales Tax Rules 1941 empowered the Commissioner to revise any assessment within four years from the date of assessment. Subsequently, the State Government issued a notification following the law to extend the time limit from four years to six years from the date of assessment. The extension of the time limit was challenged by the respond…

Neeta Bhambhani, Bengaluru vs. DCIT, (It), Circle-1(1), Bengaluru

In the result, I pass the following:-

ITA 3124/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Adv. Ema Bindu, A.RFor Respondent: Dr. Divya K.J., CIT D.R

Section 10(4)(ii)Section 143(3)Section 148Section 148ASection 151Section 69

…ta Bhambhani, Bengaluru Page 14 of 24 assessment year 2021-2022 and before only if the time limit for issuance of such notice continued to exist under section 149(1)(b) of the old regime. 47. In CTO v. Biswanath Jhunjhunwalla 1996 taxmann.com 1141 (SC)/[1996] 5 SCC 626 the Bengal Sales Tax Rules 1941 empowered the Commissioner to revise any assessment within four years from the date of assessment. Subsequently, the State Government issued a notification following the law to extend the time limit from four years to six years from the date of assessment. The extension of the time limit was challenged by the respond…

Raghavan Nambath Menon, Bengaluru vs. ITO, Ward Intl. Taxation 1(2), Bmtc Building, Koramangala, Bengaluru

In the result, I pass the following:-

ITA 278/BANG/2025[2015-16]Status: DisposedITAT Bangalore06 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: CA Suresh Muthukrishnan, A.RFor Respondent: Dr. Divya K.J., CIT D.R

Section 143(2)Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 68

…IT(IT)A No.278/Bang/2025 Raghavan Nambath Menon, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “C’’BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER IT(IT)A No.278/Bang/2025 Assessment Year : 2015-16 Raghavan Nambath Menon #158, Bellezea Muthanallur Circle Chandapura Dommasandra Road ITO Anekal Taluk 560 099 Vs. Ward Intl. Taxation 1(2) Karnataka Bangalore PAN NO : ACFPM4825Q APPELLANT RESPONDENT Appellant by : CA Suresh Muthukrishnan, A.R. Respondent by : Dr. Divya K.J., CIT D.R. Date of Hearing : 12.11.2025 Date of Pronouncement : 06.02.2026 O R D E…

M/S Hcl Technologies Ltd., Noida vs. ACIT (TDS), Noida

In the result appeal of assessee is allowed

ITA 1723/DEL/2017[2009-10]Status: DisposedITAT Delhi20 Jul 2020AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishihcl Technologies Ltd, Acit(Tds), Plot No. 3A, Tower 6, 14Th Floor, Vs. Noida Sector-126, Noida Pan: Aaach1645P (Appellant) (Respondent)

For Appellant: Shri Neeraj Jain, AdvFor Respondent: Ms. Rakhi Vimal, Sr. DR

Section 194CSection 201Section 201(1)Section 40

…as been delivered by larger bench of Hon'ble Supreme Court. 8.7 Mr.Mihir Joshi, learned Senior Advocate appearing on behalf of the petitioner has submitted that the judgment relied on by the respondent No. 2 in the case of CTO v. Biswanath Jhunjhunwala [1996] 5 SCC 626, for the principles laid down there in would not apply to the present case as the facts in the said judgment are different from the facts of the present case. (a) In the said judgment, assessments were completed on 17/02/1969 and 26/03/1969. Under rule 80(5) of the Bengal Sales Tax Act, 1941 as it then stood, the assessment can be revised if the…