A.N.Sehgal & Others vs Raje Ram Sheoran 1991 AIR 1406 (SC); 2. Allied Motors v. CIT

198 ITR 110Reported decision#19686 most cited
4

judgments rely on this decision, according to BharatTax’s citation analysis of 358,219 Indian tax judgments — from 2015 to 2022.

Judgments citing A.N.Sehgal & Others vs Raje Ram Sheoran 1991 AIR 1406 (SC); 2. Allied Motors v. CIT

Bajaj Allianz General Insurance Company Ltd., Pune vs. Deputy Commissioner of Income-Tax

ITA 1655/PUN/2015[2007-08]Status: DisposedITAT Pune19 Apr 2022AY 2007-08
For Appellant: Shri Percy J. Pardiwalla &For Respondent: Ms. Divya Bajpai, CIT
Section 14ASection 28Section 43BSection 44

…anner an amendment Of an omission in the statute has also to be seen in a holistic manner and a logical interpretation should be given in conjunction with tile object of amendment. The Hon'ble Orissa High Court in the case of CIT v Pyarilal Kasam Manji and Co.198 ITR 110 has made an observation that whenever an amendment is made, to arrive at the real meaning it is always necessary to get an exact conception of the aim, scope and object of the whole Act, to consider the defect which was sought to be remedied and the reasons given for such redressal. & C.O. 112/PUN/2017 Bajaj Allianz General A.Y. 2007-08 5.2 In t…

Deputy Commissioner of Income-Tax vs. Bajaj Allianz General Insurance Company Ltd., Pune

ITA 1645/PUN/2015[2007-08]Status: DisposedITAT Pune19 Apr 2022AY 2007-08
For Appellant: Shri Percy J. Pardiwalla &For Respondent: Ms. Divya Bajpai, CIT
Section 14ASection 28Section 43BSection 44

…anner an amendment Of an omission in the statute has also to be seen in a holistic manner and a logical interpretation should be given in conjunction with tile object of amendment. The Hon'ble Orissa High Court in the case of CIT v Pyarilal Kasam Manji and Co.198 ITR 110 has made an observation that whenever an amendment is made, to arrive at the real meaning it is always necessary to get an exact conception of the aim, scope and object of the whole Act, to consider the defect which was sought to be remedied and the reasons given for such redressal. & C.O. 112/PUN/2017 Bajaj Allianz General A.Y. 2007-08 5.2 In t…

DCIT, New Delhi vs. M/S. Bharat Sanchar Nigam Ltd., New Delhi

In the result, assessee’s appeal is allowed to the extent as mentioned above on the preliminary issue and the departmental appeal is dismissed

ITA 3386/DEL/2010[2004-05]Status: DisposedITAT Delhi23 Dec 2015AY 2004-05

Bench: Smt Diva Singh & Sh.J.S.Reddyi.T.A .No.-3304/Del/2010 (Assessment Year-2004-05) Bharat Sanchar Nigam Ltd., Vs Dcit, Corporate Office, Taxation Section, Circle-2(1), Room No.-398, First Floor, Bharat Sanchar Bhawan, C.R.Building, I.P.Estate, Janpath, New Delhi-1110001. New Delhi Pan-Aabcb5576G (Appellant) (Respondent)

Section 143(1)Section 143(3)Section 154Section 263Section 80Section 80I

…8.9. In support of the said proposition reliance was placed on the following decisions of the Apex Court :- 1. A.N.Sehgal & Others vs Raje Ram Sheoran 1991 AIR 1406 (SC); 2. Allied Motors vs CIT 224 ITR 667 (SC); and 3. CIT vs Pyari Lal Kasam Manji & Company 198 ITR 110 (Orissa High Court). 8.10. Even otherwise it was submitted that by applying the various Rules of Interpretation the scope and ambit of section 80IA (2A) of the Act cannot be Page 11 of 44 I.T.A .No.-3304 & 3386/Del/2010 restricted and the phrase “derived from” cannot be read into Section 80-IA(2A) of the Act. 8.11. It was further submitted that…

Bharat Sanchar Nigam Ltd., New Delhi vs. DCIT, New Delhi

In the result, assessee’s appeal is allowed to the extent as mentioned above on the preliminary issue and the departmental appeal is dismissed

ITA 3304/DEL/2010[2004-05]Status: DisposedITAT Delhi23 Dec 2015AY 2004-05

Bench: Smt Diva Singh & Sh.J.S.Reddyi.T.A .No.-3304/Del/2010 (Assessment Year-2004-05) Bharat Sanchar Nigam Ltd., Vs Dcit, Corporate Office, Taxation Section, Circle-2(1), Room No.-398, First Floor, Bharat Sanchar Bhawan, C.R.Building, I.P.Estate, Janpath, New Delhi-1110001. New Delhi Pan-Aabcb5576G (Appellant) (Respondent)

Section 143(1)Section 143(3)Section 154Section 263Section 80Section 80I

…8.9. In support of the said proposition reliance was placed on the following decisions of the Apex Court :- 1. A.N.Sehgal & Others vs Raje Ram Sheoran 1991 AIR 1406 (SC); 2. Allied Motors vs CIT 224 ITR 667 (SC); and 3. CIT vs Pyari Lal Kasam Manji & Company 198 ITR 110 (Orissa High Court). 8.10. Even otherwise it was submitted that by applying the various Rules of Interpretation the scope and ambit of section 80IA (2A) of the Act cannot be Page 11 of 44 I.T.A .No.-3304 & 3386/Del/2010 restricted and the phrase “derived from” cannot be read into Section 80-IA(2A) of the Act. 8.11. It was further submitted that…

A.N.Sehgal & Others vs Raje Ram Sheoran 1991 AIR 1406 (SC); 2. Allied Motors v. CIT (198 ITR 110) — Cited in 4 Judgments | BharatTax