Andhra Pradesh in CIT v. Smt. Nayana P. Dedhia

270 ITR 572High Court2004#1392 most cited

What is Andhra Pradesh in CIT v. Smt. Nayana P. Dedhia authority for?

Guidelines issued by the Central Board of Direct Taxes (CBDT) under Section 119 of the Income Tax Act, which relax the rigour of law, are binding on all income tax officers responsible for implementing the Act, who must follow these orders and instructions.

82

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. Smt. Nayana P. Dedhia · 270 ITR 572 · Section 119 Income Tax Act · CBDT circulars binding on officers · CBDT instructions · relaxation of law · taxing authorities bound by CBDT · binding directions of Board · rigour of law relaxation · administrative instructions binding

Sections most often in play

Section 250Section 10(15)(iv)(h)Section 10(34)Section 10(38)Section 111ASection 112Section 143(3)Section 144B

Issues it is cited on

section 119(1)section 253(2)section 65(b)section 132(5)section 65asection 132(3)section 62section 119(2)(a)time barred assessmentsection 65b(4)section 253(1)section 59

Judgments citing Andhra Pradesh in CIT v. Smt. Nayana P. Dedhia

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 6(2), MUMBAI, MUMBAI vs. TATA AIG GENERAL INSURANCE CO. LTD, MUMBAI

In the result the appeal of the revenue’s bearing ITA No

ITA 2398/MUM/2024[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)
Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

…cal laws may be correctly applied. Hard cases which can be properly categorized as belonging to a class, can thus be given the benefit of relaxation of law by issuing circulars binding on the taxing authorities." 13.3 In the matter of Nayana P. Dedhia (2004) 270 ITR 572 (AP), the Hon'ble Andhra Pradesh High Court held that the guidelines issued by the Board in exercise of powers in terms of section 119 of the Act relaxing the rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow and observe any such orders, instructions and directions of the Boar…

TATA AIG GENERAL INSURANCE COMPANY LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX-8(3)(1), MUMBAI

In the result the appeal of the revenue’s bearing ITA No

ITA 1450/MUM/2024[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)
Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

…cal laws may be correctly applied. Hard cases which can be properly categorized as belonging to a class, can thus be given the benefit of relaxation of law by issuing circulars binding on the taxing authorities." 13.3 In the matter of Nayana P. Dedhia (2004) 270 ITR 572 (AP), the Hon'ble Andhra Pradesh High Court held that the guidelines issued by the Board in exercise of powers in terms of section 119 of the Act relaxing the rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow and observe any such orders, instructions and directions of the Boar…

JYOTI PRAKASH DESHMUKH,MUMBAI vs. INCOME TAX OFFICER WARD 2(2), KALYAN

In the result ground no. 5

ITA 3295/MUM/2024[2017-18]Status: DisposedITAT Mumbai07 Oct 2024AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Gagan Goyal, Accountantjyoti Prakash Deshmukh F003, Shiv Shanti Complex, Manjarli, Badlapur West, Maharashtra – 421 301, Pan No.: Agspd2705K. ...... Appellant Vs. Ito, Ward 2(2), Kalyan Mohini Plaza Building, Wayle Nagar, Khadkpada, Kalyan, Maharashtra – 421 301 ..... Respondent

For Appellant: Shri Dinesh Rokhriyal, Ld. ARFor Respondent: Ms. Rajeshwari Menon, Ld. DR
Section 142(1)Section 147Section 250Section 251

…CIT(A) has already considered the same and granted relief also relying on Instruction No. 03/2017, Dated: 21.02.2017(Addition of Rs. 28.63 Lacs). 11 Jyoti Prakash Deshmukh As far as judicial pronouncements in the case of CIT vs. Smt. Nayana P. Dedhia (2004) 270 ITR 572 (By the Hon’ble Andhra Pradesh High Court) and Reuters Asia Pacific Ltd. Vs. DCIT, International Tax, Circle-4(1)(1), Mumbai (ITA No. 587/Mum./2021) by the coordinate bench are concerned, both have no use, considering the facts of the matter. Certainly the judicial pronouncement relied upon by the assessee in the case Arun Kumar Bose vs. ITO; Sil…

CUMMINS TECHNOLOGIES INDIA (P) LTD.,DEWAS vs. ACIT CIRCLE 1(1), UJJAIN

In the result, the appeal of the assesse is allowed

ITA 982/IND/2019[2015-16]Status: DisposedITAT Indore30 Nov 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicommins Technologies India Acit, Circle -1(1) Private Limited Ujjain Vs. Industrial Area No.2, A.B. Road, M.P. (Appellant / Assessee) (Revenue) Pan: Aabct2018B Assessee By Shri Ketan Ved & Pinkesh Vakharia Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 29.11.2023 Date Of Pronouncement 30.11.2023

Section 143(3)Section 144CSection 144C(5)

…applied. Hard cases which can be properly categorized as belonging to a class, can thus be given the benefit of relaxation of law by issuing circulars binding on the taxing authorities.” 13.3 In the matter of CIT v. Smt. Nayana P. Dedhia [2004] 141 Taxman 603/270 ITR 572 (AP), the Hon’ble Andhra Pradesh High Court held that the guidelines issued by the Board in exercise of powers in terms of section 119 of the Act relaxing the rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow and observe any such orders, instructions and directions of the Boar…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CRICLE-2(1), NAGPUR vs. SHRI SUNIL PRATAP AHUJA, AKOLS

Appeals of the Revenue are DISMISSED

ITA 87/NAG/2022[2014-15]Status: DisposedITAT Nagpur31 Oct 2023AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRRLE-2(1), NAGPUR vs. SHRI RAMESH DAYARAM AHUJA, AKOLA

Appeals of the Revenue are DISMISSED

ITA 86/NAG/2022[2014-15]Status: DisposedITAT Nagpur31 Oct 2023AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRRLE-2(1), NAGPUR vs. SHRI RAMESH DAYARAM AHUJA, AKOLA

Appeals of the Revenue are DISMISSED

ITA 85/NAG/2022[2012-13]Status: DisposedITAT Nagpur31 Oct 2023AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR vs. SHRI ASHISH MURLIDHAR AHUJA, AKOLA

Appeals of the Revenue are DISMISSED

ITA 84/NAG/2022[2015-16]Status: DisposedITAT Nagpur31 Oct 2023AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR vs. SHRI ASHISH MURLIDHAR AHUJA, AKOLA

Appeals of the Revenue are DISMISSED

ITA 83/NAG/2022[2014-15]Status: DisposedITAT Nagpur31 Oct 2023AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), , NAGPUR vs. SHRI MANISH PRATAP AHUJA, AKOLA

Appeals of the Revenue are DISMISSED

ITA 82/NAG/2022[2014-15]Status: DisposedITAT Nagpur31 Oct 2023AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), , NAGPUR vs. SHRI MANISH PRATAP AHUJA, AKOLA

Appeals of the Revenue are DISMISSED

ITA 81/NAG/2022[2012-13]Status: DisposedITAT Nagpur31 Oct 2023AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR vs. M/S. GUPTA METALLICS & POWER LTD., NAGPUR

Appeals of the Revenue are DISMISSED

ITA 80/NAG/2022[2011-12]Status: DisposedITAT Nagpur31 Oct 2023AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

SEEMA MUKESH GUPTA,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), NAGPUR

Appeals of the Revenue are DISMISSED

ITA 78/NAG/2022[2007-08]Status: DisposedITAT Nagpur31 Oct 2023AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

SEEMA MUKESH GUPTA,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), NAGPUR

Appeals of the Revenue are DISMISSED

ITA 77/NAG/2022[2006-07]Status: DisposedITAT Nagpur31 Oct 2023AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

VIRAJ BALLAJI BUILDERS,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), NAGPUR

Appeals of the Revenue are DISMISSED

ITA 75/NAG/2022[2009-10]Status: DisposedITAT Nagpur31 Oct 2023AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2(1), NAGPUR vs. M/S. GUPTA GLOBAL RESOURCES PVT. LTD. , NAGPUR

Appeals of the Revenue are DISMISSED

ITA 72/NAG/2022[2012-13]Status: DisposedITAT Nagpur31 Oct 2023AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR, NAGPUR vs. M/S GUPTA GLOBAL RESOURCES PVT. LTD., NAGPUR

Appeals of the Revenue are DISMISSED

ITA 71/NAG/2022[2011-12]Status: DisposedITAT Nagpur31 Oct 2023AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR vs. M/S GUPTA COAL INDIA PVT. LTD, NAGPUR

Appeals of the Revenue are DISMISSED

ITA 70/NAG/2022[2011-12]Status: DisposedITAT Nagpur31 Oct 2023AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR vs. L/H SMT. MAYADEVI MOHANDAS MOTWANI LATE MAHESH MOHANDAS MOTWANI, AKOLA

Appeals of the Revenue are DISMISSED

ITA 67/NAG/2022[2018-19]Status: DisposedITAT Nagpur31 Oct 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), , NAGPUR vs. BHARAT TRADERS, HYDERABAD

Appeals of the Revenue are DISMISSED

ITA 66/NAG/2022[2017-18]Status: DisposedITAT Nagpur31 Oct 2023AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) Assessee Asstt Sr

Section 250Section 253(1)Section 253(2)

…similar view finds fortified ‘CIT Vs Hero Cycles’ reported in 228 ITR 463 and reiterated in ‘UCO Bank Vs CIT’ 237 ITR 889 (SC) wherein it was held that circulars binds the tax authorities strictly. Further in the case of ‘CIT Vs Nayana P. Dedhia’ reported in 270 ITR 572 the Hon’ble Andhra Pradesh High Court held that guidelines issued by Board in exercise of powers in terms of section 119 of the Act relaxing rigours of law are binding on all the officers responsible for implementation of the Act and, therefore, bound to follow & observe all circulars, orders, instructions etc. 11. Insofar as the validity of ord…

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Andhra Pradesh in CIT v. Smt. Nayana P. Dedhia (270 ITR 572) — Cited in 82 Judgments | BharatTax