Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras

14 STC 355Reported decision1963#2804 most cited

What is Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras authority for?

When a rule is substituted for an old rule, the old rule ceases to exist as the first step of the substitution process. Even if the new substituted rule is later declared invalid, the old rule does not revive.

42

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2025 to 2025.

Also referred to as

Mehtab Majid & Co. (Firm) · 14 STC 355 · 1961 Income Tax Act · Rule 16 · substitution of rule · supersession of rule · invalid new rule · old rule not revived · statutory interpretation · Section 142(2A) · Section 153A · Section 90A

Sections most often in play

Section 1961Section 142(2A)Section 143(3)Section 153ASection 153BSection 90Section 90ASection 132 of the Income Tax Act

Issues it is cited on

section 158besection 153(3)section 90aaudi alteram partemextension of limitationsection 142(2a)section 153bsection 90principal commissioner of income-taxsection 158bsection 158section 12

Judgments citing Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras

SANJAY JAIN,BHILWARA, RAJASTHAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 7, NEW DELHI

In the result, Appeal of the Assessee is allowed

ITA 1384/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Jul 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 1Section 132Section 139Section 143(1)Section 153ASection 153BSection 153DSection 250

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

SH. SUBHASH SATHE,GURGAON vs. ACIT, NEW DELHI

In the result, Appeal of the Assessee in ITA

ITA 4713/DEL/2016[2007-08]Status: HeardITAT Delhi29 May 2025AY 2007-08

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

SH. SUBHASH SATHE,GURGAON vs. ACIT, NEW DELHI

In the result, Appeal of the Assessee in ITA

ITA 4712/DEL/2016[2006-07]Status: HeardITAT Delhi29 May 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

ACIT, NEW DELHI vs. SMT. INDRANI SATHE, GURGAON

In the result, Appeal of the Assessee in ITA

ITA 4255/DEL/2016[2006-07]Status: HeardITAT Delhi29 May 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

ACIT, NEW DELHI vs. SMT. INDRANI SATHE, GURGAON

In the result, Appeal of the Assessee in ITA

ITA 3058/DEL/2016[2011-12]Status: HeardITAT Delhi29 May 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

ACIT, NEW DELHI vs. SMT. INDRANI SATHE, GURGAON

In the result, Appeal of the Assessee in ITA

ITA 3057/DEL/2016[2010-11]Status: HeardITAT Delhi29 May 2025AY 2010-11

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

ACIT, NEW DELHI vs. SMT. INDRANI SATHE, GURGAON

In the result, Appeal of the Assessee in ITA

ITA 3056/DEL/2016[2009-10]Status: HeardITAT Delhi29 May 2025AY 2009-10

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

ACIT, NEW DELHI vs. SMT. INDRANI SATHE, GURGAON

In the result, Appeal of the Assessee in ITA

ITA 3055/DEL/2016[2008-09]Status: HeardITAT Delhi29 May 2025AY 2008-09

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

ACIT, NEW DELHI vs. SMT. INDRANI SATHE, GURGAON

In the result, Appeal of the Assessee in ITA

ITA 3054/DEL/2016[2007-08]Status: HeardITAT Delhi29 May 2025AY 2007-08

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

ACIT, NEW DELHI vs. SMT. INDRANI SATHE, GURGAON

In the result, Appeal of the Assessee in ITA

ITA 3053/DEL/2016[2006-07]Status: HeardITAT Delhi29 May 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

SH. SUBHASH SATHE,GURGAON vs. ACIT, NEW DELHI

In the result, Appeal of the Assessee in ITA

ITA 2773/DEL/2016[2007-08]Status: HeardITAT Delhi29 May 2025AY 2007-08

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

SH. SUBHASH SATHE,GURGAON vs. ACIT, NEW DELHI

In the result, Appeal of the Assessee in ITA

ITA 2772/DEL/2016[2006-07]Status: DisposedITAT Delhi29 May 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 153BSection 90

…is argument ignores the distinction between supersession of a rule, and substitution of a rule. In A.T.B. Mehtab Majid & Co. (Firm) [A.T.B. 6 (2024) 8 SCC 742 ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, and it w…

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SMT. SANGEETA SAWHNEY

ITA/787/2023HC Delhi13 May 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, an…

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SMT. SANGEETA SAWHNEY

ITA/69/2024HC Delhi13 May 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, an…

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SH. PRAVEEN SAWHNEY

ITA/92/2024HC Delhi13 May 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, an…

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SMT. SANGEETA SAWHNEY

ITA/76/2024HC Delhi13 May 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, an…

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SMT. SANGEETA SAWHNEY

ITA/796/2023HC Delhi13 May 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, an…

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SMT. SANGEETA SAWHNEY

ITA/790/2023HC Delhi13 May 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, an…

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SMT. SANGEETA SAWHNEY

ITA/781/2023HC Delhi13 May 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, an…

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SMT. SANGEETA SAWHNEY

ITA/74/2024HC Delhi13 May 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…ITA No.782/2023 & Connected Cases Page 36 of 47 Mehtab Majid & Co. (Firm) v. State of Madras, (1963) 14 STC 355 : 1962 SCC OnLine SC 51] , the new Rule 16 was substituted for the old Rule 16. The process of substitution consists of two steps. First, the old rule it made to cease to exist and, next, the new rule is brought into existence in its place. Even if the new rule be invalid, the first step of the old rule ceasing to exist comes into effect, an…

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