How many judgments cite CIT v. British Paints India Ltd.?

204 judgments on BharatTax cite CIT v. British Paints India Ltd. (188 ITR 44), spanning 2008 to 2026.

Which sections of the Income Tax Act does CIT v. British Paints India Ltd. come up under?

It is most often cited in judgments turning on Section 143(3), Section 144, Section 145(3), Section 271(1)(c), Section 37(1), Section 115JB.

CIT v. British Paints India Ltd.

188 ITR 44Supreme Court of India1991#447 most cited

What is CIT v. British Paints India Ltd. authority for?

The Assessing Officer has a duty to examine whether an assessee's books of account truly disclose the correct income and is not bound to accept the accounting system regularly employed by the assessee or methods followed in earlier years. Each assessment year is a distinct and self-contained unit for tax purposes.

204

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2008 to 2026.

Also referred to as

CIT v. British Paints India Ltd. · 188 ITR 44 · Section 145 · Section 144 · Assessing Officer duty · method of accounting · books of account scrutiny · true income · assessment year distinct · valuation methods · SC 1991

Sections most often in play

Section 143(3)Section 144 Section 145(3)Section 271(1)(c)Section 37(1)Section 115JB Section 153A Section 142(1)

Read the full judgment

Issues it is cited on

section 80hhc written down value section 145 section 40(a)(i)interest u/s 234b profits and gains of business or profession section 145(3)section 127 section 115j advance tax book profits penalty u/s 271(1)(c)

Judgments citing CIT v. British Paints India Ltd.

Sweta Goenka, Jabalpur vs. Pr. Commissioner of Incomr Tax-1, Jabalpur

In the result, the assessee‟s appeal is dismissed

ITA 44/JAB/2022[2017-18]Status: DisposedITAT Jabalpur17 Aug 2022AY 2017-18

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Shri Sapan Usrethe, AdvocateFor Respondent: Shri U.B. Mishra, CIT-DR

Section 143(1)Section 143(3)Section 194CSection 263

…which we may refer to some decisions, in all of which, this plea was, and for that reason, rejected, viz. CIT v. A. Gajapathy Naidu [1964] 53 ITR 114 (SC); CIT v. Chunni Lal Mehta & Sons (P.) Ltd. [1971] 82 ITR 54 (SC); CIT v. British Paints India Ltd. [1991] 188 ITR 44 (SC)). Further, the assessee, except where it shows proper accounting for the unbilled work as the closing stock as at the year-end, valued at cost, as indeed ought to be the case (CIT v. A. Krishnaswami Mudaliar [1964] 53 ITR 122 (SC)), has, without doubt, claimed and been allowed, against the disclosed credit/receipt in her operating statement (…

Chintamani Projects Pvt.Ltd, Navi Mumbai vs. Deputy Commissioner of Income-Tax, Panvel Circle, Panvel

Appeal is dismissed in above terms

ITA 1074/PUN/2018[2012-13]Status: DisposedITAT Pune27 Jul 2022AY 2012-13

Bench: Shri S.S. Godara & Dr. Dipak P. Ripoteनिर्धारण वषा / Assessment Year : 2012-13 Chintamani Projects Pvt. Ltd., Vs. Dcit, Panvel Plot No.65, Chaintamni Corner, Circle, Panvel Service Road, Sector-20, Cbd Belapur, Navi Mumbai– 400614 Pan : Aaccc2302C Appellant Respondent

Section 143(3)

…toppel is not applicable o Income Tax proceedings as has been held by the Hon'ble Court. Not only that even the ITAT itself has held that its decision should not be treated as a precedent. 8.3 Hon'ble Supreme Court in the case of CIT vs. British Paints India 188 ITR 44 has held under: "ITO is not bound to accept system of accounting. It is not only the right but the duty of the Assessing Officer to consider whether or not the books disclose the true state of accounts and the correct income can be deduced there from. It is incorrect to say that the office is bound to accept the system of accounting regularly empl…

DCIT, Circle-25(2), New Delhi vs. Transnational Drilling & Mining Associates P.Ltd, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 844/DEL/2019[2013-14]Status: DisposedITAT Delhi08 Jul 2022AY 2013-14

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg[Assessment Year : 2013-14] Dcit, Vs Transnational Drilling & Mining Circle-25(2), Associates P.Ltd., Luv-303, New Delhi. Agarsen Awas, 66-I.P.Extention, Patparganj, New Delhi-110092. Pan-Aadct1249C Appellant Respondent Appellant By Shri Abhishek Kumar, Sr. Dr Respondent By Shri Brij Mohan Barwal, Ca Date Of Hearing 05.07.2022 Date Of Pronouncement 08.07.2022

Section 40A(3)

…rt of such valuation of closing stock, the assessee also submitted that a certificate from the supplier for certifying the useful life of such Rods. By placing reliance on the judgement of Hon’ble Supreme Court in the cases of CIT vs British Paints India Ltd. 188 ITR 44 (SC) and CIT vs MCMilan & Co. 33 ITR 182 (SC), the AO made addition as a difference in the valuation of closing stock of the assessee company. During first appellate proceedings, the Ld.AR of the assessee submitted that a detailed written submissions, justifying the changed accounting policy and also relied upon the various judgements. After consi…

M/S. S P Chips Potato Pvt. Ltd, Ahmedabad vs. DCIT, Circle-4(1)(4), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 548/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad29 Jun 2022AY 2014-15

For Appellant: Shri Sanjay R. Shah, A.RFor Respondent: Shri Anshu Prakash, CIT-D.R

Section 115JSection 143Section 263

…examining the records came to conclusion and took a view that receipts at the hand of assessee was to be assessed under income from house property and income from other sources and not business income. In CIT v. British Paints India Ltd., [1991] 54 Taxman 499/188 ITR 44 (SC) Supreme Court while interpreting Section 145 of the Act held that even if the assessee had adopted a regular system of accounting, it was the duty of the Assessing Officer to consider whether correct profits and gains would be deduced from the account so maintained. 6.1 On the principles of res judicata, the Supreme Court in the case of Muni…

Tarpawankumar Ramprasad Sandhir, Ahmedabad vs. The ITO, Ward-1(3)(5), Ahmedabad

In the result, the appeal filed by the assessee is allowed to the extent indicated above

ITA 1858/AHD/2019[2016-17]Status: DisposedITAT Ahmedabad22 Apr 2022AY 2016-17

For Appellant: NoneFor Respondent: Shri R.R. Makwana, Sr. DR

Section 143(2)Section 143(3)Section 271(1)(c)

…not changed. The expenditure have to be in consonance to turnover. It is unfair to the department not to get even single paisa in taxes in turnover of crores of Rupees (Rs. 27.93 crores). Hon'ble Supreme Court in the case of CIT vs. British Paints India Ltd. 188 ITR 44 (SC) has held that, "it is duty of AO to correctly deduce the income, no principle of estoppels as AO is not bound by the method followed in earlier years." Therefore, the decision of the AO gets support from the ratio laid down by the Hon'ble Supreme Court. The decision also gets support from CIT v/s. Saatal Kattha and Chemicals Pvt. Ltd. 296 ITR…

ACIT, Uttrakhand vs. M/S. Uttaranchal Jal Vidyut Nigam Ltd., Dehradun

In the result, the appeal filed by the Revenue is dismissed

ITA 736/DEL/2017[2012-13]Status: DisposedITAT Dehradun24 Dec 2021AY 2012-13

Bench: Shri R.K. Panda & Shri Challa Nagendra Prasadassessment Year: 2012-13 Acit, Vs. Uttaranchal Jal Vidyut Circle-2, Nigam Ltd., 13-A, Subhash Road, Ujjwal, Maharani Bagh, Uttarakhand. Gms Road, Dehradun. Pan: Aaacu6672R (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate & Shri Somil Aggarwal, Advocate Revenue By : Smt. Poonam Sharma, Sr. Dr Date Of Hearing : 22.12.2021 Date Of Pronouncement : 24.12.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Revenue Is Directed Against The Order Dated 29Th December, 2016 Of The Cit(A), Dehradun, Relating To Assessment Year 2012-13. 2. The Only Effective Ground Raised By The Revenue Reads As Under:- “1. The Ld.Cit(A) Has Erred In Law & On Facts By Allowing Depreciation On Assets For Which The Actual Cost As Per Section 43(1) Of The Income Tax Act, 1961 Was Nil. 2. The Order Of The Ld.Cit(Appeals) Be Set Aside & That Of The Assessing Officer Be Restored.”

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Smt. Poonam Sharma, Sr. DR

Section 143(3)Section 2Section 32Section 43Section 43(1)

…sessee. Admittedly, the assessee was following mercantile system of accounting and was free to choose any of the two methods of accounting provided true income can be ascertained out of it and the same method is consistently followed [(CIT vs. British Paints (188 ITR 44, SC), (CIT vs. Realest Builders & Services Ltd. 216 CTR 345 (SC)]. 6.1 It was submitted that the law does not lay down what is proper method of accounting. However, what is mandated is that such system and method of accounting should comply with the accounting standards notified by the Government. It was further pointed out that the Government ha…

The ACIT, Bharuch Circle, Bharuch vs. Bharuch Enviro Infrastructure Ltd., Ankleshwar

In the result, this ground of appeal is allowed for statistical purpose

ITA 1867/AHD/2014[2008-09]Status: DisposedITAT Surat24 Dec 2021AY 2008-09

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 254(1)Section 44ASection 80I

…uring the year pertaining to the burning of sludge or keeping it in godown, but the income is deferred to future period, which is not tenable and against the provisions of law and as held by Hon'ble Apex Court decision in the case of British Paints India Ltd. 188 ITR 44, any system of accounting results in distorted picture of the true state of affairs of the business for the purpose of computing the chargeable income, the AO may modify the same.” 14. We have heard the submissions of Ld. Senior Counsel (AR), Saurabh N Soparkar and assisted by Shri Parin Shah, Advocate for assessee and Shri Deependra Kumar, Ld. Sr…

Bharuch Enviro Infrastructure Ltd., Bharuch vs. The Dy.CIT., Bharuch Circle, Bharuch

In the result, this ground of appeal is allowed for statistical purpose

ITA 1849/AHD/2014[2008-09]Status: DisposedITAT Surat24 Dec 2021AY 2008-09

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 254(1)Section 44ASection 80I

Conwood Realty P. Ltd., Mumbai vs. Dy CIT -Circle-12(1)(2), Mumbai

ITA 727/MUM/2021[2012-13]Status: DisposedITAT Mumbai26 Oct 2021AY 2012-13

Bench: Shri Rajesh Kumar () & Shri Ravish Sood () M/S Conwood Realty Pvt. Ltd. Dy. Cit, Circle-12(1)(2) Yashodham, D.B. House, Gen. Vs. Aayakar Bhavan, 2Nd Floor, A.K. Vaidya Marg, Goregaon M.K. Road, Mumbai 400020 (East), Mumbai – 400063 Pan No. Aadcc2501Q (Assessee) (Revenue) C.O. No. 55/Mum/2021 (Arising Out Of Ita No. 6447/Mum/2019) (Assessment Year: 2012-13) Acit, Circle-12(1)(2) M/S Conwood Realty Pvt. Ltd. R. No. 128D, 1St Floor, Aayakar Vs. Yashodham, D.B. House, Gen. Bhavan, Churchgate, A.K. Vaidya Marg, Goregaon Mumbai 400020 (East), Mumbai – 400063 Pan No. Aadcc2501Q (Revenue) (Assessee) Assessee By : Shri Prakash Jhunjhunwala, A.R Revenue By : Ms. Shreekala Pardeshi, D.R Date Of Hearing : 29/07/2021 Date Of Pronouncement : 26/10/2021

For Appellant: Shri Prakash Jhunjhunwala, A.RFor Respondent: Ms. Shreekala Pardeshi, D.R

Section 143(1)Section 143(2)Section 143(3)Section 36(1)(iii)

…y Ltd. Vs. CIT (1971) 82 ITR 365 (SC) the accounting entries made by an assessee are not conclusive for the purpose of determining its entitlement for claim of an expenditure. Also the Hon‟ble Supreme Court in the case of CIT Vs. British Paints Limited (1991) 188 ITR 44 (SC), has held, that it is not only the right but the duty of the Assessing Officer to act in exercise of his statutory power and reject the accounting system adopted by the assessee for determining what, ITA No.727/Mum/2021 & 6447/Mum/2019 & C.O. 55/M/2021 16 M/s Conwood Realty Pvt. Ltd. Vs. DCIT, Circle 12(1)(2) in his opinion, is the correct…

Assistant Commissioner of Income Tax Circle-1, Bellary vs. Shri Vazhyiel House Narayanan Kutty Menon, Bellary

In the result, the revenue’s appeal is partly allowed for statistical purposes

ITA 1545/BANG/2018[2014-15]Status: DisposedITAT Bangalore05 Oct 2021AY 2014-15

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year : 2014-15

For Appellant: Shri B.K. Singh, CIT(DR)(ITAT), BengaluruFor Respondent: Shri B.S. Balachandran, Advocate

…(1965) 56 ITR 42 (SC) / CIT v. A.B.V Gowda (1986) 157 ITR 697 (Kar). Each year being a self contained unit, taxes of particular year is payable with reference to the income of that year as computed in terms of the Act - CIT Vs. British Paints India Ltd. (SC) 188 ITR 44. Accordingly, a sum equivalent to e-auction sale proceeds accrued / arised to the assessee for the financial year ending 31/03/2013 should be assessed in the relevant assessment year which is under consideration Hence, the entire E-auction Page 14 of 27 sales proceeds of Rs.50,24,48,441/- (Rs.25,59,99,429/- + Rs.24,64,49,012/-) claimed as expendi…

DCIT 6(2)(1), Mumbai vs. Ceat Ltd, Mumbai

In the result, appeal of the assessee is allowed, and departmental appeal is treated as infructuous

ITA 673/MUM/2017[2008-09]Status: DisposedITAT Mumbai22 Sept 2021AY 2008-09

Bench: Shri Shamim Yahya, Am & Shri Pavan Kumar Gadale, Jm Dcit-6(2)(1) M/S. Ceat Ltd. Room No.563, Aaykar Bhawan Rpg House, 463 M.K.Road, Churchgate Vs. Dr. Annie Besant Road, Worli Mumbai-400 020 Mumbai-400 030

For Appellant: Shri Vijay MehtaFor Respondent: Shri V. Sreekar & Shri Manprit Duggal

Section 143(3)Section 147Section 148Section 2Section 47

…terest on refund under section 244A would get substituted in terms of sub-section (3) of section 244A without affecting right already accrued. Further, the judgment of the Supreme Court rendered in the case of CIT v. Chunilal V. Mehta & Sons (P.) Ltd. [1971] 82 ITR 54 clearly shows that once a right accrues under an agreement, then such accrual is not affected by dispute between the parties. Further, in case of dispute, the final outcome would ultimately relate back to the year of accrual. It was also contended by the assessee that it would be without remedy if the interest was reduced by virtue of assessment un…

Dy. Commissioner of Income Tax, Circle-1(2), Hyderabad vs. Blend Colours Private Limited, Hyderabad

In the result, the appeal of the revenue in ITA No

ITA 1185/HYD/2019[2015-16]Status: DisposedITAT Hyderabad22 Jul 2021AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2015-16 Blend Colours Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Circle – 1(2), Pan – Aaccb 2492 A Hyderabad. (Appellant) (Respondent) Assessment Year: 2015-16 Dy. Commissioner Of Vs Blend Colours Pvt. Ltd., Income-Tax, Hyderabad. Circle – 1(2), Hyderabad. Pan – Aaccb 2492 A (Appellant) (Respondent) Assessee By: Shri Sidharth Toshnival Revenue By: Shri A. Sitarama Rao Date Of Hearing: 05/07/2021 Date Of Pronouncement: 22/07/2021

For Appellant: Shri Sidharth ToshnivalFor Respondent: Shri A. Sitarama Rao

Section 115JSection 143(2)Section 143(3)

…13 ITR 24], the Hon'ble Supreme Court has held that where question of law is involved, the rule of consistency will not prevail. Similar observations were made by Hon'ble apex court in 313 ITR 363; 307 ITR 338; 300 ITR. Further, in the case of British Paints [188 ITR 44], the Hon'ble Supreme Court has held that there cannot be estoppel against the law. Similar view was held that there cannot be estoppel against the law. Similar view was held in the cases of Luchi Ram Puranmal [177 CTR 640 (MP)]; Foss Electric 263 ITR 125] and Distributors of Baroda [118 ITR 243]. The Hon'ble Delhi High Court in CWT v. Meattles (P…

Blend Colours Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-1(2), Hyderabad

In the result, the appeal of the revenue in ITA No

ITA 1137/HYD/2019[2015-16]Status: DisposedITAT Hyderabad22 Jul 2021AY 2015-16

For Appellant: Shri Sidharth ToshnivalFor Respondent: Shri A. Sitarama Rao

Section 115JSection 143(2)Section 143(3)

The Commissioner of Income Tax, Trichur vs. The South Indian Bank Ltd., Trichur

Appeal stands dismissed

ITA/178/2009HC Kerala13 Jul 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR. JUSTICE BECHU KURIAN THOMAS

Section 260ASection 36(1)Section 36(1)(viia)Section 36(2)

…IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR. JUSTICE BECHU KURIAN THOMAS TUESDAY, THE 13TH DAY OF JULY 2021 / 22ND ASHADHA, 1943 ITA NO. 178 OF 2009 AGAINST THE ORDER IN ITA 113/1996 OF I.T.A.TRIBUNAL,COCHIN BENCH, ERNAKULAM APPELLANT/S: THE COMMISSIONER OF INCOME TAX, TRICHUR. BY ADV SRI.JOSE JOSEPH, SC, FOR INCOME TAX RESPONDENT/S: THE SOUTH INDIAN BANK LTD.,. TRICHUR. BY ADVS. SRI.JOSEPH MARKOSE (SR.) SRI.V.ABRAHAM MARKOS SRI.ABRAHAM JOSEPH MARKOS SRI.ISAAC THOMAS SHRI.ALEXANDER JOSEPH MARKOS SHRI.SHARAD JOSEPH KODANTHARA THIS INCOME TAX APPEAL HAVI…

Daawat Foods Ltd., New Delhi vs. ACIT, New Delhi

Appeal are dismissed

ITA 4159/DEL/2013[2009-10]Status: DisposedITAT Delhi07 Jun 2021AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing)

Section 132Section 142Section 143(3)Section 14ASection 40Section 40A(3)Section 69Section 80I

…en approved/accepted for the purpose of the computing the taxable income by various Courts and Tribunals from time to time. In this context, the decisions of the Apex Court in case of Chainrup Sampatram vs. CIT 24 ITR 481 and CIT vs. British Paints India Ltd. 188 ITR 44 (SC) along with United Commercial Bank vs. CIT 240 ITR 355 (SC) relied by the Ld. AR are applicable in the present case. Further, there is no evidence for undisclosed sale which was pointed out by the Assessing Officer or by the CIT(A) in their respective orders. Thus, the addition made by the Assessing Officer which was confirmed by the CIT(A) do…

DCIT, New Delhi vs. M/S Daawat Foods Ltd., New Delhi

Appeal are dismissed

ITA 4042/DEL/2013[2009-10]Status: DisposedITAT Delhi07 Jun 2021AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing)

Section 132Section 142Section 143(3)Section 14ASection 40Section 40A(3)Section 69Section 80I

Novartis India Ltd, Mumbai vs. DCIT Cir 7(1), Mumbai

Appeal stand partly allowed

ITA 3379/MUM/2009[2001-02]Status: HeardITAT Mumbai30 Apr 2021AY 2001-02

For Appellant: Shri Jehangir D. Mistry (Ld. SrFor Respondent: Shri Salil Mishra-CIT DR and Shri Tharian Oommen-Ld. Sr. DR

Section 115JSection 143(3)

…portionate amount of freight component while valuing closing stock of finished goods. As against this, the assessee claimed full expenditure of freight as deduction. The AO opined that as per the decision of Hon'ble Apex Court in CIT Vs. British Paints (1991; 188 ITR 44), it is the real cost of stock which was to be taken into account to determine real income of the assessee. All costs incurred towards stock-in-trade were to be considered while valuing the closing stock and exclusion of any cost would result in distorted picture of taxable income. The freight component on closing stock came to be Rs.44.09 Lacs. H…

M/S. Monarch Plaza Comforts Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-4(1)(2), Bengaluru

In the result appeal filed by assessee stands partly allowed

ITA 1644/BANG/2018[2011-12]Status: DisposedITAT Bangalore23 Mar 2021AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiita No.1644 & 1645/Bang/2018 Assessment Year : 2011-12 & 2012-13

For Appellant: Shri S Ramsubramanyan, C.AFor Respondent: Smt. R Premi, JCIT (DR)

Section 143(2)Section 147Section 148Section 148(2)Section 40

…1645/Bang/2018 vis-a-vis the method of accounting adopted by assessee in the previous assessment year or the immediately succeeding assessment year. 20. We rely on the decision of Hon’ble Supreme Court in case of CIT vs British Paints India Ltd., reported in 188 ITR 44. In this case, Hon’ble Supreme Court observed that assessee was valuing the work in progress and finished products at raw material cost by excluding other overriding expenditure. Hon’ble Supreme Court, held the method adopted by assessee therein was not acceptable, as it was not recognised method. 21. Further, we note that the method adopted by th…

M/S. Veerabhadrappa Sangappa & Company, Sandur vs. The Assistant Commissioner of Income Tax, Circle- 1, Bellary

In the result appeal filed by assessee stands partly allowed

ITA 1054/BANG/2019[2013-14]Status: DisposedITAT Bangalore08 Dec 2020AY 2013-14

Bench: Shri. B. R. Baskaran & Smt. Beena Pillaiassessment Year : 2013–14

For Appellant: Shri Chythanya K.K, AdvocateFor Respondent: Shri Muzaffar Hussain, CIT

Section 145Section 28Section 5

…(1965) 56 ITR 42 (SC) / CIT v. A.B.V Gowda (1986) 157 ITR 697 (Kar). Each year being a self contained unit, taxes of particular year is payable with reference to the income of that year as computed in terms of the Act - CIT Vs. British Paints India Ltd. (SC) 188 ITR 44. Accordingly, a sum equivalent to e-auction sale proceeds accrued / arised to the assessee for the financial year ending 31/03/2013 should be assessed in the relevant assessment year which is under consideration Hence, the entire E-auction sales proceeds of Rs.50,24,48,441/- (Rs.25,59,99,429/- + Rs.24,64,49,012/-) claimed as expenditure / deductio…

M/S. Safina Hotels Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(1)(1), Bangalore

In the result, the appeal of the assessee is allowed

ITA 2512/BANG/2019[2016-17]Status: DisposedITAT Bangalore09 Nov 2020AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojarim/S. Safina Hotels Pvt. Ltd., 84/85, Safina Plaza, Infantry Road, Bangalore-560 001 ….Appellant Pan Aaccs 5146G Vs. Dy. Commissioner Of Income Tax, Circle 6(1)(1), Bangalore. ……Respondent. Assessee By: Shri Tata Krishna, Advocate. Revenue By: Shri Kannan Narayanan, Jcit(D.R)

For Appellant: Shri Tata Krishna, AdvocateFor Respondent: Shri Kannan Narayanan, JCIT(D.R)

Section 143(2)Section 143(3)Section 32Section 37

…(SC); ii. Sasson J.David 8& Co. P.Ltd. v. CIT (1979) 118 ITR 261 (SC); iii. CIT vs. Walchand and Co. (P.) Ltd., [ 1967] 65 ITR 381(SC); iv. CIT vs. Panipat Woollen 8v General Mills Co. Ltd., [ 1976] 103 ITR 66(SC) v. CIT v. British Paints India Ltd. [1991] 188 ITR 44 (SC) vi. Vipin Kumar Khanna v. CIT [2001] 251 ITR 7822 (Delhi) vii. CIT vs. Dalmia Cement P. Ltd., (2002) 254 ITR 377(Del) viii. PCIT v. Reebok India Company [2018] 409 ITR 587 (Delhi) ix. CIT v. Raghuvir Synthetics Ltd [2013] 354 ITR 222 (Gujarat) x. Q PCIT v. Chain House International (P.) Ltd. [2018] 98 taxmann.com 47 (Madhya Pradesh) xi. Jo…