CIT v. Calcutta Knitwears

362 ITR 673Supreme Court of India2014#122 most cited

What is CIT v. Calcutta Knitwears authority for?

The recording of a satisfaction note by the Assessing Officer is a jurisdictional prerequisite for assessments under Section 153C, and the six-year limitation period for such assessments is reckoned from the date this satisfaction is recorded.

528

judgments rely on this decision, according to BharatTax’s citation analysis of 367,357 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Calcutta Knitwears · section 153C · satisfaction note · jurisdictional prerequisite · limitation period · seized material · assessment year · block period · search assessment · section 158BD

Also reported as

43 Taxmann.com 446223 Taxmann 115

Sections most often in play

Section 153CSection 143(3)Section 132Section 153ASection 153DSection 144Section 115BBESection 292C
Read the full judgment

Issues it is cited on

section 158bdincome tax settlement commissionsection 158bcsection 144asection 144basatisfaction notesection 158bblock periodsection 158section 153c(1)documents seizedsection 292c

Judgments citing CIT v. Calcutta Knitwears

Sanjana, Allahabad vs. ITO, Ward-1(5), Allahabad

The appeals are partly allowed

ITA 54/ALLD/2023[2016-17]Status: DisposedITAT Allahabad31 Oct 2025AY 2016-17

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

…4/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 74 of 79 statute has to be construed strictly even if its interpretation results in hardship or inconvenience and the Hon'ble Apex Court has held in the case of CIT vs. Calcutta Knitwears reported in [2014] 362 ITR 673 (SC) that common sense approach, equity, logic, ethics and morality have no role to play. Similarly the Hon'ble Apex Court in the case of CIT vs. Vadilal Lallubhai, etc. reported in [1972] 86 ITR 2(SC) held that it is not permissible to construe any provision of a statute much lesser taxing provision by reading into much more words than necessary…

Sanjana, Allahabad vs. ITO, Ward- 1 (5), Allahabad

The appeals are partly allowed

ITA 53/ALLD/2023[2015-16]Status: DisposedITAT Allahabad31 Oct 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

…4/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 74 of 79 statute has to be construed strictly even if its interpretation results in hardship or inconvenience and the Hon'ble Apex Court has held in the case of CIT vs. Calcutta Knitwears reported in [2014] 362 ITR 673 (SC) that common sense approach, equity, logic, ethics and morality have no role to play. Similarly the Hon'ble Apex Court in the case of CIT vs. Vadilal Lallubhai, etc. reported in [1972] 86 ITR 2(SC) held that it is not permissible to construe any provision of a statute much lesser taxing provision by reading into much more words than necessary…

Sanjana, Allahabad vs. ITO, Ward- 1 (5), Allahabad

The appeals are partly allowed

ITA 52/ALLD/2023[2014-15]Status: DisposedITAT Allahabad31 Oct 2025AY 2014-15

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

…4/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 74 of 79 statute has to be construed strictly even if its interpretation results in hardship or inconvenience and the Hon'ble Apex Court has held in the case of CIT vs. Calcutta Knitwears reported in [2014] 362 ITR 673 (SC) that common sense approach, equity, logic, ethics and morality have no role to play. Similarly the Hon'ble Apex Court in the case of CIT vs. Vadilal Lallubhai, etc. reported in [1972] 86 ITR 2(SC) held that it is not permissible to construe any provision of a statute much lesser taxing provision by reading into much more words than necessary…

Sanjana, Allahabad vs. ITO, Ward- 1(5), Allahabad

The appeals are partly allowed

ITA 51/ALLD/2023[2013-14]Status: DisposedITAT Allahabad31 Oct 2025AY 2013-14

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

…4/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 74 of 79 statute has to be construed strictly even if its interpretation results in hardship or inconvenience and the Hon'ble Apex Court has held in the case of CIT vs. Calcutta Knitwears reported in [2014] 362 ITR 673 (SC) that common sense approach, equity, logic, ethics and morality have no role to play. Similarly the Hon'ble Apex Court in the case of CIT vs. Vadilal Lallubhai, etc. reported in [1972] 86 ITR 2(SC) held that it is not permissible to construe any provision of a statute much lesser taxing provision by reading into much more words than necessary…

Sanjana, Allahabad vs. ITO, Ward-1(5), Allahabad

The appeals are partly allowed

ITA 50/ALLD/2023[2012-13]Status: DisposedITAT Allahabad31 Oct 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

…4/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 74 of 79 statute has to be construed strictly even if its interpretation results in hardship or inconvenience and the Hon'ble Apex Court has held in the case of CIT vs. Calcutta Knitwears reported in [2014] 362 ITR 673 (SC) that common sense approach, equity, logic, ethics and morality have no role to play. Similarly the Hon'ble Apex Court in the case of CIT vs. Vadilal Lallubhai, etc. reported in [1972] 86 ITR 2(SC) held that it is not permissible to construe any provision of a statute much lesser taxing provision by reading into much more words than necessary…

Yogi Satyam, Allahabad vs. ITO, Ward- 1 (5), Allahabad

The appeals are partly allowed

ITA 5/ALLD/2023[2012-13]Status: DisposedITAT Allahabad31 Oct 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Dr. Pawan Jaiswal and Shri AjitFor Respondent: Shri A. K. Singh, D.R
Section 143(3)Section 147Section 148

…4/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 74 of 79 statute has to be construed strictly even if its interpretation results in hardship or inconvenience and the Hon'ble Apex Court has held in the case of CIT vs. Calcutta Knitwears reported in [2014] 362 ITR 673 (SC) that common sense approach, equity, logic, ethics and morality have no role to play. Similarly the Hon'ble Apex Court in the case of CIT vs. Vadilal Lallubhai, etc. reported in [1972] 86 ITR 2(SC) held that it is not permissible to construe any provision of a statute much lesser taxing provision by reading into much more words than necessary…

Anoop Jain HUF, Delhi vs. Joint Commissioner of Income Tax (OSD), Central Circle - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4043/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

…ITA No.4038/Del/2018 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2013-14] Ritu Jain vs JCIT (OSD) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida PAN-AAMPJ9586C APPELLANT RESPONDENT [Assessment Year : 2013-14] Anoop Jain vs JCIT (OSD) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida PAN-AADPJ2136K APPELLANT RESPONDENT [Assessment Year : 2013-14] Anoop Jain HUF vs JCIT (OSD) No.11, Barbar Lane, Bengali Central Circle-1, Mark…

Anoop Jain, Delhi vs. Joint Commissioner of Income Tax (OSD), Central Circle - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4042/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

…ITA No.4038/Del/2018 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2013-14] Ritu Jain vs JCIT (OSD) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida PAN-AAMPJ9586C APPELLANT RESPONDENT [Assessment Year : 2013-14] Anoop Jain vs JCIT (OSD) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida PAN-AADPJ2136K APPELLANT RESPONDENT [Assessment Year : 2013-14] Anoop Jain HUF vs JCIT (OSD) No.11, Barbar Lane, Bengali Central Circle-1, Mark…

Ritu Jain, Delhi vs. Joint Commissioner of Income Tax (OSD), CC - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4038/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

…ITA No.4038/Del/2018 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI “G” BENCH: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2013-14] Ritu Jain vs JCIT (OSD) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida PAN-AAMPJ9586C APPELLANT RESPONDENT [Assessment Year : 2013-14] Anoop Jain vs JCIT (OSD) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida PAN-AADPJ2136K APPELLANT RESPONDENT [Assessment Year : 2013-14] Anoop Jain HUF vs JCIT (OSD) No.11, Barbar Lane, Bengali Central Circle-1, Mark…

M/S Good Living Shelters Pvt Ltd, Mumbai vs. Assistant Commissioner of Income Tax-12(2)(2), Mumbai

In the result all three appeals filed by the assessee are allowed

ITA 1611/MUM/2024[2009-10]Status: DisposedITAT Mumbai28 Oct 2025AY 2009-10

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Ms. Padmavathy S, Hon’Ble

For Appellant: S/Shri Subhash Chhajed & Sunil WakawalaFor Respondent: Shri Arun Kanti Datta -CIT DR
Section 132Section 143(1)Section 143(3)Section 153CSection 69A

…ng Officer of the assessee to have separately examined the matter and independently recorded a satisfaction note of which there is no mention in the assessment order. Reliance is placed on the decision of the Supreme Court in M/s Calcutta Knitwears, Ludhiana (362 ITR 673) and the CBDT circular no. 24/2015 dated 31.12.2015. It is submitted that inspite of grant of sufficient time Revenue has been unable to produce any such satisfaction note. 10. Without prejudice to the above legal contentions, the learned AR made an alternative submission that the appeal may be remitted back to the learned CIT(A) considering tha…

M/S Good Living Shelters Pvt Ltd, Mumbai vs. Assistant Commissioner of Income Tax-12(2)(2), Mumbai

In the result all three appeals filed by the assessee are allowed

ITA 1610/MUM/2024[2010-11]Status: DisposedITAT Mumbai28 Oct 2025AY 2010-11

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Ms. Padmavathy S, Hon’Ble

For Appellant: S/Shri Subhash Chhajed & Sunil WakawalaFor Respondent: Shri Arun Kanti Datta -CIT DR
Section 132Section 143(1)Section 143(3)Section 153CSection 69A

…ng Officer of the assessee to have separately examined the matter and independently recorded a satisfaction note of which there is no mention in the assessment order. Reliance is placed on the decision of the Supreme Court in M/s Calcutta Knitwears, Ludhiana (362 ITR 673) and the CBDT circular no. 24/2015 dated 31.12.2015. It is submitted that inspite of grant of sufficient time Revenue has been unable to produce any such satisfaction note. 10. Without prejudice to the above legal contentions, the learned AR made an alternative submission that the appeal may be remitted back to the learned CIT(A) considering tha…

M/S Good Livilng Shelters Pvt Ltd, Mumbai vs. Assistant Commissioner of Income Tax 12(2)(2), Mumbai

In the result all three appeals filed by the assessee are allowed

ITA 1609/MUM/2024[2008-09]Status: DisposedITAT Mumbai28 Oct 2025AY 2008-09

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Ms. Padmavathy S, Hon’Ble

For Appellant: S/Shri Subhash Chhajed & Sunil WakawalaFor Respondent: Shri Arun Kanti Datta -CIT DR
Section 132Section 143(1)Section 143(3)Section 153CSection 69A

…ng Officer of the assessee to have separately examined the matter and independently recorded a satisfaction note of which there is no mention in the assessment order. Reliance is placed on the decision of the Supreme Court in M/s Calcutta Knitwears, Ludhiana (362 ITR 673) and the CBDT circular no. 24/2015 dated 31.12.2015. It is submitted that inspite of grant of sufficient time Revenue has been unable to produce any such satisfaction note. 10. Without prejudice to the above legal contentions, the learned AR made an alternative submission that the appeal may be remitted back to the learned CIT(A) considering tha…

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Chitravel Vetrimaran, Chennai

ITA 905/CHNY/2025[2019-20]Status: DisposedITAT Chennai22 Oct 2025AY 2019-20
Section 132Section 142(1)Section 143(2)Section 153ASection 153CSection 250Section 271D

…nitiating proceedings u/s.153C, recording of a valid satisfaction note is mandatory and in the absence of the same, the entire proceedings would be void ab-initio. The same was held by the Hon'ble Supreme Court in the case of CIT vs. Calcutta Knitwears [2014] 362 ITR 673 (SC). Wherein the Hon'ble Apex Court had at paragraph 44 of its order held that; "44. In the result, we hold that for the purpose of Section 158BD of the Act a satisfaction note is sine qua non and must be prepared by the assessing officer before he transmits the records to the other assessing officer who has jurisdiction over such other person."…

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Chitravel Vetrimaran, Chennai

ITA 904/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Oct 2025AY 2017-18
Section 132Section 142(1)Section 143(2)Section 153ASection 153CSection 250Section 271D

…nitiating proceedings u/s.153C, recording of a valid satisfaction note is mandatory and in the absence of the same, the entire proceedings would be void ab-initio. The same was held by the Hon'ble Supreme Court in the case of CIT vs. Calcutta Knitwears [2014] 362 ITR 673 (SC). Wherein the Hon'ble Apex Court had at paragraph 44 of its order held that; "44. In the result, we hold that for the purpose of Section 158BD of the Act a satisfaction note is sine qua non and must be prepared by the assessing officer before he transmits the records to the other assessing officer who has jurisdiction over such other person."…

Shri Vinay Pratap Singh, Lucknow vs. Astt. Commissioner of Income Tax, Lucknow

In the result, the appeal of the assessee is partly allowed

ITA 688/LKW/2015[2012-13]Status: DisposedITAT Lucknow17 Oct 2025AY 2012-13

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Swarn Singh, C.AFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 132Section 143(3)Section 153CSection 153D

…IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW ‘A’ BENCH, LUCKNOW BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT MEMBER A.Y. 2012-13 Shri Vinay Pratap Singh, vs. Asstt. Commissioner of Income 18/57, Block-C, Indira Nagar, Tax, Central Circle-I, Lucknow Lucknow-226016 PAN: AWEPS9823P (Appellant) (Respondent) Assessee by: Sh. Swarn Singh, C.A. Revenue by: Sh. R.K. Agarwal, CIT DR Date of hearing: 31.07.2025 Date of pronouncement: 17.10.2025 O R D E R PER NIKHIL CHOUDHARY, A.M.: [ This is an appeal filed by the assessee against the orders of the ld. CIT(A)- 3, Lucknow dated 21…

Jeevan Jyoti Infrastructure Company Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 56/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Minto Colonizers Private Limited, Allahabad vs. DCIT Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 54/ALLD/2025[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Deputy Commissioner of Income Tax, Allahabad vs. Navjeevan Pediatrics Private Limited, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 44/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Deputy Commissioner of Income Tax (Central Circle), Allahabad vs. Jeevan Jyoti Charitable Trust, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 41/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…

Deputy Commissioner of Income Tax, Allahabad vs. Jeevan Jyoti Charitable Trust, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 40/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…be given effect of the word in its own terms and there is no scope for importing any rule of interpretation. Learned Departmental Representatives also placed reliance on the precedents in the cases of 438 ITR 288 (SC) CIT vs. Mohammed Meeran Shahul Hameed and 362 ITR 673 (SC) CIT vs. Calcutta Knitwears for the proposition that a provision of the Act is to be read as it is and nothing is to be added or taken away from it. Learned Departmental Representatives placed further reliance on 266 ITR 1 (SC) Prakash Nath Khanna vs CIT and 121 ITR 535 (SC) CIT vs. National Taj Traders for the proposition that casus omissus…