CIT v. G.M. Mittal Stainless Steell (P) ltd.

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…4 ITR 121 (Chennai) CIT vs. Mepco Industries Ltd. viii) 303 ITR 23 (P&H) CIT vs. Munjal Castings ix) 321 ITR 92 (Bom) Grasim Industries Ltd. vs. CIT x) 325 ITR 343 (P&H) CIT vs. Tek Chand Saini xi) 333 ITR 547 (Del) CIT vs. Honda Siel Power Products Ltd. xii) 263 ITR 255 (SC) CIT vs. G.M. Mittal Stainless Steel Ltd. PROPOSITION IV: THAT IT IS NECESSARY FOR COMMISISONER OF INCOME TAX TO POINT OUT THE MATERIAL ON RECORD AS TO HOW THE ORDER OF AO IS PREJUDICIAL TO THE INTEREST OF REVENUE i) 142 ITR 778 (Pat) CIT vs. Shanti Lal Aggarwala ii) 96 ITR 310 (All) CIT vs. Late Sunder Lal iii) 111 ITR 326 (All) J.P. Srivast…

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…4 ITR 121 (Chennai) CIT vs. Mepco Industries Ltd. viii) 303 ITR 23 (P&H) CIT vs. Munjal Castings ix) 321 ITR 92 (Bom) Grasim Industries Ltd. vs. CIT x) 325 ITR 343 (P&H) CIT vs. Tek Chand Saini xi) 333 ITR 547 (Del) CIT vs. Honda Siel Power Products Ltd. xii) 263 ITR 255 (SC) CIT vs. G.M. Mittal Stainless Steel Ltd. PROPOSITION IV: THAT IT IS NECESSARY FOR COMMISISONER OF INCOME TAX TO POINT OUT THE MATERIAL ON RECORD AS TO HOW THE ORDER OF AO IS PREJUDICIAL TO THE INTEREST OF REVENUE i) 142 ITR 778 (Pat) CIT vs. Shanti Lal Aggarwala ii) 96 ITR 310 (All) CIT vs. Late Sunder Lal iii) 111 ITR 326 (All) J.P. Srivast…

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…4 ITR 121 (Chennai) CIT vs. Mepco Industries Ltd. viii) 303 ITR 23 (P&H) CIT vs. Munjal Castings ix) 321 ITR 92 (Bom) Grasim Industries Ltd. vs. CIT x) 325 ITR 343 (P&H) CIT vs. Tek Chand Saini xi) 333 ITR 547 (Del) CIT vs. Honda Siel Power Products Ltd. xii) 263 ITR 255 (SC) CIT vs. G.M. Mittal Stainless Steel Ltd. PROPOSITION IV: THAT IT IS NECESSARY FOR COMMISISONER OF INCOME TAX TO POINT OUT THE MATERIAL ON RECORD AS TO HOW THE ORDER OF AO IS PREJUDICIAL TO THE INTEREST OF REVENUE i) 142 ITR 778 (Pat) CIT vs. Shanti Lal Aggarwala ii) 96 ITR 310 (All) CIT vs. Late Sunder Lal iii) 111 ITR 326 (All) J.P. Srivast…

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…4 ITR 121 (Chennai) CIT vs. Mepco Industries Ltd. viii) 303 ITR 23 (P&H) CIT vs. Munjal Castings ix) 321 ITR 92 (Bom) Grasim Industries Ltd. vs. CIT x) 325 ITR 343 (P&H) CIT vs. Tek Chand Saini xi) 333 ITR 547 (Del) CIT vs. Honda Siel Power Products Ltd. xii) 263 ITR 255 (SC) CIT vs. G.M. Mittal Stainless Steel Ltd. PROPOSITION IV: THAT IT IS NECESSARY FOR COMMISISONER OF INCOME TAX TO POINT OUT THE MATERIAL ON RECORD AS TO HOW THE ORDER OF AO IS PREJUDICIAL TO THE INTEREST OF REVENUE i) 142 ITR 778 (Pat) CIT vs. Shanti Lal Aggarwala ii) 96 ITR 310 (All) CIT vs. Late Sunder Lal iii) 111 ITR 326 (All) J.P. Srivast…

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…4 ITR 121 (Chennai) CIT vs. Mepco Industries Ltd. viii) 303 ITR 23 (P&H) CIT vs. Munjal Castings ix) 321 ITR 92 (Bom) Grasim Industries Ltd. vs. CIT x) 325 ITR 343 (P&H) CIT vs. Tek Chand Saini xi) 333 ITR 547 (Del) CIT vs. Honda Siel Power Products Ltd. xii) 263 ITR 255 (SC) CIT vs. G.M. Mittal Stainless Steel Ltd. PROPOSITION IV: THAT IT IS NECESSARY FOR COMMISISONER OF INCOME TAX TO POINT OUT THE MATERIAL ON RECORD AS TO HOW THE ORDER OF AO IS PREJUDICIAL TO THE INTEREST OF REVENUE i) 142 ITR 778 (Pat) CIT vs. Shanti Lal Aggarwala ii) 96 ITR 310 (All) CIT vs. Late Sunder Lal iii) 111 ITR 326 (All) J.P. Srivast…

M/S GANESH DASS HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…4 ITR 121 (Chennai) CIT vs. Mepco Industries Ltd. viii) 303 ITR 23 (P&H) CIT vs. Munjal Castings ix) 321 ITR 92 (Bom) Grasim Industries Ltd. vs. CIT x) 325 ITR 343 (P&H) CIT vs. Tek Chand Saini xi) 333 ITR 547 (Del) CIT vs. Honda Siel Power Products Ltd. xii) 263 ITR 255 (SC) CIT vs. G.M. Mittal Stainless Steel Ltd. PROPOSITION IV: THAT IT IS NECESSARY FOR COMMISISONER OF INCOME TAX TO POINT OUT THE MATERIAL ON RECORD AS TO HOW THE ORDER OF AO IS PREJUDICIAL TO THE INTEREST OF REVENUE i) 142 ITR 778 (Pat) CIT vs. Shanti Lal Aggarwala ii) 96 ITR 310 (All) CIT vs. Late Sunder Lal iii) 111 ITR 326 (All) J.P. Srivast…

SH. ARVAIL SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…4 ITR 121 (Chennai) CIT vs. Mepco Industries Ltd. viii) 303 ITR 23 (P&H) CIT vs. Munjal Castings ix) 321 ITR 92 (Bom) Grasim Industries Ltd. vs. CIT x) 325 ITR 343 (P&H) CIT vs. Tek Chand Saini xi) 333 ITR 547 (Del) CIT vs. Honda Siel Power Products Ltd. xii) 263 ITR 255 (SC) CIT vs. G.M. Mittal Stainless Steel Ltd. PROPOSITION IV: THAT IT IS NECESSARY FOR COMMISISONER OF INCOME TAX TO POINT OUT THE MATERIAL ON RECORD AS TO HOW THE ORDER OF AO IS PREJUDICIAL TO THE INTEREST OF REVENUE i) 142 ITR 778 (Pat) CIT vs. Shanti Lal Aggarwala ii) 96 ITR 310 (All) CIT vs. Late Sunder Lal iii) 111 ITR 326 (All) J.P. Srivast…

ANIL TUTEJA,FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

KARAN PRATAP SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, HARYANA

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

MUNISH KUMAR LEGAL HEIR LATE SH GURDEEP SINGH,VILL MANAKPUR, YAMUNANAGAR vs. ITO, WARD 5, YAMUNANAGAR

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

MADHU GREWAL,CHANDIGARH vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHANDIGARH-1, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

MANINDER JEET SINGH V.P.O. UDHAMGARH,JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

RAM NIWAS,FATEHABAD vs. INCOME TAX OFFICER, INCOME TAX OFFICE, SIRSA ROAD, INDUSTRIAL AREA, FATEHABAD

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

RAKESH KUMAR,JAGADHRI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

ASHOK KUMAR THAKRAL,JAGADHRI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA , PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

KARTAR SINGH, FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

SH. RAM LAL,FATEHABAD vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

BIMLA DEVI,JAGADHRI vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…

PARAMJIT SINGH,SIRSA vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

…benches of the Income-tax Appellate Tribunal. Therefore, the conclusion of the Tribunal that the Commissioner of Income-tax could not have invoked his jurisdiction under Section 263 of the said Act was correct.”  CIT vs G.M. Mittal Stainless Steell (P) ltd. (263 ITR 255) (2003) (SC) “9…..If at the time when the power under s. 263 was exercised the decision of the jurisdictional High Court had not been set aside by this Court or at least had not been appealed from, it would not be open to the Commissioner to have proceeded on the basis that the High Court was erroneous and that the AO who had acted in terms of th…