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

263 ITR 255Supreme Court of India2003#801 most cited

What is CIT v. G.M. Mittal Stainless Steell (P) ltd. authority for?

A subsequent change of law is not a valid ground for exercising the Commissioner's suo motu revisionary power under Section 263. If the Assessing Officer's view is plausible, it cannot be termed erroneous and prejudicial to the interest of the Revenue.

128

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2010 to 2026.

Also referred to as

CIT v. G.M. Mittal Stainless Steell (P) Ltd. · 263 ITR 255 · Section 263 · suo motu revision · subsequent change of law · erroneous and prejudicial to revenue · plausible view by AO · Commissioner revision power · Income Tax Act · Supreme Court 2003

Sections most often in play

Section 143(3)Section 263Section 56(2)(viii)Section 57(iv)Section 148Section 151Section 10(37)Section 147

Issues it is cited on

section 145b(1)section 145a(b)section 145bsection 45(5)section 57(iv)section 141section 282a(1)section 56(2)(viii)section 10(37)section 194laenhanced compensationsanction under section 151

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

Inder Kaur, Sirsa vs. Pr.CIT, Rohtak

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

ITA 326/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

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

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

…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. Amarjeet Singh, Sirsa vs. Pr.CIT, Rohtak

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

ITA 325/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

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

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

…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. Gurdeep Singh Mahal, Sirsa vs. Pr.CIT, Rohtak

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

ITA 233/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

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

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

…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. Devender Kumar, Yamuna Nagar vs. ITO, Ward -1, Yamuna Nagar

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

ITA 192/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

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

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

…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. Baljinder Singh, Chandigarh vs. Pr.CIT, Chandigarh -1, Chandigarh

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

ITA 167/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

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

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

…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…

Ankit Jain, Hyderabad vs. DCIT., Central Circle -1(2), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1545/HYD/2025[2020-21]Status: DisposedITAT Hyderabad30 Jan 2026AY 2020-21

Bench: Us:

Section 115BSection 143(3)Section 147Section 148Section 148ASection 292CSection 69

…sue by this very High Court, the judicial propriety requires for this Bench to honor the view taken by the Division Bench of this High Court itself. 26. The Hon'ble Supreme Court in the case of CIT v. G.M. Mittal Stainless Steel (P.) Ltd. [2003] 130 Taxman 67/263 ITR 255 (SC)/2003 11 Supreme Court Cases 441, dealing with an issue of not following the judgment of the jurisdictional High Court, held at paragraph No.9 as under: "9. Apart from the language of Section 263 of the Income Tax Act, if we were to accept the submission of the appellant that the Revenue Authorities within the State could refuse to follow the…

Ankit Jain, Hyderabad vs. ACIT., Central Circle - 1(2), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1544/HYD/2025[2019-20]Status: DisposedITAT Hyderabad30 Jan 2026AY 2019-20

Bench: Us:

Section 115BSection 143(3)Section 147Section 148Section 148ASection 292CSection 69

…sue by this very High Court, the judicial propriety requires for this Bench to honor the view taken by the Division Bench of this High Court itself. 26. The Hon'ble Supreme Court in the case of CIT v. G.M. Mittal Stainless Steel (P.) Ltd. [2003] 130 Taxman 67/263 ITR 255 (SC)/2003 11 Supreme Court Cases 441, dealing with an issue of not following the judgment of the jurisdictional High Court, held at paragraph No.9 as under: "9. Apart from the language of Section 263 of the Income Tax Act, if we were to accept the submission of the appellant that the Revenue Authorities within the State could refuse to follow the…

Rashid Hussain, Hyderabad vs. ACIT., Central Circle-1(3), Hyderabad

ITA 1322/HYD/2025[2021-22]Status: DisposedITAT Hyderabad30 Jan 2026AY 2021-22

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 143(2)Section 147Section 148Section 148ASection 151ASection 250Section 37(1)

…sue by this very High Court, the judicial propriety requires for this Bench to honor the view taken by the Division Bench of this High Court itself. 26. The Hon'ble Supreme Court in the case of CIT v. G.M. Mittal Stainless Steel (P.) Ltd. [2003] 130 Taxman 67/263 ITR 255 (SC)/2003 11 Supreme Court Cases 441, dealing with an issue of not following the judgment of the jurisdictional High Court, held at paragraph No.9 as under: "9. Apart from the language of Section 263 of the Income Tax Act, if we were to accept the submission of the appellant that the Revenue Authorities within the State could refuse to follow the…

Sunanda Medical Institute, Delhi vs. CIT(Exemptions), Mumbai

The appeal is allowed for statistical purposes

ITA 7483/MUM/2025[2025-26]Status: DisposedITAT Mumbai29 Jan 2026AY 2025-26

Bench: Shri Saktijit Dey, Vp & Shri Arun Khodpia, Am

Section 80GSection 80G(5)

…feat substantial rights especially in cases involved registration of charitable institutions which otherwisemeet the conditions stipulated under the Act. The Hon'ble Supreme Court in the case of CIT v. G.M. MittalStainless Steel (P.) Ltd. [2003] 130 Taxman 67/263 ITR 255 (SC) has held the procedural lapses should notcome in the way of granting substantive relief, provided the assessee is otherwise eligible. Various judicialpronouncements have held that the procedural defects or clerical errors should not defeat the substantiverights particularly in the context of welfare and beneficial legislations like Registrat…

Prabhakar Reddy Basireddy, Nalgonda vs. DCIT., Central Circle-1(1), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1592/HYD/2025[2022-23]Status: DisposedITAT Hyderabad24 Dec 2025AY 2022-23

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 132Section 147Section 148

…sue by this very High Court, the judicial propriety requires for this Bench to honor the view taken by the Division Bench of this High Court itself. 26. The Hon'ble Supreme Court in the case of CIT v. G.M. Mittal Stainless Steel (P.) Ltd. [2003] 130 Taxman 67/263 ITR 255 (SC)/2003 11 Supreme Court Cases 441, dealing with an issue of not following the judgment of the jurisdictional High Court, held at paragraph No.9 as under: "9. Apart from the language of Section 263 of the Income Tax Act, if we were to accept the submission of the appellant that the Revenue Authorities within the State could refuse to follow the…

Prabhakar Reddy Basireddy, Nalgonda vs. DCIT., Central Circle-1(1), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1591/HYD/2025[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21
Section 132Section 147Section 148

…sue by this very High Court, the judicial propriety requires for this Bench to honor the view taken by the Division Bench of this High Court itself. 26. The Hon'ble Supreme Court in the case of CIT v. G.M. Mittal Stainless Steel (P.) Ltd. [2003] 130 Taxman 67/263 ITR 255 (SC)/2003 11 Supreme Court Cases 441, dealing with an issue of not following the judgment of the jurisdictional High Court, held at paragraph No.9 as under: "9. Apart from the language of Section 263 of the Income Tax Act, if we were to accept the submission of the appellant that the Revenue Authorities within the State could refuse to follow the…

Ziqitza Healthcare Ltd, Mumbai vs. Pr. Commissioner of Income Tax -4, Mumbai

In the result, the appeal is accordingly, allowed

ITA 3637/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Nov 2025AY 2020-21

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri Prabhash Shankar, Hon’Bleziqitza Healthcare Ltd., Principal Cit - 4, 23, Sunshine Tower, Mumbai. Vs. Senapati Bapat Marg, Delisle Road, Dadar West, Mumbai 400 013. Pan Aaacz1733C (Appellant) (Respondent)

For Appellant: Shri Ketan L Vajani-CAFor Respondent: Shri Arun Kanti Datta – CIT-DR
Section 143(3)Section 263Section 36(1)(va)

…of record that this legal position has undergone a change on account of the decision of Supreme Court in Checkmate Services (P.) Ltd. (supra). 9. The issue is no longer res integra. The Supreme Court in the case of CIT vs. G M Mittal Stainless Steel P. Ltd. [263 ITR 255] has, inter alia, held that the subsequent change of law cannot be a ground for exercising power of suo moto revision u/s. 263 of the Act. The following observations of the Supreme Court are apposite: ITA 3637/Mum/2025 Ziqitza Healthcare Ltd. “Although nobody appears on behalf of the respondent despite service of notice of appeal, we are of the…

Rajvee Exports, Surat vs. DCIT, Central Circle 3, Surat

In the result, we find no infirmity in the impugned order

ITA 520/SRT/2025[2021-22]Status: DisposedITAT Surat30 Oct 2025AY 2021-22

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2021-2022 Rajvee Exports, Dcit, Central Circle 3, 400, Shri Godiji Building, Aayakar Bhavan, Devidas Pipla Road, Vs. Surat-395001. Mahidharpura, S.O. Surat-395003. Pan No. Aagfr 1008 K Appellant Respondent

For Appellant: Mr. Rasesh Shah, CAFor Respondent: Shri Mukesh Jain, CIT-DR
Section 133ASection 143Section 143(3)Section 263

…nce was placed upon Officer, which is impermissible in law. Reliance was placed upon the judgment of the Hon’ble Supre the judgment of the Hon’ble Supreme Court in CIT v. G.M. Mittal CIT v. G.M. Mittal Stainless Steel (P) Ltd. Stainless Steel (P) Ltd. [(2003) 263 ITR 255 (SC)] and the decision [(2003) 263 ITR 255 (SC)] and the decision of the Hon’ble Gujarat High Court in of the Hon’ble Gujarat High Court in CIT v. Amit Corporation CIT v. Amit Corporation [(2013) 81 CCH 69 (Guj.)]. [(2013) 81 CCH 69 (Guj.)]. 6. Per contra, the Ld. Departmental Representative supported Per contra, the Ld. Departmental Representat…

Ucal Limited, Chennai vs. PCIT, Chennai-3, Chennai

ITA 1018/CHNY/2025[2020-21]Status: DisposedITAT Chennai15 Oct 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate &For Respondent: Shri. C.N. Bipin, C.I.T
Section 143(3)Section 263Section 36(1)(va)Section 37

…Reply to the Show Cause Notice under Section 524 263 of the Act dated 06.03.2025 29. 24.03.2025 Revision order (Impugned Order) 538 CITATIONS – I 30. 10.12.2002 Commissioner of Income-tax v. G.M. Mittal 554 Stainless Steel (P.) Ltd - Supreme Court of India - 263 ITR 255 31. 12.10.2022 Checkmate Services (P.) Ltd. v. Commissioner of 558 Income-tax-1 - Supreme Court of India - 448 ITR 518 32. 24.07.2015 Commissioner of Income Tax No.121, 578 Nungambakkam High Road, Chennai. – High Court of Madras - Tax Case (Appeal) Nos.585 and 586 of 2015 33. 23.10.2024 M/s. Heylands Exports Pvt. Ltd. v. The PCIT-1, 584 Chennai –…

Britg Foundation, Vizianagaram vs. Commissioner of Income-Tax (Exemptions), Hyderabad

In the result, appeal is allowed for statistical purposes

ITA 208/VIZ/2025[2022-23 to 2026-27]Status: DisposedITAT Visakhapatnam10 Jul 2025

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.208/Viz/2025 (निर्धारण वर्ा/ Assessment Years: 2022-23 To 2026-27) Britg Foundation V. Commissioner Of Income Tax (Exemptions) 22-14-12, Kotlamadappa Street Aaykar Bhawan, Opp. L.B. Stadium Vizianagaram H.O. Basheer Bagh, Hyderabad – 500004 Telangana Vizianagaram – 535002 Andhra Pradesh [Pan:Aaetb5357K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri C. Sanjeevarao, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 12Section 12ASection 12A(1)(ac)

…stake should not defeat substantial rights especially in cases involving registration of charitable institutions which otherwise meet the conditions stipulated under the Act. The Hon’ble Supreme Court in the case of CIT v. G.M.Mittal Stainless Steel (P) Ltd. [263 ITR 255 (SC)] has held the procedural lapses should not come in the way of granting substantive relief, provided the assessee is otherwise eligible. Various judicial pronouncements have held that the procedural defects or clerical errors should not defeat the substantive rights particularly in the context of welfare and beneficial legislations like Regis…

Andhara University Alumni Association, Visakhapatnam vs. Income Tax Officer (Exemption Ward), Visakhapatnam

In the result, appeal is allowed for statistical purposes

ITA 71/VIZ/2025[NA]Status: DisposedITAT Visakhapatnam30 Jun 2025

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 70 & 71/Viz/2025 Andhra University Alumni Association V. Income Tax Officer (Exemption Ward) 1St Floor, Science & Technology Building Income Tax Office Andhra University Infinity Tower, Shankarmatham Road Visakhapatnam – 530003 Santhipuram, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan:Aaeaa7037Q] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 12ASection 12A(1)(ac)

…istake should not defeat substantial rights especially in cases involved registration of charitable institutions which otherwise meet the conditions stipulated under the Act. The Hon’ble Supreme Court in the case of CIT v. G.M.Mittal Stainless Steel (P) Ltd. [263 ITR 255 (SC)] has held the procedural lapses should not come in the way of granting substantive relief, provided the assessee is otherwise eligible. Various judicial pronouncements have held that the procedural defects or clerical errors should not defeat the substantive rights particularly in the context of welfare and beneficial legislations like Regis…

Andhara University Alumni Association, Visakhapatnam vs. Income Atx Officer (Exemption Ward), Visakhapatnam

In the result, appeal is allowed for statistical purposes

ITA 70/VIZ/2025[NA]Status: DisposedITAT Visakhapatnam30 Jun 2025

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos. 70 & 71/Viz/2025 Andhra University Alumni Association V. Income Tax Officer (Exemption Ward) 1St Floor, Science & Technology Building Income Tax Office Andhra University Infinity Tower, Shankarmatham Road Visakhapatnam – 530003 Santhipuram, Visakhapatnam – 530016 Andhra Pradesh Andhra Pradesh [Pan:Aaeaa7037Q] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 12ASection 12A(1)(ac)

…istake should not defeat substantial rights especially in cases involved registration of charitable institutions which otherwise meet the conditions stipulated under the Act. The Hon’ble Supreme Court in the case of CIT v. G.M.Mittal Stainless Steel (P) Ltd. [263 ITR 255 (SC)] has held the procedural lapses should not come in the way of granting substantive relief, provided the assessee is otherwise eligible. Various judicial pronouncements have held that the procedural defects or clerical errors should not defeat the substantive rights particularly in the context of welfare and beneficial legislations like Regis…

Kaligotla Snigdha Sridevi Foundation, Visakhapatnam vs. Income Tax Officer (Exemption Ward), Visakhapatnam

In the result, appeal is allowed for statistical purposes

ITA 67/VIZ/2025[NA]Status: DisposedITAT Visakhapatnam30 Jun 2025

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.67/Viz/2025 Kaligotla Snigdha Sridevi Foundation V. Income Tax Officer (Exemption Ward) Income Tax Office Koligotla Vari Street Infinity Tower, Shankarmatham Road Chinna Bazar, Bheemunipatnam Santhipuram, Visakhapatnam – 530016 Visakhapatnam Andhra Pradesh [Pan:Aadtk1059J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 12ASection 80G

…istake should not defeat substantial rights especially in cases involved registration of charitable institutions which otherwise meet the conditions stipulated under the Act. The Hon’ble Supreme Court in the case of CIT v. G.M.Mittal Stainless Steel (P) Ltd. [263 ITR 255 (SC)] has held the procedural lapses should not come in the way of granting substantive relief, provided the assessee is otherwise eligible. Various judicial pronouncements have held that the procedural defects or Page. No 4 I.T.A.No.67/VIZ/2025 Kaligotla Snigdha Sridevi Foundation clerical errors should not defeat the substantive rights particu…

Alliance Broadcasting Pvt. Ltd., Tirunelveli vs. PCIT (Central), Chennai

In the result, appeal filed by the assessee is allowed

ITA 2278/CHNY/2024[2017-18]Status: DisposedITAT Chennai18 Jun 2025AY 2017-18
For Respondent: For Mr.K. Ravi, Advocate
Section 132Section 143(1)Section 144Section 153CSection 2(24)(x)Section 263Section 36(1)(va)Section 40

…dverse view against the assessee, which view is a plausible view and can't be termed as erroneous and prejudicial to the interest of the Revenue as held by the Hon'ble Supreme Court in the case of CIT v. G.M. Mittal Stainless Steel (P) Ltd. reported in (2003) 263 ITR 255 (SC). 9. The second reason is that the search operation u/s.132 of the Act was conducted in the case of VV Group Concerns on 25.10.2018. Pursuant to it, proceedings u/s.153C of the Act have been initiated against the assessee on 11.03.2021 and directed assessee to file ROI including that for AY 2017-18. In this regard, it is noted that the assess…

Ms. Shree Waheguru Fashions Pvt. Ltd., Ring Road, Surat vs. PCIT, Aayakar Bhavan, Surat

In the result, appeal of the assessee is allowed

ITA 402/SRT/2024[2020-21]Status: DisposedITAT Surat03 Apr 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.402/Srt/2024 Assessment Year: (2020-21) (Hybrid Hearing) M/S Shree Waheguru Fashions Principal Commissioner Of बनाम/ Pvt. Ltd., B-1110, Radha Krishna Vs. Income-Tax (Central), Textile Market, Ring Road, Surat Central Circle-1, Surat, Aayakar - 395002 Bhavan, Majura Gate, Surat- 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aahcs 9568 H (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 132Section 132(4)Section 143(2)Section 144Section 147Section 263

…IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.402/SRT/2024 Assessment Year: (2020-21) (Hybrid Hearing) M/s Shree Waheguru Fashions Principal Commissioner of बनाम/ Pvt. Ltd., B-1110, Radha Krishna Vs. Income-tax (Central), Textile Market, Ring Road, Surat Central Circle-1, Surat, Aayakar - 395002 Bhavan, Majura Gate, Surat- 395001 "थायीलेखासं./जीआइआरसं./PAN/GIR No: AAHCS 9568 H (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant by Shri Rasesh Shah, CA राज" की ओर से /Respondent…