CIT v. Hissaria Brothers

386 ITR 719Supreme Court of India2016#1673 most cited

What is CIT v. Hissaria Brothers authority for?

The relevant date for determining the limitation period under Section 275(1)(c) for passing penalty orders under Sections 271D and 271E is the date of passing the assessment order.

68

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2017 to 2026.

Also referred to as

Hissaria Brothers SC · penalty order limitation period · Section 275(1)(c) · Section 271D penalty · Section 271E penalty · date of assessment order for penalty · limitation for penalty under 269SS · limitation for penalty under 269T · Supreme Court penalty limitation · income tax penalty time limit

Also reported as

74 Taxmann.com 22

Sections most often in play

Section 271DSection 271ESection 269TSection 269SSSection 275Section 275(1)(c)Section 153ASection 143(3)

Issues it is cited on

section 275(1)(a)section 275(1)section 275(1)(c)penalty under section 271esection 245hsection 275section 269tsection 271epenalty under section 271dsection 261revision under section 263section 129

Judgments citing CIT v. Hissaria Brothers

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1061/JPR/2025[2022-23]Status: DisposedITAT Jaipur10 Nov 2025AY 2022-23

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

…der From the perusal of the various cases laws relied upon by the assessee as well as other cases available in the legal domain, it is seen that the exact issue has been discussed in the following cases:- Hon'ble Supreme Court in the case of Hissaria Brothers 386 ITR 719 held as under "Penalty under ss.271D and 271E-Limitation under s.275- Computation-Penalty orders under ss.271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation-CIT v. Hissaria Bros (2007) 211 CTR (Raj) 156 affirmed." Hon'ble Rajasthan High Court in the CIT v. Jitendra Si…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1060/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Nov 2025AY 2016-17

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

…lved in the present case is fully covered by the decision of Hon'ble Jurisdictional High Court in the case of Hissaria Bros. (supra). The same has been affirmed by the Hon'ble Apex Court in the case of Hissaria Brothers [2016] 74 taxmann.com 22/243 Taxman 174/386 ITR 719 holding as under. "Penalty under ss.271D and 271E-Limitation under s.275- Computation-Penalty orders under ss.271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation-CIT v. Hissaria Bros. (2007) 211 CTR (Raj) 156 affirmed." Similar view was taken again by the Hon'ble Rajas…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1059/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Nov 2025AY 2016-17

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

…der From the perusal of the various cases laws relied upon by the assessee as well as other cases available in the legal domain, it is seen that the exact issue has been discussed in the following cases:- Hon'ble Supreme Court in the case of Hissaria Brothers 386 ITR 719 held as under "Penalty under ss.271D and 271E-Limitation under s.275- Computation-Penalty orders under ss.271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation-CIT v. Hissaria Bros (2007) 211 CTR (Raj) 156 affirmed." Hon'ble Rajasthan High Court in the CIT v. Jitendra Si…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1058/JPR/2025[2012-13]Status: DisposedITAT Jaipur10 Nov 2025AY 2012-13

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

…der From the perusal of the various cases laws relied upon by the assessee as well as other cases available in the legal domain, it is seen that the exact issue has been discussed in the following cases:- Hon'ble Supreme Court in the case of Hissaria Brothers 386 ITR 719 held as under "Penalty under ss.271D and 271E-Limitation under s.275- Computation-Penalty orders under ss.271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation-CIT v. Hissaria Bros (2007) 211 CTR (Raj) 156 affirmed." Hon'ble Rajasthan High Court in the CIT v. Jitendra Si…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1057/JPR/2025[2012-13]Status: DisposedITAT Jaipur10 Nov 2025AY 2012-13

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

…der From the perusal of the various cases laws relied upon by the assessee as well as other cases available in the legal domain, it is seen that the exact issue has been discussed in the following cases:- Hon'ble Supreme Court in the case of Hissaria Brothers 386 ITR 719 held as under "Penalty under ss.271D and 271E-Limitation under s.275- Computation-Penalty orders under ss.271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation-CIT v. Hissaria Bros (2007) 211 CTR (Raj) 156 affirmed." Hon'ble Rajasthan High Court in the CIT v. Jitendra Si…

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Jayapriya Company, Chennai

ITA 1899/CHNY/2025[2021-22]Status: DisposedITAT Chennai30 Oct 2025AY 2021-22
Section 132Section 269SSection 271D

…आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक सदस्य एवं श्री एस. आर. रघुनाथा, लेखा सदस्य के समक्ष BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI S.R.RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.1899/Chny/2025 निर्धारण वर्ष/Assessment Year: 2021-22 & Cross-Objection No.65/Chny/2025 निर्धारण वर्ष/Assessment Year: 2021-22 v. Jayapriya Company, No.37, Second Floor, Siva Vishnu Complex, Natesan Street, T. Nagar, Chennai-600 017. [PAN: AAHFJ 0958 M] (प्रत्यर्थी/Respondent/Cross- Objector) Mr. Bipin C.N., CIT & Ms. R. Anita, Addl…

Deputy Commissioner of Income Tax, Central Circle-2, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 274/JPR/2025[2017-18]Status: DisposedITAT Jaipur26 Jun 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Tax, Central Circle-02, Jaipur Vs. Kiran Fine Jewellers Private Limited F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri R. K. Bhatra, CA राजस्व

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

…idered the binding precedent of our Rajasthan High Court in the case of CIT Vs. Hissaria Bros 169 Taxman 262 (Rajasthan). The said decision has been affirmed by the Hon'ble Apex Court in the case of Hissaria Brothers [2016] 74 taxmann.com 22/243 Taxman 174/386 ITR 719 wherein our High Court held that “"Penalty under ss. 271D and 271E-Limitation under s. 275-Computation- Penalty orders under ss. 271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation. Therefore, based on that binding precedent he held that the relevant date for determi…

Deputy Commissioner of Income Tax, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 271/JPR/2025[2017-18]Status: DisposedITAT Jaipur26 Jun 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Tax, Central Circle-02, Jaipur Vs. Kiran Fine Jewellers Private Limited F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri R. K. Bhatra, CA राजस्व

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

…idered the binding precedent of our Rajasthan High Court in the case of CIT Vs. Hissaria Bros 169 Taxman 262 (Rajasthan). The said decision has been affirmed by the Hon'ble Apex Court in the case of Hissaria Brothers [2016] 74 taxmann.com 22/243 Taxman 174/386 ITR 719 wherein our High Court held that “"Penalty under ss. 271D and 271E-Limitation under s. 275-Computation- Penalty orders under ss. 271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation. Therefore, based on that binding precedent he held that the relevant date for determi…

Deputy Commissioner of Income Tax, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 270/JPR/2025[2014-15]Status: DisposedITAT Jaipur26 Jun 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

…idered the binding precedent of our Rajasthan High Court in the case of CIT Vs. Hissaria Bros 169 Taxman 262 (Rajasthan). The said decision has been affirmed by the Hon'ble Apex Court in the case of Hissaria Brothers [2016] 74 taxmann.com 22/243 Taxman 174/386 ITR 719 wherein our High Court held that “"Penalty under ss. 271D and 271E-Limitation under s. 275-Computation- Penalty orders under ss. 271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation. Therefore, based on that binding precedent he held that the relevant date for determi…

Deputy Commissioner of Income Tax, Central Circle-2, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 268/JPR/2025[2013-14]Status: DisposedITAT Jaipur26 Jun 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं./ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Kiran Fine Jewellers Private Tax, Vs. Limited Central Circle-02, Jaipur F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Shri R. K. Bhatra, CA राजस्व की

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 271DSection 271E

…idered the binding precedent of our Rajasthan High Court in the case of CIT Vs. Hissaria Bros 169 Taxman 262 (Rajasthan). The said decision has been affirmed by the Hon'ble Apex Court in the case of Hissaria Brothers [2016] 74 taxmann.com 22/243 Taxman 174/386 ITR 719 wherein our High Court held that “"Penalty under ss. 271D and 271E-Limitation under s. 275-Computation- Penalty orders under ss. 271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation. Therefore, based on that binding precedent he held that the relevant date for determi…

M/S the Panniyankara Service Co-Op Bank Ltd, Kozhikode vs. The Joint Commissioner of Income Tax, Range 1, Kozhikode

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

ITA 910/COCH/2022[2015-16]Status: DisposedITAT Cochin21 May 2025AY 2015-16

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Arun Raj S, AdvocateFor Respondent: Smt.Veni Raj, CIT-DR
Section 143(3)Section 269SSection 271Section 271DSection 273BSection 275(1)(c)Section 80PSection 80P(2)(a)

…e end of the month of passing the assessment order dated 20-12-2017 is barred by limitation as per section 275(1)(c) of the Income Tax Act as held by the Hon'ble Supreme Court in CIT Vs. Hissaria Brothers vide order dated 22nd August, 2016; reported in [2016] 386 ITR 719 (SC)." 4 ITA No.910/Coch/2022. The Panniyankara SCB Limited. 5. The learned Counsel appearing on behalf of the assessee while challenging the additional ground argued that the date of initiation of penalty will have to be considered from the date of assessment order and not from the date of notice issued for initiation of penalty u/s.271D of th…

Ajay Bakliwal, Kota vs. ACIT, Central Circle, Kota

In the result, the appeal of the assessee is allowed

ITA 1278/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Apr 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132Section 132(1)Section 269SSection 271DSection 274Section 275(1)(c)

…ch penalty proceedings was not to be reckoned from the issue of show cause by the Jt. CIT, but the period of limitation was to be reckoned from the date of issue of first show cause for initiation of such penalty proceedings”. CIT Vs. Hissaria Brothers [2016] 386 ITR 719 (SC) “Penalty under ss. 271D and 271E—Limitation under s. 275— Computation— Penalty orders under ss. 271D and 271E passed beyond six months from the end of the month in which the assessments were completed were barred by limitation— CIT vs. Hissaria Bros. (2007) 211 CTR (Raj) 156 affirmed.” Application over the Facts of Present case: No penalty…

Rvr Technologies Ltd., Mandideep vs. ITO-2(1), Bhopal

In the result, appeal for A

ITA 277/IND/2023[2014-15]Status: DisposedITAT Indore30 May 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 271E

…ITR 452 (All.) (ii)Jagdish Chandra Suwalka vs JCIT [2023] 154 taxmann.com 504 (Jaipur - Trib.) (iii) JCIT v. Jitendra Singh Rathore [2013] 352 ITR 327(Raj) Page 11 of 25 ITANo.275 to 277/Ind/2023 RVT Technologies Ltd. (iv) CIT v. Hissaria Brothers [2016] 386 ITR 719 (SC) (v) Omec Engineers vs CIT [2008] 294 Taxman 599 (Jharkhand) (vi) CIT v. Ratna Agencies [2006] 284 ITR 609 (vii) CIT vs Lakshmi Trust Co. 303 ITR 99 (Mad.). (viii) Shreenath Builders v. Dy. CIT [2000] 111 Taxman 142 (Mag.) 7.1 Thus, Ld. AR has submitted that even otherwise when the repayment was through RTGS the same is through banking channe…

Rvr Technologies Ltd., Mandideep vs. Addl. CIT-Range-3, Bhopal

In the result, appeal for A

ITA 276/IND/2023[2009-10]Status: DisposedITAT Indore30 May 2024AY 2009-10

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 271E

…ITR 452 (All.) (ii)Jagdish Chandra Suwalka vs JCIT [2023] 154 taxmann.com 504 (Jaipur - Trib.) (iii) JCIT v. Jitendra Singh Rathore [2013] 352 ITR 327(Raj) Page 11 of 25 ITANo.275 to 277/Ind/2023 RVT Technologies Ltd. (iv) CIT v. Hissaria Brothers [2016] 386 ITR 719 (SC) (v) Omec Engineers vs CIT [2008] 294 Taxman 599 (Jharkhand) (vi) CIT v. Ratna Agencies [2006] 284 ITR 609 (vii) CIT vs Lakshmi Trust Co. 303 ITR 99 (Mad.). (viii) Shreenath Builders v. Dy. CIT [2000] 111 Taxman 142 (Mag.) 7.1 Thus, Ld. AR has submitted that even otherwise when the repayment was through RTGS the same is through banking channe…

Rvr Technologies Ltd., Mandideep vs. ACIT-3(1), Bhopal

In the result, appeal for A

ITA 275/IND/2023[2008-09]Status: DisposedITAT Indore30 May 2024AY 2008-09

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 147Section 148Section 271E

…ITR 452 (All.) (ii)Jagdish Chandra Suwalka vs JCIT [2023] 154 taxmann.com 504 (Jaipur - Trib.) (iii) JCIT v. Jitendra Singh Rathore [2013] 352 ITR 327(Raj) Page 11 of 25 ITANo.275 to 277/Ind/2023 RVT Technologies Ltd. (iv) CIT v. Hissaria Brothers [2016] 386 ITR 719 (SC) (v) Omec Engineers vs CIT [2008] 294 Taxman 599 (Jharkhand) (vi) CIT v. Ratna Agencies [2006] 284 ITR 609 (vii) CIT vs Lakshmi Trust Co. 303 ITR 99 (Mad.). (viii) Shreenath Builders v. Dy. CIT [2000] 111 Taxman 142 (Mag.) 7.1 Thus, Ld. AR has submitted that even otherwise when the repayment was through RTGS the same is through banking channe…

M/S.Karannur Service Co-Op Bank Ltd, Kozhikkode vs. The ITO, WD-1(2), Kozhikkode

In the result, the appeals by the assessee are allowed

ITA 249/COCH/2020[2015-16]Status: DisposedITAT Cochin16 Nov 2023AY 2015-16

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri P. Raghunathan, AdvocateFor Respondent: Sh. Sanjith K. Das, CIT-DR
Section 143(3)Section 271DSection 273BSection 274Section 275(1)(c)Section 80P(1)

…ty and, thus, only upon the issue of notice u/s. 274 of the Act by the Jt. CIT, i.e., on 02.01.2018 (in the instant case), so that the limitation shall expire on 31.7.2018, cannot be regarded as good law in view of the decision in CIT vs. Hissaria Bros.[2016] 386 ITR 719 (SC), upholding the decision reported at [2007] 291 ITR 244 (Raj), para 9 whereof, reading as under, was referred to: “9. The Tribunal found on the question of limitation that the order of penalty should have been passed within 6 months from the end of the month in which the assessment was completed. On this premise, it was held that since all th…

The Karannur Service Co-Op Bank Ltd, Kozhikkode vs. The ITO, WD-1(2), Kozhikkode

In the result, the appeals by the assessee are allowed

ITA 248/COCH/2020[2015-16]Status: DisposedITAT Cochin16 Nov 2023AY 2015-16

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri P. Raghunathan, AdvocateFor Respondent: Sh. Sanjith K. Das, CIT-DR
Section 143(3)Section 271DSection 273BSection 274Section 275(1)(c)Section 80P(1)

…ty and, thus, only upon the issue of notice u/s. 274 of the Act by the Jt. CIT, i.e., on 02.01.2018 (in the instant case), so that the limitation shall expire on 31.7.2018, cannot be regarded as good law in view of the decision in CIT vs. Hissaria Bros.[2016] 386 ITR 719 (SC), upholding the decision reported at [2007] 291 ITR 244 (Raj), para 9 whereof, reading as under, was referred to: “9. The Tribunal found on the question of limitation that the order of penalty should have been passed within 6 months from the end of the month in which the assessment was completed. On this premise, it was held that since all th…

Income-Tax Officer, Ward - 3, Ichalkaranji vs. Shri. Danwade Kutubuddin Shahabudin, Kolhapur

In the result, the appeal of Revenue is dismissed

ITA 1688/PUN/2018[2005-06]Status: DisposedITAT Pune14 Aug 2023AY 2005-06

Bench: Shri S.S. Viswanethra Ravi & Shri G.D. Padmahshali

For Appellant: Shri Pramod ShingteFor Respondent: Shri Mahesh Jasnani
Section 131(1)Section 132Section 153ASection 269SSection 271DSection 271ESection 275Section 275(1)(c)

…e other relevant proceedings. The Hon’ble supreme Court was pleased to confirm the decision of Hon’ble 11 ITA No. 1688/PUN/2018, A.Y. 2005-06 High Court of Rajasthan in the case of Hissaria Bros. (supra) vide its decision dated 22-08-2016 reported in (2016) 386 ITR 719 (SC). 10. In view of the decision of Hon’ble High Court of Rajasthan in the case of Hissaria Bros. (supra), for better understanding, for ready reference the provisions u/s. 275(1)(c) of the Act relevant to F.Y. 2007 (31-07-2007) is reproduced here-in-below : “Bar of limitation for imposing penalties. 275. (1) No order imposing a penalty under t…

Jagdish Chandra Suwalka, Jaipur vs. JCIT, Range-7, Jaipur

In the result, appeal of the assessee is allowed

ITA 376/JPR/2022[2015-16]Status: DisposedITAT Jaipur28 Apr 2023AY 2015-16

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Mahendra Gargieya, AdvocateFor Respondent: Ms Monisha Choudhary (Addl. CIT)
Section 143(1)Section 143(2)Section 143(3)Section 269SSection 271DSection 44A

…alty proceedings was not to be reckoned from the issue of show cause by the Jt. CIT, but the period of limitation was to be reckoned from the date of issue of first show cause for initiation of such penalty proceedings”. 1.2.2.CIT Vs. Hissaria Brothers [2016] 386 ITR 719 (SC)(DPB 5-6): “Penalty under ss. 271D and 271E—Limitation under s. 275— Computation—Penalty orders under ss. 271D and 271E passed beyond six months from the end of the month in which the 6 Shri Jagdish Chandra Suwalka, Jaipur. assessments were completed were barred by limitation— CIT vs. Hissaria Bros. (2007) 211 CTR (Raj) 156 affirmed.” 1.3 A…

Delhi State Taxi Operators Co-Operative Thrift Credit & Services Society Ltd, New Delhi vs. JCIT Range - 60, New Delhi

ITA 3108/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Apr 2023AY 2013-14

Bench: Shri Shamim Yahya & Ms. Astha Chandra

For Appellant: Shri C.S. Aggarwal, Sr. AdvocateFor Respondent: Shri T. James Singson, CIT-DR
Section 269SSection 271DSection 271ESection 275

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL MEMBER ITA Nos. 3107 & 3108/Del/2019 Asstt. Years: 2013-14 & 2013-14 M/s. Delhi State Taxi Vs. JCIT, Operators’s Co-operative Thrift Range-60, Credit & Services Society Ltd., New Delhi. C-19, Pandav Nagar, Ganesh Nagar Complex, New Delhi – 110 091. PAN AAAAD0030A (Appellant) (Respondent) Assessee by: Shri C.S. Aggarwal, Sr. Advocate, Shri Ravi Pratap Mall, Adv., Ms. Pushpa Sharma, Adv., Shri Uma Shankar, Adv. and Shri Sandeip S Nagar, CA Department by : Shri T. James Singson, CI…