How many judgments cite CIT v. ICICI Bank Limited?

32 judgments on BharatTax cite CIT v. ICICI Bank Limited (343 ITR 74), spanning 2018 to 2025.

Which sections of the Income Tax Act does CIT v. ICICI Bank Limited come up under?

It is most often cited in judgments turning on Section 143(3), Section 263, Section 147, Section 144B, Section 115JB, Section 143(2).

CIT v. ICICI Bank Limited

343 ITR 74High Court2012#3737 most cited

What is CIT v. ICICI Bank Limited authority for?

The period of limitation for exercising revisionary powers under section 263(2) of the Income-tax Act begins from the date of the original assessment order under section 143(3) if the issue sought to be revised was covered by that order and was not part of the reassessment.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2025.

Also referred to as

CIT v. ICICI Bank · section 263 · section 143(3) · revision limitation · date of assessment order · section 263(2) · erroneous and prejudicial · lack of enquiry · income escaping assessment

Also reported as

19 Taxmann.com 142

Sections most often in play

Section 143(3)Section 263 Section 147 Section 144B Section 115JB Section 143(2)Section 144C Section 14A

Issues it is cited on

section 263(2)doctrine of merger section 148(2)section 263(1)revision u/s 263 malabar industrial revision under section 263 lack of enquiry income escaping assessment erroneous and prejudicial national faceless assessment centre section 263

Judgments citing CIT v. ICICI Bank Limited

ASIT C MEHTA INVESTMENT INTERRMEDIATES LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX-4 MUMBAI, MUMBAI

ITA 3411/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Nov 2025AY 2018-19

Bench: Smt. Kavitha Rajagopal (Jm) & Shri Omkareshwar Chidara (Am) Asit C. Mehta Investment Pr.Cit Interrmediates Limited Room No. Ab-629 Nucleus House, Saki Vihar Vs. Aayakar Bhavan Road, Mumbai-400 072. M.K. Road,Mumbai-20 Pan : Aaaca5009N Appellant Respondent

For Respondent: Shri Yogesh Thar & Shri

Section 143(3)Section 147Section 148Section 263Section 37(1)

…covered in favour of the appellant by the order of ITAT in earlier years. The Ld. AR relied on the decision of Hon'ble Apex Court in the case of Alagendran Finance Ltd. (293 ITR 101)(SC) and Hon'ble Jurisdictional High Court’s decision of CIT Vs. ICICI Bank (343 ITR 74)(Bom) for the proposition that the Revision Order is barred by limitation. Hence, it was pleaded that the order under section 263 of the Act may be quashed. 4. The Ld. DR relied on the order of Ld. PCIT under section 263 of the Act, where it was mentioned that the issue of “Business Associate Expenses” was not discussed and enquired into by Ld. A…

USUF TRADING CO.,,MURSHIDABAD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, KOLKATA - 1,, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 396/KOL/2025[2017-18]Status: DisposedITAT Kolkata13 May 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Principal Commissioner Of Income Tax, Kolkata - 1, Usuf Trading Co., Office Of The Income Tax Officer, Near Railway Station, Dhuliyan Ward - 42(1), Murshidabad, 39, Jangipur, Murshidabad, Vs. R.N. Tagore Road, Behrampur, West Bengal, 742202 Murshidabad, West Bengal, 742101 (Appellant) (Respondent) Pan No. Aacfu4764B Assessee By : Shri S.K. Tulsiyan, Ar Revenue By : Shri Sanat Raha, Cit (Dr) Date Of Hearing: 07.05.2025 Date Of Pronouncement : 13.05.2025

For Appellant: Shri S.K. Tulsiyan, ARFor Respondent: Shri Sanat Raha, CIT (DR)

Section 142(1)Section 143(3)Section 194CSection 194C(6)Section 263Section 263(2)Section 40A(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM Principal Commissioner of Income Tax, Kolkata - 1, USUF TRADING CO., Office of the Income Tax Officer, Near Railway Station, Dhuliyan Ward - 42(1), Murshidabad, 39, Jangipur, Murshidabad, Vs. R.N. Tagore Road, Behrampur, West Bengal, 742202 Murshidabad, West Bengal, 742101 (Appellant) (Respondent) PAN No. AACFU4764B Assessee by : Shri S.K. Tulsiyan, AR Revenue by : Shri Sanat Raha, CIT (DR) Date of hearing: 07.05.2025 Date of pronouncement : 13.05.2025 O R D E R Per Rajesh Kumar, AM: This is a…

MCLEOD RUSSEL INDIA LTD.,KOLKATA vs. PCIT, KOLKATA - 2, KOLKATA

In the result, appeal of the assessee is allowed

ITA 1136/KOL/2024[2015-2016]Status: DisposedITAT Kolkata24 Apr 2025AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1136/Kol/2024 (नििाारण वर्ा / Assessment Year : 2015-2016) Mcleod Russel India Limited, Vs Pr.Cit, Kolkata-2 Four Mangoe Lane, Surendra Mohan Ghosh Sarani, Kolkata-700001 Pan No. :Aaace 6918 J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri N.S.Saini, Ar & Ms. Priyanka Salarpuria, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2025 घोषणा की तारीख/Date Of Pronouncement : 24/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Assessee Against The Order Dated 30.03.2024, Passed By The Ld. Pr.Cit, Kolkata-2, U/S.263 Of The Act For The Assessment Year 2015-2016 On The Following Grounds :- 1. On The Facts & In Circumstances Of The Case As Well As Law On The Subject, The Learned Pr. Cit Has Erred In Passing The Order U/S 263 By Invoking Of Section 263 Of The Act, Although The Assessment Order Passed U/S. 147 R.W.S. 143(3) Of The I. T. Act, 1961 Was Neither Erroneous Nor Prejudicial To The Interest Of The Revenue. 2. For That On The Facts & In The Circumstances Of The Case & In Law, The Reassessment Order For A.Y. 2015-16 Which Is Sought To Be Revised By The Ld. Pcit U/S 263 Had Neither Considered The Issue Of Eligibility For Deduction U/S 801E Of The 1.T. Act In The Reassessment Proceedings Nor The Reopening Of The Assessment Made On That Ground. Therefore, The Issue Does Not Arise Out Of The Order Passed U/S 147 Of The 1.T. Act, 1961. 3. For That On The Facts Of The Case & Law, The Issue Of Notice U/S 263 Of The Act On The Ground That The Assessee Company

For Appellant: Shri N.S.Saini, AR & Ms. PriyankaFor Respondent: Shri P.N.Barnwal, CIT-DR

Section 143(3)Section 147Section 244ASection 263Section 263(1)Section 801ESection 80I

…el in pursuance to his argument relied on the decision of the Hon’ble Apex Court in the case of CIT Vs. Alagendran Finance Ltd., reported in [2007] 293 ITR 1 (SC) and the decision of Hon’ble Bombay High Court in the case of ICICI Bank Ltd., reported in [2012] 343 ITR 74 (Bom.). The ld. AR also relied on the decision of the coordinate bench of the Tribunal in the case of Mcleod Russel India Ltd., passed in ITA No.984/Kol/2024, order dated 12.09.2024, wherein a similar issue has been decided in favour of the assessee. Ld. AR, therefore, prayed that the revisionary jurisdiction exercised by the Pr.CIT may kindly be…

HSBC SECURITIES AND CAPITAL MARKETS (INDIA) PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, MUMBAI-4, MUMBAI

In the result, the appeal filed by the Assessee stands allowed

ITA 2586/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Feb 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: Ms. Krupa Gandhi, Ld. A.RFor Respondent: Shri Biswanath Das, Ld. D.R

Section 115JSection 143(3)Section 147Section 14ASection 154Section 263

…hat case the relevant date for the purpose of determination of period of limitation for exercising powers under section 263 of the Act would be the date of the original Assessment Order" 2.3.5 Hon'ble Jurisdictional High Court in the case of ICICI Bank Ltd. (343 ITR 74) (Refer pg. no. 50 to 55 of LPB) held that where jurisdiction u/s 263 of the Act is sought to be exercised with reference to an issue which is covered by order of assessment u/s 143(3) of the Act and which does not form subject-matter of reassessment, limitation u/s 263(2) of the Act shall run from order u/s 143(3) of the Act. 2.3.6 Hon'ble Juris…

SHIV VEGPRO PRIVATE LIMITED ,KOTA vs. PCIT-UDAIPUR , UDAIPUR

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

ITA 1014/JPR/2024[2017-18]Status: DisposedITAT Jaipur28 Jan 2025AY 2017-18

For Appellant: Shri Mahendra Gargieya, (Adv.) &For Respondent: Mrs. Alka Gautam, (CIT-DR)

Section 147Section 263Section 36(1)(va)Section 43B

…2011 and not w.r.t. the reassessment order passed dated\n26.03.2015, relying upon certain decisions.\n10.5.6CIT v. Bharti Airtel Ltd (Supra Para 3.3) (DC )\n10.5.7 In Ashok Buildcon Ltd. Vs. ACIT (Supra Para 3.4) (DC)\n10.5.8 In CIT vs. ICICI Bank Ltd. (2012) 343 ITR 74/252 CTR 85 (Mum),\nheld that (DC ):\n\"Section 263 of the Income-tax Act, 1961 Revision Of orders\nprejudicial to interest of revenue - Assessment year 1996-97 - Whether\nwhere jurisdiction under section 263 is sought to be exercised with\nreference to an issue which is covered by original order of assessment\nunder section 143(3) and which does n…

LATITUDE INFRAVENTURES,NAGPUR vs. PCIT,NAGPUR-1, NAGPUR

In the result, appeal filed by the assessee for assessment year 2017–18

ITA 350/NAG/2024[2017-18]Status: DisposedITAT Nagpur22 Oct 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Sandipkumar Salunke

Section 143(1)Section 143(3)Section 147Section 148Section 263Section 263(2)

…3. Date of passing order u/s 263 limitation period Reliance is placed on following judicial precedents:  CIT v. Lark Chemicals Ltd. [2015] Taxmann.com 446 (Bombay) High Court of Bombay (Refer Pages 1 to 6 of legal paperbook)  CIT v. ICICI Bank Ltd. [2012] 19 Taxmann.com 142 (Bombay) High Court of Bombay (Refer Pages 7 to 13 of legal paperbook)  M/s Jainsons Agrochem Industries v. PCIT Writ petition no. 2136/2024 High Court of Rajasthan at Jodhpur (Refer Pages 29 to 38 of legal paperbook)  Indira Industries v. PCIT [2018] 95 Taxmann.com 103 (Madras) High Court of Madras. (Refer Pages 41 to 46 of legal paperb…

LATITUDE INFRAVENTURES,NAGPUR vs. PCIT,NAGPUR-1, NAGPUR

In the result, appeal filed by the assessee for assessment year 2017–18

ITA 349/NAG/2024[2016-17]Status: DisposedITAT Nagpur22 Oct 2024AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Sandipkumar Salunke

Section 143(1)Section 143(3)Section 147Section 148Section 263Section 263(2)

MCLEOD RUSSEL INDIA LTD.,KOLKATA vs. PCIT - 2, KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 984/KOL/2024[2016-2017]Status: DisposedITAT Kolkata12 Sept 2024AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 143(1)Section 144BSection 147Section 148Section 148(2)Section 197(9)Section 263Section 263(2)Section 37(1)

…ereas in the present case the order has been passed on 30.03.2024 and, therefore, the proceedings are barred by limitation. The Ld. AR in defense of his argument relied on the decision of Hon’ble Bombay High Court in the case of CIT Vs. ICICI Bank Ltd. [2012] 343 ITR 74 (Bom.) and decision of the Hon’ble Supreme Court in the case of CIT Vs. Alagendran Finance Ltd. [2007] 293 ITR 1(SC). The Ld. AR, therefore, prayed that the impugned revisionary order passed by the Ld. Pr. CIT is invalid and may be quashed. 6. Ld. DR, on the other hand, strongly opposed the contention of the Ld. AR of the assessee by submitting t…

VINAY BAWRI,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, GUWAHATI

In the result, the appeal of the assessee is allowed

ITA 42/GTY/2021[2013-14]Status: DisposedITAT Guwahati22 Sept 2023AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 153(3)Section 153ASection 154Section 263Section 263(1)

…e to be quashed. In defense of his argument, Ld. Counsel relied on the decision passed by the Hon’ble Supreme Court in the case of CIT vs Alagendran Finance Ltd (293 ITR 1) (SC) and by Hon’ble Bombay High Court in the case of CIT vs. ICICI Bank Limited (2012) 343 ITR 74 (Bom.). The ld. A.R. submitted that in both these decisions, the Hon’ble Courts have held that the two years period of limitation shall run from the end of financial year in which the original assessment was framed and not from the end of financial year in which the reassessment was framed when the issue on which the assessment was revised was not…

ZULU MERCHANDISE (P)LTD,KOLKATA vs. PCIT 2, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 380/KOL/2023[2012-13]Status: DisposedITAT Kolkata11 Jul 2023AY 2012-13

Bench: Sri Rajesh Kumar & Sonjoy Sarma

Section 143(3)Section 147Section 2Section 249Section 253Section 263Section 3Section 5

…sly barred by limitation by relying on the following decisions: (i) CIT –vs.- Alagendran Finance Limited (2007) 293 ITR 1 (SC); Page 7 of 12 I.T.A. No.: 380/KOL/2023 Assessment Year: 2012-13 Zulu Merchandise Pvt. Ltd. (ii) CIT –vs.- ICICI Bank Limited (2012) 343 ITR 74 (Bom.). 10. The Ld. D.R. on the other hand relied heavily on the order of LD. PCIT by submitting that the assessee is not put to any loss by the exercise of jurisdiction as the assessee would be given sufficient time and enough opportunity to present its case, therefore the appeal of the assessee may kindly be dismissed. 11. We have heard the riva…

KROSS LIMITED,JAMSHEDPUR vs. PCIT, RANCHI, RANCHI

In the result, the appeal of the assessee is allowed

ITA 34/RAN/2022[12-13]Status: DisposedITAT Ranchi06 Jun 2023

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 133(6)Section 143(3)Section 147Section 148Section 263Section 263(2)Section 56(2)(vii)

…t but it is barred by limitation and the assessment as farmed u/s 143(3) r.w.s 147 of the Act which is against the ratio laid down by the Hon’ble Supreme Court in the case of CIT vs Alagendran Finance Ltd (293 ITR 1) (SC) and CIT vs. ICICI Bank Limited (2012) 343 ITR 74 (Bom.). The ld. A.R. submitted that in both these decisions, the Hon’ble Courts have held that the two 4 AY: 2012-13 Kross Limited years period of limitation shall run from the end of financial year in which the original assessment was framed and not from the end of financial year in which the reassessment was framed when the issue on which the a…

BONJOUR ESTATES (P) LIMITED,NEW DELHI vs. PR.CIT-1, NEW DELHI

In the result appeal of the assessee partly allowed

ITA 732/DEL/2021[2010-11]Status: DisposedITAT Delhi11 Apr 2023AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri B.R.R. Kumarassessment Year: 2010-11 M/S. Bonjour Estates (P) Ltd., The Pcit (1), C-444, Defence Colony, New New Delhi 110002 Delhi 110024 Vs. Pan Aaecn 4851 H (Appellant) (Respondent) For Assessee : Shri Neeraj Mangla, Ca For Revenue : Shri P. Praveen Sidharth, Cit Dr

For Appellant: Shri Neeraj Mangla, CAFor Respondent: Shri P. Praveen Sidharth, CIT DR

Section 139Section 143(1)Section 143(3)Section 148Section 263

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: A: NEW DELHI BEFORE SHRI CHANDRA MOHAN GARG, JUDICIAL MEMBER AND SHRI B.R.R. KUMAR, ACCOUNTANT MEMBER Assessment Year: 2010-11 M/s. Bonjour Estates (P) Ltd., The PCIT (1), C-444, Defence Colony, New New Delhi 110002 Delhi 110024 vs. PAN AAECN 4851 H (Appellant) (Respondent) For Assessee : Shri Neeraj Mangla, CA For Revenue : Shri P. Praveen Sidharth, CIT DR Date of Hearing : 15.02.2023 Date of Pronouncement : 11.04.2023 ORDER PER CHANDRA MOHAN GARG, J.M. This appeal filed by the assessee is directed against the order dated 28.03.2021 of the Ld. PCIT(1), New Del…

M/S K.M. KHADIM & CO.,KOLKATA vs. PCIT-1, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 278/KOL/2022[2014-15]Status: DisposedITAT Kolkata21 Dec 2022AY 2014-15

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 263

…u/s 143(3) dated 26.12.2016 is also barred by limitation so the power of the Ld. PCIT can also not to be exercised by relying on the following decisions: (i) CIT –vs.- Alagendran Finance Limited (2007) 293 ITR 1 (SC); (ii) CIT –vs.- ICICI Bank Limited (2012) 343 ITR 74 (Bom.). 6. The Ld. D.R. on the other hand relied heavily on the order of LD. PCIT by submitting that the assessee is not put to any loss by the exercise of jurisdiction as the assessee would be given sufficient time and enough opportunity to present its case, therefore the appeal of the assessee may kindly be dismissed. 5 I.T.A. No. 278/Kol/2022…

MAYUR RICE MILLS PRIVATE LIMITED,JHUMRITELAIYA vs. PCIT, RANCHI

In the result, the appeal of the assessee is allowed

ITA 33/RAN/2022[2012-13]Status: DisposedITAT Ranchi02 Nov 2022AY 2012-13

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Rajesh Kumar, Hon’Bleassessment Year: 2012-13 Mayur Rice Mills Private Limited Pr. Cit, Ranchi Gujhandi Road Vs Vill – Barwadih, Jhumritelaiya Pin - 825409 Pan : Aafcm5928H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.K. Pransukha, A/R Revenue By : Shri Sanjay Mukherjee, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 21/09/2022 घोषणा क" तारीख /Date Of Pronouncement : 02/11/2022 आदेश/O R D E R Per Shri Rajesh Kumar: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Learned Principal Commissioner Of Income Tax (Appeals) - Ranchi (Hereinafter ‘Ld. Pr. Cit’), Dated 30/03/2022, Passed Under Section 263 Of The Income Tax Act, 1961 (In Short “The Act”), For Assessment Year 2012-13. 2. The Sole Issue Raised In The Various Grounds Of Appeal Is Against The Invalid Exercise Of Jurisdiction U/S 263 Of The Act By The Ld. Pr. Cit As The Revisionary Proceedings Are Hopelessly Barred By Limitation.

For Appellant: Shri S.K. Pransukha, A/RFor Respondent: Shri Sanjay Mukherjee, CIT, D/R

Section 133(6)Section 143(3)Section 147Section 263Section 263(2)Section 56(2)(vii)

…nt Year: 2012-13 Mayur Rice Mills Private Limited 4 of the Act but it is barred by limitation which is against the ratio laid down by the Hon’ble Supreme Court in the case of CIT vs Alagendran Finance Ltd (293 ITR 1) (SC) and CIT vs. ICICI Bank Limited (2012) 343 ITR 74 (Bom.). The ld. A.R. submitted that in both these decisions, the Hon’ble Courts have held that the two years period of limitation shall run from the end of financial year in which the original assessment was framed and not from the end of financial year in which the reassessment was framed when the issue on which the assessment was revised was not…

DEEPAK BAJAJ ,KOLKATA vs. ITO, WARD 40(1), KOLKATA

In the result, the appeal of the assessee is allowed

ITA 569/KOL/2021[2009-10]Status: DisposedITAT Kolkata30 Jun 2022AY 2009-10

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 263

…its arguments, the Ld. Counsel relied on the decision of Hon’ble Supreme Court in the case of CIT vs. Aagendran Finance Ltd. reported in [2007] 293 ITR 1 (SC) and also the decision of Hon’ble Bombay High Court in the case of CIT vs. ICICI Bank Limited (2012) 343 ITR 74 (Bom.). The Ld. Counsel for the assessee submitted that in both these decisions, the Hon’ble Courts have held that the two years period of limitation shall run from the end of financial year in which the original assessment was framed and not from the end of financial year in which the reassessment was framed when the issue on which the assessment…

M/S. RAVI FOUNDATION ,MUMBAI vs. PR. CIT-17, MUMBAI

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

ITA 884/MUM/2021[2010-11]Status: DisposedITAT Mumbai26 Apr 2022AY 2010-11

For Appellant: Ms. Arati AggarwalFor Respondent: Shri T. Shankar (Sr. AR)

Section 133ASection 143(3)Section 263Section 263(2)

…n 263(2) of the Act. In support of such contention, learned counsel relied upon the following decisions: - 1. CIT Vs. Alagendran Finance Ltd., [2007] 293 ITR 1 (SC) 2. Ashoka Buildcon Ltd. Vs. ACIT, [2010] 325 ITR 574 (Bom.) 3. CIT Vs. ICICI Bank Ltd., [2012] 343 ITR 74 (Bom.) 4. Indira Industries Vs. PCIT, [2018] 95 TAXMANN.COM 103 (Mad.) 5. CIT Vs. Lark Chemicals Ltd, [2014] 368 ITR 655 (Bom.) 6. CIT Vs. Bharti Airtel Ltd., [2013] 37 taxmann.com 218 (Del.) 7. CIT Vs. Shriram Engg. Construction Co. Ltd., [201 1] 330 ITR 568 (Mad.) 8. L.G.Electronics India (P.) Ltd. Vs. PCIT, [2016] 388 ITR 135 (All.) 9. Jin…

ALKEM LABORATORIES LTD,PATNA vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is allowed

ITA 23/PAT/2021[2014-15]Status: DisposedITAT Patna08 Mar 2022AY 2014-15

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 115JSection 143Section 143(3)Section 147Section 148Section 148(2)Section 154Section 263Section 263(1)Section 35

…se notice under section 263 of the Act was issued on 15.01.2021. In defence of his arguments , Ld. Sr. Counsel relied on the series of decisions, namely – (i) CIT –vs.- Alagendran Finance Limited (2007) 293 ITR 1 (SC); (ii) CIT –vs.- ICICI Bank Limited (2012) 343 ITR 74 (Bom.). The ld. A.R. submitted that in both these decisions, the Hon’ble Courts have held that the two years period of limitation shall run from the end of financial year in which the original assessment was framed and not from the end of financial year in which the reassessment was framed when the issue on which the assessment was revised was no…

ALKEM LABORATORIES LTD,PATNA vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is allowed

ITA 22/PAT/2021[2012-13]Status: DisposedITAT Patna08 Mar 2022AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 115JSection 143Section 143(3)Section 147Section 148Section 148(2)Section 154Section 263Section 263(1)Section 35

RAMESH KUMAR PUROHIT ,MUMBAI vs. PR. CIT,CITY-17, MUMBAI

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

ITA 692/MUM/2021[2011-12]Status: DisposedITAT Mumbai10 Jan 2022AY 2011-12

Bench: Ms. Suchitra Raghunath Kamble () & Shri Amarjit Singh () Assessment Year: 2011-12 Ramesh Kumar Purohit, Pr. Cit, City-17, Room No. 120, 1St Floor, Sahara Shopee, Shop No. 191, Off. Manish Market, S.S. Musafirkhana Road, Vs. Kautilya Bhavan, C-41 To C- Mumbai-400 001. 43, G Block, Bandra Kurla Complex, Bandra (E), Mumbai-400051. Pan No. Axmpp 6458 N Appellant Respondent

For Appellant: Mr. Prakash Jhunjhunwala, ARFor Respondent: Mr. D.K. Gupta, DR

Section 143(3)Section 147Section 263Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE MS. SUCHITRA RAGHUNATH KAMBLE (JUDICIAL MEMBER) AND SHRI AMARJIT SINGH (ACCOUNTANT MEMBER) Assessment Year: 2011-12 Ramesh Kumar Purohit, Pr. CIT, City-17, Room No. 120, 1st floor, Sahara Shopee, Shop No. 191, Off. Manish Market, S.S. Musafirkhana Road, Vs. Kautilya Bhavan, C-41 to C- Mumbai-400 001. 43, G Block, Bandra Kurla Complex, Bandra (E), Mumbai-400051. PAN No. AXMPP 6458 N Appellant Respondent Assessee by : Mr. Prakash Jhunjhunwala, AR Revenue by : Mr. D.K. Gupta, DR Date of Hearing : 23/12/2021 Date of pronouncement : 10/01/2022 ORDER…

JINDAL STEEL & POWER LTD.,HISAR vs. CIT, HISAR

In the result, appeal of the assessee is allowed

ITA 1462/DEL/2016[2005-06]Status: DisposedITAT Delhi16 Nov 2021AY 2005-06

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Sh. S. Najmi, CIT

Section 143(3)Section 147Section 263Section 263(2)Section 80

…ildcon Pvt. Ltd. vs. Pr. CIT - ITA No. 2648/Del/2016 has taken the similarview. It has similarly been held in the following decisions: AshokaBuildcon Ltd V. ACIT: 325 ITR 574 (Bom) CIT vs. Lark Chemicals Limited: 230 Taxman 305 CIT vs. ICICI Bank Limited: 343 ITR 74 (i) Claim of deduction u/s 80-IA/ IB already allowed by Hon ’ble IT AT 18. It is further submitted that the CIT exceeded his jurisdiction in setting aside the claim of deduction under sections 80-IA and 80- IB, even though the said claims were extensively examined and considered in the original assessment order dated 31.12.2007, which order stood…

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