What is CIT v. Kelvinator of India Ltd. authority for?

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

How many judgments cite CIT v. Kelvinator of India Ltd.?

1,673 judgments on BharatTax cite CIT v. Kelvinator of India Ltd. (320 ITR 561), spanning 2010 to 2026.

Which sections of the Income Tax Act does CIT v. Kelvinator of India Ltd. come up under?

It is most often cited in judgments turning on Section 147, Section 143(3), Section 148, Section 142(1), Section 151, Section 143(2).

CIT v. Kelvinator of India Ltd. (320 ITR 561)

M/S. Repco Home Finance Ltd., Chennai vs. ACIT, Chennai

In the result, the appeal of assessee in ITA No

ITA 2733/CHNY/2016[2012-13]Status: DisposedITAT Chennai20 Sept 2017AY 2012-13

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojari]

For Appellant: Mr.M.Viswanathan, C.A ""For Respondent: Dr.S.Sundaresan

Section 143(3)Section 147Section 148Section 36

…that the AO had got ‘tangible materials’ to exercise his power to reopen the concluded assessment. Hence, the present notice issued u/s.148 of the Act is totally without jurisdiction and he relied on the decision in the case of CIT vs. Kelvinator India Ltd.(320 ITR 561(SC) ) to support his view. ITA Nos.2732 & 2733/16 :- 4 -: 5. The ld. DR, relied on the order of the CIT(Appeals). 6. We have heard both the parties and perused the material on record. The main contention of ld.A.R is that in this case the original assessment was completed u/s.143(3) of the Act on 29.11.2011. The assessee has furnished all de…

M/S. Repco Home Finance Ltd., Chennai vs. ACIT, Chennai

In the result, the appeal of assessee in ITA No

ITA 2732/CHNY/2016[2009-10]Status: DisposedITAT Chennai20 Sept 2017AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojari]

For Appellant: Mr.M.Viswanathan, C.A ""For Respondent: Dr.S.Sundaresan

Section 143(3)Section 147Section 148Section 36

…that the AO had got ‘tangible materials’ to exercise his power to reopen the concluded assessment. Hence, the present notice issued u/s.148 of the Act is totally without jurisdiction and he relied on the decision in the case of CIT vs. Kelvinator India Ltd.(320 ITR 561(SC) ) to support his view. ITA Nos.2732 & 2733/16 :- 4 -: 5. The ld. DR, relied on the order of the CIT(Appeals). 6. We have heard both the parties and perused the material on record. The main contention of ld.A.R is that in this case the original assessment was completed u/s.143(3) of the Act on 29.11.2011. The assessee has furnished all de…

ACIT, Chennai vs. Shree Laxmi Jewellery Pvt. Ltd., Chennai

In the result, the cross objection of the assessee is allowed and appeal of the Revenue is dismissed in limini

ITA 3345/CHNY/2016[2009-10]Status: DisposedITAT Chennai12 Sept 2017AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकरअपीलसं./I.T.A.No.3345/Mds/2016 ("नधा"रणवष" / Assessment Year: 2009-10) Vs M/S. Shree Laxmi Jewellery Pvt. The Acit, Central Circle – 1(3), Ltd., Chennai – 34. No.99, Usman Road, T.Nagar, Chennai – 600 017. Pan: Aaacl1289M (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co No.15/Mds/2017 (In Ita No.3345/Mds/2016) Vs The Acit, M/S. Shree Laxmi Jewellery Pvt. Ltd., Central Circle – 1(3), No.99, Usman Road, T.Nagar, Chennai – 34. Chennai – 600 017. Pan: Aaacl1289M (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: 01.08.2017For Respondent: Shri T. Banusekar, FCA

Section 143(3)Section 147Section 148Section 250(6)

…आयकर अपील"य अ"धकरण, ‘ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL , ‘A’ BENCH, CHENNAI "ी एन "ी एन.आर आर.एस एस. गणेशन गणेशन,"याियक "याियक सद"य सद"य एवं एवं "ी "ी ए. मोहन मोहन अलंकामणी अलंकामणी,लेखा लेखा सद"य सद"य केकेकेके सम" सम" "ी "ी एन एन आर आर एस एस गणेशन गणेशन "याियक "याियक सद"य सद"य एवं एवं "ी "ी मोहन मोहन अलंकामणी अलंकामणी लेखा लेखा सद"य सद"य सम" सम" BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER AND SHRI A. MOHAN ALANKAMONY, ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.No.3345/Mds/2016 ("नधा"रणवष" / Assessment Year: 2009-10) Vs M/s. Shree Laxmi Jewellery Pvt. The ACIT, Central Circle – 1(3), Ltd., Chennai –…

The Principal Commissioner of Income Tax-1 vs. M/s Devi Sea Foods Ltd

ITTA/521/2017HC Telangana11 Sept 2017

…HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Special Appeal Writ No. 491/2017 M/s. HCL Infosystems Limited, Having its address at E-232A, Ram Nagar Extension, Sodala, Jaipur and through its Authorized Signatory Smt. Bhavna Kapoor now through its Authorized Signatory Mr. Vikas Jain ----Appellant Versus 1. State Of Rajasthan, Through The Principal Secretary Finance, Tax Division, Finance Department, Having Its Address At Secretariat, Jaipur In The State Of Rajasthan. 2. Commissioner Commercial Taxes, Rajasthan Having Its Address At Kar Bhawan, Bhagwandas Road, Ambedka…

ACIT - 19(1), Mumbai vs. Ganesh J. Modi, Mumbai

In the result, the appeal for the AY 2010-11 of the assessee and the revenue are allowed for statistical purposes

ITA 2770/MUM/2016[2008-09]Status: DisposedITAT Mumbai08 Sept 2017AY 2008-09

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 Ganesh J Modi Acit Circle 19(1), 115/28 J.K. Building, Dr. M Vs. Room No. 203, 2Nd G Mahimtura Marg, Floor, Matru Mandir, 3Rdkumbharwada, Tardeo, Mumbai-400004 Mumbai-400007 Pan No. Aacpm0690C (Appellant) (Respondent) Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 Acit Circle 19(1), Ganesh J Modi Room No. 203, 2Nd Vs. 115/28 J.K. Building, Dr. M Floor, Matru Mandir, G Mahimtura Marg, 3Rd Tardeo, Kumbharwada, Mumbai-400007 Mumbai-400004 Pan No. Aacpm0690C (Appellant) (Respondent) Assessee By : Shri Sanjiv M. Shah, Ar Revenue By: Shri Saurabh Kumar Rai, Dr Date Of Hearing : 13/06/2017 Date Of Pronouncement: 08/09/2017

For Appellant: Shri Sanjiv M. Shah, ARFor Respondent: Shri Saurabh Kumar Rai, DR

Section 133(6)Section 143Section 143(3)

…We refer here to page 36-39 of the Paper Book (P/B) filed before the Tribunal. In CIT vs. Bhanji Lavji (1971) 79 ITR 582 (SC), it has been held that an assessment cannot be reopened only because of change of opinion. In CIT vs. Kelvinator of India Ltd. (2010) 320 ITR 561 (SC), it is held that (i) after substitution of section 147 by the Direct Tax Laws (Amendment) Act, 1987, concept of ‘change of opinion’ must be treated as an in-built test to check abuse of power by the Assessing Officer and (ii) after 01.04.1989, the Assessing Officer has power to reopen, provided there is ‘tangible material’ to come to conclus…

Ganesh J Modi, Mumbai vs. Asst CIT Cir 19(1), Mumbai

In the result, the appeal for the AY 2010-11 of the assessee and the revenue are allowed for statistical purposes

ITA 1967/MUM/2016[2008-09]Status: DisposedITAT Mumbai08 Sept 2017AY 2008-09

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 Ganesh J Modi Acit Circle 19(1), 115/28 J.K. Building, Dr. M Vs. Room No. 203, 2Nd G Mahimtura Marg, Floor, Matru Mandir, 3Rdkumbharwada, Tardeo, Mumbai-400004 Mumbai-400007 Pan No. Aacpm0690C (Appellant) (Respondent) Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2010-11 Acit Circle 19(1), Ganesh J Modi Room No. 203, 2Nd Vs. 115/28 J.K. Building, Dr. M Floor, Matru Mandir, G Mahimtura Marg, 3Rd Tardeo, Kumbharwada, Mumbai-400007 Mumbai-400004 Pan No. Aacpm0690C (Appellant) (Respondent) Assessee By : Shri Sanjiv M. Shah, Ar Revenue By: Shri Saurabh Kumar Rai, Dr Date Of Hearing : 13/06/2017 Date Of Pronouncement: 08/09/2017

For Appellant: Shri Sanjiv M. Shah, ARFor Respondent: Shri Saurabh Kumar Rai, DR

Section 133(6)Section 143Section 143(3)

…We refer here to page 36-39 of the Paper Book (P/B) filed before the Tribunal. In CIT vs. Bhanji Lavji (1971) 79 ITR 582 (SC), it has been held that an assessment cannot be reopened only because of change of opinion. In CIT vs. Kelvinator of India Ltd. (2010) 320 ITR 561 (SC), it is held that (i) after substitution of section 147 by the Direct Tax Laws (Amendment) Act, 1987, concept of ‘change of opinion’ must be treated as an in-built test to check abuse of power by the Assessing Officer and (ii) after 01.04.1989, the Assessing Officer has power to reopen, provided there is ‘tangible material’ to come to conclus…

DCIT 9(1)(1), Mumbai vs. Acon Measurement P.Ltd, Mumbai

The appeal of the Revenue is dismissed and the

ITA 4736/MUM/2015[2009-10]Status: DisposedITAT Mumbai06 Sept 2017AY 2009-10

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2009-10 Dcit -9(1))(1), M/S Acon Measurement Pvt. Room No.260A, 02Nd Floor बनाम/ Limited, Aayakar Bhavan A-22, Nanddham Indl. Estate, Vs. M.K. Road Marol Maroshi Road, Mumbai-400020. Andheri (East), Mumbai-400059 (राज"व /Revenue) ("नधा"रती /Assessee) Pan. No. Aaaca5078K

Section 133(6)

…k Ltd. [(2013) 357 ITR 448 (Ker)]; xvi. Sitara Diamond Pvt. Ltd. v. ITO [(2013) 358 ITR 424 (Bom)]; xvii. Rayala Corporation P. Ltd. v. Asst. CIT [(2014) 363 ITR 630 (Mad)]. 4.26. So far as, the decision in the case of CIT vs Kelvinator of India Ltd. (2010) 320 ITR 561 (SC) is concerned, the Hon’ble Apex Court, while coming to a particular conclusion, only in a situation, when not a single piece of paper C.O. No.112/Mum/2017 or document was recovered, therefore, the Hon’ble Court held that since there was no tangible material found and the addition was merely on the basis of statement only then reopening o…

ACIT, Jaipur vs. State Bank of Bikaner & Jaipur, Jaipur

Appeal is dismissed

ITA 41/JPR/2010[2007-08]Status: DisposedITAT Jaipur29 Aug 2017AY 2007-08

For Appellant: Shri P.C. Parwal (CA)For Respondent: Smt. Rolly Agarwal (CIT)

Section 14ASection 36(1)(viia)

…5. Action of the AO of reassessment constitutes change of opinion as per Ape Court decision: Following decisions of Hon’ble Supreme Court relied upon by the appellant in submission dated 16-10-2012 do not justify reopening: 1. CIT vs. Kelvinator of India Ltd. 320 ITR 561/187 Taxman 312 (SC) The concept of “change of opinion” on the part of the Assessing Officer to reopen as assessment does not stand obliterated after ht substitution of section 147 of the Income-tax At, 1961, by the Direct Tax Laws (Amendment) Acts, 1987 and 1989. After the amendment, the Assessing Officer has to have reason to believe that incom…

M/S S B B J, Jaipur vs. ACIT, Jaipur

Appeal is dismissed

ITA 921/JPR/2009[2007-08]Status: DisposedITAT Jaipur29 Aug 2017AY 2007-08

For Appellant: Shri P.C. Parwal (CA)For Respondent: Smt. Rolly Agarwal (CIT)

Section 14ASection 36(1)(viia)

…5. Action of the AO of reassessment constitutes change of opinion as per Ape Court decision: Following decisions of Hon’ble Supreme Court relied upon by the appellant in submission dated 16-10-2012 do not justify reopening: 1. CIT vs. Kelvinator of India Ltd. 320 ITR 561/187 Taxman 312 (SC) The concept of “change of opinion” on the part of the Assessing Officer to reopen as assessment does not stand obliterated after ht substitution of section 147 of the Income-tax At, 1961, by the Direct Tax Laws (Amendment) Acts, 1987 and 1989. After the amendment, the Assessing Officer has to have reason to believe that incom…

The Pr. Commissioner of Income -Tax-6 vs. M/s. B.Surendra Chowdary

ITTA/519/2017HC Telangana21 Aug 2017

…HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Special Appeal Writ No. 491/2017 M/s. HCL Infosystems Limited, Having its address at E-232A, Ram Nagar Extension, Sodala, Jaipur and through its Authorized Signatory Smt. Bhavna Kapoor now through its Authorized Signatory Mr. Vikas Jain ----Appellant Versus 1. State Of Rajasthan, Through The Principal Secretary Finance, Tax Division, Finance Department, Having Its Address At Secretariat, Jaipur In The State Of Rajasthan. 2. Commissioner Commercial Taxes, Rajasthan Having Its Address At Kar Bhawan, Bhagwandas Road, Ambedka…

Crr Leathers, Chennai vs. ITO, Chennai

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

ITA 616/CHNY/2017[2008-09]Status: DisposedITAT Chennai21 Aug 2017AY 2008-09

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.616/Mds/2017 "नधा"रण वष"/Assessment Year:2008-09 M/S. Crr Leathers, The Income Tax Officer, 9/5, Patnool Sardarjung Street, Vs. Non Corporate Ward 4(3), Periamet, Chennai 600 003. Chennai 600 006. [Pan: Aaafc4173G] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri K. Ravi, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 08.06.2017 घोषणा क" तार"ख /Date Of Pronouncement : 21.08.2017 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 5, Chennai Dated 27.10.2016 Relevant To The Assessment Year 2008-09, Wherein, In The Grounds Appeal, Besides Challenging The Confirmation Of Various Additions For Want Of Tds Under Section 195 Of The Income Tax Act, 1961 [“Act” In Short], The Assessee Has Mainly Challenged Confirmation Of Reopening Of Assessment, Which Is Barred By Limitation.

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri K. Ravi, JCIT

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 195Section 40

…me would amount to giving a premium to an authority exercising quasi- judicial function to take benefit of its own wrong.” 17. The above said decision of the Full Bench of the Delhi High Court was upheld by the Supreme Court in the decision reported in [2010] 320 ITR 561 (SC) Commissioner of Income-Tax - Vs - Kelvinator of India Ltd., wherein the Supreme Court held that the concept of "change of opinion" on the part of the Assessing Officer to reopen the assessment did not stand obliterated after the substitution of Section 147 of the Income Tax Act. The Supreme Court also held that the Assessing Officer has powe…

DCIT, Circle-5(2), Kolkata vs. M/S. Balmer Lawrie & Co. Ltd., Kolkata

In the result the appeal by the revenue is dismissed

ITA 81/KOL/2015[2002-2003]Status: DisposedITAT Kolkata18 Aug 2017AY 2002-2003

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Shri M.Balaganesh, Am ] Assessment Year : 2002-03

For Appellant: Shri Anand R.Baiwar, CITFor Respondent: Shri N.K.Poddar, Sr. Advocate

Section 115JSection 142Section 143(3)Section 148

…also submitted that the reassessment proceedings have been initiated by the AO purely on the basis of change of opinion and in this regard the assessee placed reliance on the decision of the Hon’ble Supreme Court in the case of CIT vs Kelvinator of India Ltd. 320 ITR 561 (SC). 12. After considering the submissions of the AO, who relied on the decision of Hon’ble Gujarat High Court in the case of Gujarat Power Corporation Limited vs ACIT 350 ITR 266 (Guj) and CIT vs Sun Engineering Works Pvt. Ltd. 198 ITR 297 ITA No.81/Kol/2015 M/s. Balmer Lawrie & Co.Ltd A.Y.2002-03 5 (SC) the CIT(A) held that the initiation o…

ACIT, Chennai vs. Kasturi & Sons Limited, Chennai

In the result, all the Revenue’s appeals are allowed for statistical purposes

ITA 2252/CHNY/2015[2011-12]Status: DisposedITAT Chennai18 Aug 2017AY 2011-12

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Sh. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri R. Jeyakumar, CIT

Section 143(1)Section 148

…e 3 I.T.A. Nos.1611 to 1619/Mds/14 I.T.A. No. 2106/Mds/15 I.T.A. Nos.2012 to 2015/Mds/14 I.T.A. No.2252/Mds/15 reopening of assessment is only change of opinion. He placed his reliance on the judgment of Apex Court in CIT v. Kelvinator India Ltd. (2010) (320 ITR 561). 4. On the contrary, Shri R. Jeyakumar, the Ld. Departmental Representative, submitted that the return was originally processed under Section 143(1) of the Act. The return of the assessee for assessment year 2008-09 was taken for scrutiny. According to the Ld. D.R., on verification of ledger and other details for assessment year 2008-09, the…

Kasturi and Sons Ltd., Chennai vs. DCIT, Chennai

In the result, all the Revenue’s appeals are allowed for statistical purposes

ITA 2106/CHNY/2015[2011-12]Status: DisposedITAT Chennai18 Aug 2017AY 2011-12

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Sh. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri R. Jeyakumar, CIT

Section 143(1)Section 148

…e 3 I.T.A. Nos.1611 to 1619/Mds/14 I.T.A. No. 2106/Mds/15 I.T.A. Nos.2012 to 2015/Mds/14 I.T.A. No.2252/Mds/15 reopening of assessment is only change of opinion. He placed his reliance on the judgment of Apex Court in CIT v. Kelvinator India Ltd. (2010) (320 ITR 561). 4. On the contrary, Shri R. Jeyakumar, the Ld. Departmental Representative, submitted that the return was originally processed under Section 143(1) of the Act. The return of the assessee for assessment year 2008-09 was taken for scrutiny. According to the Ld. D.R., on verification of ledger and other details for assessment year 2008-09, the…

DCIT, Chennai vs. Kasturi and Sons Ltd., Chennai

In the result, all the Revenue’s appeals are allowed for statistical purposes

ITA 2015/CHNY/2014[2010-11]Status: DisposedITAT Chennai18 Aug 2017AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Sh. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri R. Jeyakumar, CIT

Section 143(1)Section 148

…e 3 I.T.A. Nos.1611 to 1619/Mds/14 I.T.A. No. 2106/Mds/15 I.T.A. Nos.2012 to 2015/Mds/14 I.T.A. No.2252/Mds/15 reopening of assessment is only change of opinion. He placed his reliance on the judgment of Apex Court in CIT v. Kelvinator India Ltd. (2010) (320 ITR 561). 4. On the contrary, Shri R. Jeyakumar, the Ld. Departmental Representative, submitted that the return was originally processed under Section 143(1) of the Act. The return of the assessee for assessment year 2008-09 was taken for scrutiny. According to the Ld. D.R., on verification of ledger and other details for assessment year 2008-09, the…

DCIT, Chennai vs. Kasturi and Sons Ltd., Chennai

In the result, all the Revenue’s appeals are allowed for statistical purposes

ITA 2014/CHNY/2014[2009-10]Status: DisposedITAT Chennai18 Aug 2017AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Sh. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri R. Jeyakumar, CIT

Section 143(1)Section 148

…e 3 I.T.A. Nos.1611 to 1619/Mds/14 I.T.A. No. 2106/Mds/15 I.T.A. Nos.2012 to 2015/Mds/14 I.T.A. No.2252/Mds/15 reopening of assessment is only change of opinion. He placed his reliance on the judgment of Apex Court in CIT v. Kelvinator India Ltd. (2010) (320 ITR 561). 4. On the contrary, Shri R. Jeyakumar, the Ld. Departmental Representative, submitted that the return was originally processed under Section 143(1) of the Act. The return of the assessee for assessment year 2008-09 was taken for scrutiny. According to the Ld. D.R., on verification of ledger and other details for assessment year 2008-09, the…

DCIT, Chennai vs. Kasturi and Sons Ltd., Chennai

In the result, all the Revenue’s appeals are allowed for statistical purposes

ITA 2013/CHNY/2014[2008-09]Status: DisposedITAT Chennai18 Aug 2017AY 2008-09

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Sh. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri R. Jeyakumar, CIT

Section 143(1)Section 148

…e 3 I.T.A. Nos.1611 to 1619/Mds/14 I.T.A. No. 2106/Mds/15 I.T.A. Nos.2012 to 2015/Mds/14 I.T.A. No.2252/Mds/15 reopening of assessment is only change of opinion. He placed his reliance on the judgment of Apex Court in CIT v. Kelvinator India Ltd. (2010) (320 ITR 561). 4. On the contrary, Shri R. Jeyakumar, the Ld. Departmental Representative, submitted that the return was originally processed under Section 143(1) of the Act. The return of the assessee for assessment year 2008-09 was taken for scrutiny. According to the Ld. D.R., on verification of ledger and other details for assessment year 2008-09, the…

DCIT, Chennai vs. Kasturi and Sons Ltd., Chennai

In the result, all the Revenue’s appeals are allowed for statistical purposes

ITA 2012/CHNY/2014[2007-08]Status: DisposedITAT Chennai18 Aug 2017AY 2007-08

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Sh. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri R. Jeyakumar, CIT

Section 143(1)Section 148

…e 3 I.T.A. Nos.1611 to 1619/Mds/14 I.T.A. No. 2106/Mds/15 I.T.A. Nos.2012 to 2015/Mds/14 I.T.A. No.2252/Mds/15 reopening of assessment is only change of opinion. He placed his reliance on the judgment of Apex Court in CIT v. Kelvinator India Ltd. (2010) (320 ITR 561). 4. On the contrary, Shri R. Jeyakumar, the Ld. Departmental Representative, submitted that the return was originally processed under Section 143(1) of the Act. The return of the assessee for assessment year 2008-09 was taken for scrutiny. According to the Ld. D.R., on verification of ledger and other details for assessment year 2008-09, the…

Kasturi and Sons Ltd., Chennai vs. DCIT, Chennai

In the result, all the Revenue’s appeals are allowed for statistical purposes

ITA 1619/CHNY/2014[2010-11]Status: DisposedITAT Chennai18 Aug 2017AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Sh. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri R. Jeyakumar, CIT

Section 143(1)Section 148

…e 3 I.T.A. Nos.1611 to 1619/Mds/14 I.T.A. No. 2106/Mds/15 I.T.A. Nos.2012 to 2015/Mds/14 I.T.A. No.2252/Mds/15 reopening of assessment is only change of opinion. He placed his reliance on the judgment of Apex Court in CIT v. Kelvinator India Ltd. (2010) (320 ITR 561). 4. On the contrary, Shri R. Jeyakumar, the Ld. Departmental Representative, submitted that the return was originally processed under Section 143(1) of the Act. The return of the assessee for assessment year 2008-09 was taken for scrutiny. According to the Ld. D.R., on verification of ledger and other details for assessment year 2008-09, the…

Kasturi and Sons Ltd., Chennai vs. DCIT, Chennai

In the result, all the Revenue’s appeals are allowed for statistical purposes

ITA 1618/CHNY/2014[2009-10]Status: DisposedITAT Chennai18 Aug 2017AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Sh. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri R. Jeyakumar, CIT

Section 143(1)Section 148

…e 3 I.T.A. Nos.1611 to 1619/Mds/14 I.T.A. No. 2106/Mds/15 I.T.A. Nos.2012 to 2015/Mds/14 I.T.A. No.2252/Mds/15 reopening of assessment is only change of opinion. He placed his reliance on the judgment of Apex Court in CIT v. Kelvinator India Ltd. (2010) (320 ITR 561). 4. On the contrary, Shri R. Jeyakumar, the Ld. Departmental Representative, submitted that the return was originally processed under Section 143(1) of the Act. The return of the assessee for assessment year 2008-09 was taken for scrutiny. According to the Ld. D.R., on verification of ledger and other details for assessment year 2008-09, the…

CIT v. Kelvinator of India Ltd.

What is CIT v. Kelvinator of India Ltd. authority for?

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

Judgments citing CIT v. Kelvinator of India Ltd.

M/S. Repco Home Finance Ltd., Chennai vs. ACIT, Chennai

M/S. Repco Home Finance Ltd., Chennai vs. ACIT, Chennai

ACIT, Chennai vs. Shree Laxmi Jewellery Pvt. Ltd., Chennai

The Principal Commissioner of Income Tax-1 vs. M/s Devi Sea Foods Ltd

ACIT - 19(1), Mumbai vs. Ganesh J. Modi, Mumbai

Ganesh J Modi, Mumbai vs. Asst CIT Cir 19(1), Mumbai

DCIT 9(1)(1), Mumbai vs. Acon Measurement P.Ltd, Mumbai

ACIT, Jaipur vs. State Bank of Bikaner & Jaipur, Jaipur

M/S S B B J, Jaipur vs. ACIT, Jaipur

The Pr. Commissioner of Income -Tax-6 vs. M/s. B.Surendra Chowdary

Crr Leathers, Chennai vs. ITO, Chennai

DCIT, Circle-5(2), Kolkata vs. M/S. Balmer Lawrie & Co. Ltd., Kolkata

ACIT, Chennai vs. Kasturi & Sons Limited, Chennai

Kasturi and Sons Ltd., Chennai vs. DCIT, Chennai

DCIT, Chennai vs. Kasturi and Sons Ltd., Chennai

DCIT, Chennai vs. Kasturi and Sons Ltd., Chennai

DCIT, Chennai vs. Kasturi and Sons Ltd., Chennai

DCIT, Chennai vs. Kasturi and Sons Ltd., Chennai

Kasturi and Sons Ltd., Chennai vs. DCIT, Chennai

Kasturi and Sons Ltd., Chennai vs. DCIT, Chennai