CIT v. Mrs. Sandhya P. Naik

253 ITR 534High Court2002#1914 most cited

What is CIT v. Mrs. Sandhya P. Naik authority for?

The period during which a restraint order issued under section 132(3) of the Income-tax Act, 1961, remains in force must be excluded when calculating the period of limitation for completing an assessment, particularly for search assessments.

60

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2026.

Also referred to as

CIT v. Mrs. Sandhya P. Naik · Section 132(3) restraint order · period of limitation · search assessment · Section 153B · time-barred assessment · exclusion of period · warrant of authorisation · Section 132(5) limitation · VLS Finance Ltd.

Sections most often in play

Section 153BSection 132(3)Section 132(8A)Section 153ASection 115BBESection 68Section 69CSection 250

Issues it is cited on

section 132(5)section 132(3)section 132(2)section 65(b)section 158besection 65asection 153b(1)(a)section 62section 119(1)warrant of authorisationsection 153(2)time barred assessment

Judgments citing CIT v. Mrs. Sandhya P. Naik

AMOLAK SINGH BHATIA,BILASPUR vs. DCIT,CENTRAL CIRCLE-08, DELHI

ITA 3502/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Jan 2026AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 139Section 143(2)Section 153Section 153ASection 153DSection 246

…7 Taxman 380/308 ITR 168 (Delhi). (v) PCIT Central v. Hitesh Ashok Vaswani, 2011 (11) TMI 347- Gujarat High Court (vi) C. Ramaiah Reddy v. Assistant Commissioner of Income-tax, /[2011] 339 ITR 210 (Karnataka) (vii) CIT v. Sandhya P. Naik [2002] 124 Taxman 384/253 ITR 534 (Bom.). (viii) CIT v. T.S. Chandrasekhar [2009] 221 CTR 385 (Kar.). (ix) Mohd Yasin v. CIT [2017] 84 taxmann.com 292/398 ITR 33 (Raj.). (x) CIT v. White & White Mineral (P.) Ltd. [2011] 12 taxmann.com 120/200 Taxman 192 (Mag.)/330 ITR 172 (Raj.). (xi) CIT v. Om Prakash Mandora [2013] 37 taxmann.com 426/[2014] 222 Taxman 138 (Raj.). (xii) M/s. Pol…

MR ISMAIL MUHAMMAD KHAN ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 4289/MUM/2023[2018-19]Status: DisposedITAT Mumbai20 Jun 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

MR ISMAIL MUHAMMAD KHAN,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 4288/MUM/2023[2019-20]Status: DisposedITAT Mumbai20 Jun 2025AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

MR ISMAIL MUHAMMAD KHAN ,MUMBAI vs. ASSISATNT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 4286/MUM/2023[2020-21]Status: DisposedITAT Mumbai20 Jun 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

ISMAIL MUHAMMAD KHAN,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(2), MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 4273/MUM/2023[2016-17]Status: DisposedITAT Mumbai20 Jun 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

ISMAIL MUHAMMAD KHAN,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME, CENTRAL CIRCLE-1 (2),, MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 4272/MUM/2023[2017-18]Status: DisposedITAT Mumbai20 Jun 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

ISMAIL MUHAMMAD KHAN,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), MUMBAI

In the result all the appeals filed by both the\nassessees are stands allowed

ITA 4267/MUM/2023[2011-12]Status: DisposedITAT Mumbai20 Jun 2025AY 2011-12
Section 153ASection 250Section 68Section 69C

…and the restraint order u/s\n132(3) has not been considered for the purpose of\ncalculating period of limitation.\n\n42. In-fact the Hon'ble Delhi High court in VLS Finance\nLtd considered the Bombay High court decision in CIT v.\nMrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and\nheld that same was not applicable in the facts before it.\nThus the law laid down in CIT v Mrs Sandhya P.\nNaik(Supra) was not challenged and same continues to\nhold the field.\n\nEven the decision of Hon'ble Supreme Court in Anil\nMinda v CIT (2023) 148 taxmann.com 407 (SC) is not\napplicable to the facts of the present case for the…

M/S. INDEX LOGISTICS PVT LTD,MUMBAI vs. ACIT CC 1 (2), MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 3362/MUM/2023[2018-19]Status: DisposedITAT Mumbai20 Jun 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

M/S. INDEX LOGISTICS PVT LTD,MUMBAI vs. ACIT CC 1 (2), MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 3361/MUM/2023[2019-20]Status: DisposedITAT Mumbai20 Jun 2025AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

M/S. INDEX LOGISTICS PVT LTD,MUMBAI vs. ACIT CC 1 (2), MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 3360/MUM/2023[2020-21]Status: DisposedITAT Mumbai20 Jun 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

M/S. INDEX LOGISTICS PVT LTD,MUMBAI vs. ACIT CC 1 (2), MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 3347/MUM/2023[2016-17]Status: DisposedITAT Mumbai20 Jun 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

M/S. INDEX LOGISTICS PVT LTD,MUMBAI vs. ACIT CC 1 (2), MUMBAI

In the result all the appeals filed by both the assessees are stands allowed

ITA 3346/MUM/2023[2017-18]Status: DisposedITAT Mumbai20 Jun 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 153ASection 250Section 68Section 69C

…cepted and the restraint order u/s 132(3) has not been considered for the purpose of calculating period of limitation. 42. In-fact the Hon’ble Delhi High court in VLS Finance Ltd considered the Bombay High court decision in CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and held that same was not applicable in the facts before it. Thus the law laid down in CIT v Mrs Sandhya P. Naik(Supra) was not challenged and same continues to hold the field. Even the decision of Hon’ble Supreme Court in Anil Minda v CIT (2023) 148 taxmann.com 407 (SC) is not applicable to the facts of the present case for the followin…

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 180/VIZ/2023[2020-21]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ama drawn on 14-9-1998 which was the last for the purpose of reckoning the commencement of the limitation period. The Court examined various decisions including Dr. C. Balakrishna Nair v. CIT [1999] 237 ITR 70 (Ker.) 27 and CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and concluded as under :— "A general consensus appears to have emerged among the High Courts to the effect that a search under section 132 of the Act should be continuous and if it is discontinued and thereafter resumed, then there must be a valid explanation for the gap. Insofar as the present case is concerned, the facts on record show t…

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 179/VIZ/2023[2019-20]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ama drawn on 14-9-1998 which was the last for the purpose of reckoning the commencement of the limitation period. The Court examined various decisions including Dr. C. Balakrishna Nair v. CIT [1999] 237 ITR 70 (Ker.) 27 and CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and concluded as under :— "A general consensus appears to have emerged among the High Courts to the effect that a search under section 132 of the Act should be continuous and if it is discontinued and thereafter resumed, then there must be a valid explanation for the gap. Insofar as the present case is concerned, the facts on record show t…

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 178/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ama drawn on 14-9-1998 which was the last for the purpose of reckoning the commencement of the limitation period. The Court examined various decisions including Dr. C. Balakrishna Nair v. CIT [1999] 237 ITR 70 (Ker.) 27 and CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and concluded as under :— "A general consensus appears to have emerged among the High Courts to the effect that a search under section 132 of the Act should be continuous and if it is discontinued and thereafter resumed, then there must be a valid explanation for the gap. Insofar as the present case is concerned, the facts on record show t…

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 177/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ama drawn on 14-9-1998 which was the last for the purpose of reckoning the commencement of the limitation period. The Court examined various decisions including Dr. C. Balakrishna Nair v. CIT [1999] 237 ITR 70 (Ker.) 27 and CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and concluded as under :— "A general consensus appears to have emerged among the High Courts to the effect that a search under section 132 of the Act should be continuous and if it is discontinued and thereafter resumed, then there must be a valid explanation for the gap. Insofar as the present case is concerned, the facts on record show t…

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 176/VIZ/2023[2016-17]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ama drawn on 14-9-1998 which was the last for the purpose of reckoning the commencement of the limitation period. The Court examined various decisions including Dr. C. Balakrishna Nair v. CIT [1999] 237 ITR 70 (Ker.) 27 and CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and concluded as under :— "A general consensus appears to have emerged among the High Courts to the effect that a search under section 132 of the Act should be continuous and if it is discontinued and thereafter resumed, then there must be a valid explanation for the gap. Insofar as the present case is concerned, the facts on record show t…

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 175/VIZ/2023[2015-16]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ama drawn on 14-9-1998 which was the last for the purpose of reckoning the commencement of the limitation period. The Court examined various decisions including Dr. C. Balakrishna Nair v. CIT [1999] 237 ITR 70 (Ker.) 27 and CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and concluded as under :— "A general consensus appears to have emerged among the High Courts to the effect that a search under section 132 of the Act should be continuous and if it is discontinued and thereafter resumed, then there must be a valid explanation for the gap. Insofar as the present case is concerned, the facts on record show t…

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 174/VIZ/2023[2014-15]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ama drawn on 14-9-1998 which was the last for the purpose of reckoning the commencement of the limitation period. The Court examined various decisions including Dr. C. Balakrishna Nair v. CIT [1999] 237 ITR 70 (Ker.) 27 and CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and concluded as under :— "A general consensus appears to have emerged among the High Courts to the effect that a search under section 132 of the Act should be continuous and if it is discontinued and thereafter resumed, then there must be a valid explanation for the gap. Insofar as the present case is concerned, the facts on record show t…

POLISETTY SOMASUNDARAM,GUNTUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 173/VIZ/2023[2013-14]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…ama drawn on 14-9-1998 which was the last for the purpose of reckoning the commencement of the limitation period. The Court examined various decisions including Dr. C. Balakrishna Nair v. CIT [1999] 237 ITR 70 (Ker.) 27 and CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534 (Bom.) and concluded as under :— "A general consensus appears to have emerged among the High Courts to the effect that a search under section 132 of the Act should be continuous and if it is discontinued and thereafter resumed, then there must be a valid explanation for the gap. Insofar as the present case is concerned, the facts on record show t…

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