CIT v. Mussadilal Ram

165 ITR 14Supreme Court of India1987#2847 most cited

What is CIT v. Mussadilal Ram authority for?

A difference between returned and assessed income raises an inference of concealment under Section 271(1)(c), placing the onus on the assessee to rebut this presumption. Willful concealment is not a necessary ingredient for attracting such a penalty.

41

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Mussadilal Ram · Section 271(1)(c) penalty · concealment of income · furnishing inaccurate particulars · onus on assessee · difference between returned and assessed income · presumption of concealment · willful concealment not essential · Explanation 1 to Section 271(1)(c)

Sections most often in play

Section 271(1)(c)Section 143(3)Section 153ASection 274Section 271AABSection 271AAB(1)(c)Section 54F

Issues it is cited on

section 271aab(1)penalty proceedings initiatedsection 271aabfurnishing inaccurate particulars of incomesection 271aapenalty under section 271(1)(c)furnishing inaccurate particularssection 260penalty u/s 271(1)(c)section 271aconcealment of incomesection 274

Judgments citing CIT v. Mussadilal Ram

Shri.M.J.Siwani, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, all the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 1933/BANG/2016[2012-13]Status: DisposedITAT Bangalore26 Oct 2020AY 2012-13

Bench: Shri B. R. Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri V. Chandra Sekhar, A.RFor Respondent: Shri Muzaffar Hussain, D.R
Section 132Section 143(3)Section 153ASection 153C

…given by the assessee should be an acceptable explanation as held by Hon’ble Supreme ITA Nos.1928 to 1939/Bang/2016 & ITA Nos.511&512/Bang/2017 Shri M.J. Siwani & Shri H.J. Siwani, Bangalore Page 13 of 29 court in the case of CIT vs. Mussadilal Ram bharosa (165 ITR 14)(SC). However, the present explanations of the assessee are not acceptable. The Ld A.R, in the rejoinder, submitted that the decision in the case of Mussadilal Ram bharosa (supra) has been rendered in the context of penalty levied u/s 271(1)(c) of the Act. He submitted that the assessee has presented correct facts before the AO and the assessing o…

Shri.M.J.Siwani, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, all the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 1932/BANG/2016[2011-12]Status: DisposedITAT Bangalore26 Oct 2020AY 2011-12

Bench: Shri B. R. Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri V. Chandra Sekhar, A.RFor Respondent: Shri Muzaffar Hussain, D.R
Section 132Section 143(3)Section 153ASection 153C

…given by the assessee should be an acceptable explanation as held by Hon’ble Supreme ITA Nos.1928 to 1939/Bang/2016 & ITA Nos.511&512/Bang/2017 Shri M.J. Siwani & Shri H.J. Siwani, Bangalore Page 13 of 29 court in the case of CIT vs. Mussadilal Ram bharosa (165 ITR 14)(SC). However, the present explanations of the assessee are not acceptable. The Ld A.R, in the rejoinder, submitted that the decision in the case of Mussadilal Ram bharosa (supra) has been rendered in the context of penalty levied u/s 271(1)(c) of the Act. He submitted that the assessee has presented correct facts before the AO and the assessing o…

Shri.M.J.Siwani, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, all the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 1931/BANG/2016[2010-11]Status: DisposedITAT Bangalore26 Oct 2020AY 2010-11

Bench: Shri B. R. Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri V. Chandra Sekhar, A.RFor Respondent: Shri Muzaffar Hussain, D.R
Section 132Section 143(3)Section 153ASection 153C

…given by the assessee should be an acceptable explanation as held by Hon’ble Supreme ITA Nos.1928 to 1939/Bang/2016 & ITA Nos.511&512/Bang/2017 Shri M.J. Siwani & Shri H.J. Siwani, Bangalore Page 13 of 29 court in the case of CIT vs. Mussadilal Ram bharosa (165 ITR 14)(SC). However, the present explanations of the assessee are not acceptable. The Ld A.R, in the rejoinder, submitted that the decision in the case of Mussadilal Ram bharosa (supra) has been rendered in the context of penalty levied u/s 271(1)(c) of the Act. He submitted that the assessee has presented correct facts before the AO and the assessing o…

Shri.M.J.Siwani, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, all the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 1930/BANG/2016[2009-10]Status: DisposedITAT Bangalore26 Oct 2020AY 2009-10

Bench: Shri B. R. Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri V. Chandra Sekhar, A.RFor Respondent: Shri Muzaffar Hussain, D.R
Section 132Section 143(3)Section 153ASection 153C

…given by the assessee should be an acceptable explanation as held by Hon’ble Supreme ITA Nos.1928 to 1939/Bang/2016 & ITA Nos.511&512/Bang/2017 Shri M.J. Siwani & Shri H.J. Siwani, Bangalore Page 13 of 29 court in the case of CIT vs. Mussadilal Ram bharosa (165 ITR 14)(SC). However, the present explanations of the assessee are not acceptable. The Ld A.R, in the rejoinder, submitted that the decision in the case of Mussadilal Ram bharosa (supra) has been rendered in the context of penalty levied u/s 271(1)(c) of the Act. He submitted that the assessee has presented correct facts before the AO and the assessing o…

Shri.M.J.Siwani, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, all the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 1929/BANG/2016[2008-09]Status: DisposedITAT Bangalore26 Oct 2020AY 2008-09

Bench: Shri B. R. Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri V. Chandra Sekhar, A.RFor Respondent: Shri Muzaffar Hussain, D.R
Section 132Section 143(3)Section 153ASection 153C

…given by the assessee should be an acceptable explanation as held by Hon’ble Supreme ITA Nos.1928 to 1939/Bang/2016 & ITA Nos.511&512/Bang/2017 Shri M.J. Siwani & Shri H.J. Siwani, Bangalore Page 13 of 29 court in the case of CIT vs. Mussadilal Ram bharosa (165 ITR 14)(SC). However, the present explanations of the assessee are not acceptable. The Ld A.R, in the rejoinder, submitted that the decision in the case of Mussadilal Ram bharosa (supra) has been rendered in the context of penalty levied u/s 271(1)(c) of the Act. He submitted that the assessee has presented correct facts before the AO and the assessing o…

Shri.M.J.Siwani, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, all the appeals of the assessee are treated as partly allowed for statistical purposes

ITA 1928/BANG/2016[2006-07]Status: DisposedITAT Bangalore26 Oct 2020AY 2006-07

Bench: Shri B. R. Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri V. Chandra Sekhar, A.RFor Respondent: Shri Muzaffar Hussain, D.R
Section 132Section 143(3)Section 153ASection 153C

…given by the assessee should be an acceptable explanation as held by Hon’ble Supreme ITA Nos.1928 to 1939/Bang/2016 & ITA Nos.511&512/Bang/2017 Shri M.J. Siwani & Shri H.J. Siwani, Bangalore Page 13 of 29 court in the case of CIT vs. Mussadilal Ram bharosa (165 ITR 14)(SC). However, the present explanations of the assessee are not acceptable. The Ld A.R, in the rejoinder, submitted that the decision in the case of Mussadilal Ram bharosa (supra) has been rendered in the context of penalty levied u/s 271(1)(c) of the Act. He submitted that the assessee has presented correct facts before the AO and the assessing o…

Orbit Corporation Ltd, Mumbai vs. DCIT Cen Cir 47, Mumbai

In the result, appeals of the assessee for all three assessment years i

ITA 7036/MUM/2017[2009-10]Status: DisposedITAT Mumbai19 Feb 2020AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: NoneFor Respondent: Shri Awangshi Gimson
Section 143(3)Section 271(1)(c)Section 271ASection 80I

…n. He may not prove what he assets to the hilt positively, but at least material brought on record must show that what he says is reasonably valid. The above views were approved by the Hon'ble Supreme Court in the case of cit Vs. Mussadilal Ram Bharose (1987) 165 ITR 14 (SC). Referring to the judgment of Honble Patna high Court, their Lordships have observed as follows- "The Patna High Court emphasized that as to the nature of explanation to be rendered by the assessee, it was plain on principle that it is not the law that the moment any fantastic or unacceptable explanation is given, the burden placed on him wil…

Orbit Corporation Ltd, Mumbai vs. DCIT Cen Cir 47, Mumbai

In the result, appeals of the assessee for all three assessment years i

ITA 7035/MUM/2017[2008-09]Status: DisposedITAT Mumbai19 Feb 2020AY 2008-09

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: NoneFor Respondent: Shri Awangshi Gimson
Section 143(3)Section 271(1)(c)Section 271ASection 80I

…n. He may not prove what he assets to the hilt positively, but at least material brought on record must show that what he says is reasonably valid. The above views were approved by the Hon'ble Supreme Court in the case of cit Vs. Mussadilal Ram Bharose (1987) 165 ITR 14 (SC). Referring to the judgment of Honble Patna high Court, their Lordships have observed as follows- "The Patna High Court emphasized that as to the nature of explanation to be rendered by the assessee, it was plain on principle that it is not the law that the moment any fantastic or unacceptable explanation is given, the burden placed on him wil…

Orbit Corporation Ltd, Mumbai vs. DCIT Cen Cir 47, Mumbai

In the result, appeals of the assessee for all three assessment years i

ITA 7034/MUM/2017[2010-2011]Status: DisposedITAT Mumbai19 Feb 2020AY 2010-2011

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: NoneFor Respondent: Shri Awangshi Gimson
Section 143(3)Section 271(1)(c)Section 271ASection 80I

…n. He may not prove what he assets to the hilt positively, but at least material brought on record must show that what he says is reasonably valid. The above views were approved by the Hon'ble Supreme Court in the case of cit Vs. Mussadilal Ram Bharose (1987) 165 ITR 14 (SC). Referring to the judgment of Honble Patna high Court, their Lordships have observed as follows- "The Patna High Court emphasized that as to the nature of explanation to be rendered by the assessee, it was plain on principle that it is not the law that the moment any fantastic or unacceptable explanation is given, the burden placed on him wil…

Shri Laxmi Bidi Trading Company, Ahmedabad vs. The DCIT, Circle-5(3), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1678/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad09 Sept 2019AY 2014-15
Section 139(1)Section 143(3)Section 271BSection 40A(2)(b)Section 40bSection 44ASection 92BSection 92E

…ssment year: 2014-15 Page 4 of 5 7. In our considered view, the assessee has given a reasonable explanation and the explanation so offered has not been specifically faulted. As held by Hon’ble Supreme Court in the case of CIT v. Mussadilal Ram Bharose [1987] 165 ITR 14 ( SC) that “while it is not the law that any and every explanation by the assessee must be accepted, it must be acceptable explanation, acceptable to a fact-finding body”. In our considered view, the explanation given by the assessee is a reasonable explanation and nothing has been placed before us to show that the explanation given by the assesse…

Puneet Saluja, New Delhi vs. ITO, New Delhi

The appeal of the assessee is dismissed

ITA 3497/DEL/2016[2006-07]Status: DisposedITAT Delhi13 Jun 2019AY 2006-07

Bench: : Shri H.S. Sidhu & Shri B.R.R. Kumarassessment Year: 2007-08

Section 133ASection 271Section 271(1)(c)

…with explanation 1 thereto and the judicial pronouncements in the case of B.A. Balasubramaniam & Bros. Co. v. CIT [2001] 116 Taxman 842 (SC),CIT v. B.A. Baiasubramaniam & Bros. Co. [1985] 152 ITR 529 / 20 Taxman 215(Mad.), CIT v. Mussadilal Ram Bharose [1987] 165 ITR 14 /30 Taxman 546H; CIT v. K.R. Sadayappan [1990] 185 ITR 49/51 Taxman 304 , Addl. CIT v. Jeevan Lai Sah[1994] 205 ITR 244 / 73 Taxman 182 (SC) and K.P. Madhusudanan v. CIT [2001] 251 ITR 99/ 118 Taxman 324 (SC), it is well established that whenever there is difference between the returned and assessed income, there is inference of concealment. The E…

Arun Ravindranath Sawhney, Mumbai vs. DCIT Cen Cir 3(4), Mumbai

In the result, the appeal of assessee is allowed

ITA 7192/MUM/2016[2007-08]Status: DisposedITAT Mumbai31 May 2019AY 2007-08

Bench: Sri Mahavir Singh, Jm & Sri G Manjunatha, Am Aayakr Apila Sam./ Ita No. 7192/Mum/2016 (Inaqa-Arna Baya- / Assessment Year 2007-08) Arun Ravindranath Sawhney The Dy. Commissioner Of 502, Daisylea Apartment, 17- Income Tax, Central Circle A Mount Pleasant Road, 3(4), Old Acit Central Vs. Mumbai-400 006 Circle 24& 26 Air India Building, Nariman Point, Mumbai-400 021 .. (P`%Yaqaai- / Respondent) (Apilaaqai- / Appellant) स्थायी लेखा िं./Pan No. Aafps4688F

For Appellant: Shri Nitesh Joshi, ARFor Respondent: S/shri Anadi Varma
Section 132Section 143(3)Section 153ASection 271Section 271(1)Section 271(1)(c)Section 274

…Smt. Kaushalya (1994) 75 Taxmann 549 (Bombay) 7. ACIT vs. Dr. Nitin Laxmikant Lad, IN ITA No. 2241 to 2244/PN/2012 8. CIT Vs. Sangmeshwara Associate (2012) 345 ITR 396 (Kar) 9. S. Rajnish Vohra vs. DCIT ITA No. 516/Chd/2012 10. CIT vs. Mussadilal Ram Bharose 165 ITR 14 20 11. M/s Lakshmi Ring Travellers, ITA No. 2083 (Mds)/2011 12. CIT vs. Munish Iron Store (2003) 263 0484 (2004) 13. Mahendra Mital vs. ACiT (2011) 139 TTJ 513 (Mum) 14. Mrs. SArita Kaur Manjeet Singh Chopra V. ITO (2017) 88 Taxmann.com 360 (Pune-Trib) 15. MAK Data (P) Ltd. v. CIT (2013) 358 ITR 593 16. m/S Madhushree Gupta vs. UOI & Anr. (2009)…

Vaswani Trust, Mumbai vs. ITO 12(2)(4), Mumbai

In the result, this appeal of assessee is partly allowed

ITA 3005/MUM/2018[2005-06]Status: DisposedITAT Mumbai01 Feb 2019AY 2005-06

Bench: Shri Sandeep Gosain & Shri G. Manjunatha

For Appellant: Shri Rakesh Mohan, ARFor Respondent: Shri Rajeev Gubgotra, DR
Section 139(1)Section 143(3)Section 147Section 148Section 166Section 24Section 271(1)(c)Section 274

…have concealed the particulars of his income or furnished inaccurate particulars thereof and consequently liable for penalty provided by the section. Further, in the case of IT Vs. : 9 : ITA Nos. 3005, 3006, 3007, 3008 & 3009/Mum/18 Musaddilal Ram Bharose (165 ITR 14), the Apex Court has held that after insertion of Explanation, the responsibility of rebuttal lies on the assessee. b) Further, in the judgement in the case of RaghuvirSoni Vs. ACIT 258 ITR 239 (Raj.), the Hon'ble High Court have held that the provisions relating to levy of penalty for concealment of income have been materially altered w.e.f. Apri…

DCIT, Bangalore vs. M/S Geneva Fine Punch Enclosures Ltd., Bangalore

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

ITA 1560/BANG/2013[2009-10]Status: DisposedITAT Bangalore19 Jan 2018AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Lalit Kumardeputy Commissioner Of Income-Tax, Circle 11(3), Bengaluru. … Appellant Vs. M/S.Geneva Industries Ltd., (Formerly Geneva Fine Punch Enclosures Ltd.),No.140/1, Pattandur Agrahara Village, Whitefield Road, Bengaluru-560 066. … Respondent Pan: Aaacg7208F & (By The Assessee) Assessee By : Shri B.Balachandran, Advocate. Revenue By : Shri Pradeep Kumar, Cit(Dr) Date Of Hearing : 02/11/2017 Date Of Pronouncement : 19/01/2018 O R D E R Per Inturi Rama Rao, Am : These Cross Appeals Filed By The Assessee-Company As Well As Revenue Directed Against The Order Of The Ld. Commissioner Of Income- Tax(Appeals)-I, Bengaluru, Dated 30/08/2013 For The Assessment Year 2009-10. 2. Briefly, Facts Of The Case Are As Under: The Assessee Is A Company Duly Incorporated Under The Provisions Of The Companies Act 1956. It Is Engaged In The Business Of Making Of Sheet Metal, Medical Equipments & Accessories. The Return Of Income For The Assessment Year 2009-

For Appellant: Shri B.Balachandran, AdvocateFor Respondent: Shri Pradeep Kumar, CIT(DR)
Section 143Section 54GSection 69

…ial burden of proving is always on the assessee to show that the transactions in loose sheets are not in the nature of income and reliance in this regard can be placed on the decision of the Hon’ble Supreme Court in the case of CIT vs. Mussadilal Ram Bharose (165 ITR 14). In the present case, the assessee merely denied it without tendering any credible explanation. In our considered opinion, this does not amount to due discharge of initial burden on the part of assessee and therefore the ITA No.1560 & 1628/Bang/2013 Page 6 of 12 Assessing Officer was justified in drawing adverse inference and making addition of R…

P.Srinivasan, Salem vs. ITO, Salem

In the result, the assessee’s appeal is disposed of in the foregoing terms

ITA 1280/CHNY/2017[2009-10]Status: DisposedITAT Chennai16 Oct 2017AY 2009-10

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddy

For Appellant: Smt. Veni S.Raj, Jt. CITFor Respondent: 01.08.2017
Section 271(1)(c)Section 274

…SC); K.P. Madhusudhanan vs. CIT [2001] 251 ITR 99 (SC); B.A. Balasubramaniam and Bros v. CIT (1999) 236 ITR 977 (SC); Addl. CIT vs. Jeevan Lal Shah [1994] 205 ITR 244 (SC); CIT vs. K. R. Sadayappan [1990] 185 ITR 49 (SC); CIT vs. Mussadilal Ram Bharose [1987] 165 ITR 14 (SC); and Sharma Alloys (India) Ltd. v. ITO [2013] 357 ITR 379 (Mad). Coming to the facts of the case, we find that neither in the assessment nor in the penalty proceedings did the assessee furnish any explanation whatsoever with regard to the encashment of the relevant cheques, i.e., as to how the cheques, issued to third parties at Surat, found…

Principal Commissioner of Income Tax - 7 vs. Bikram Singh

The appeal is allowed in the above terms

ITA/55/2017HC Delhi25 Aug 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MS. JUSTICE PRATHIBA M. SINGH

Section 68

…nvestigate the creditworthiness of the creditor/subscriber the genuineness of the transaction and the veracity of the repudiation….” 26. In Divine Leasing (supra), on the question of burden of proof, the Court relied upon CIT v. Musaddilal Ram Bharose, (1987) 165 ITR 14, to hold that the initial burden is upon the Assessee to show the absence of fraud and this is not discharged by the Assessee tendering an incredible and fantastic explanation. The Court also held that every explanation given by the Assessee need not be accepted. 27. In Kamdhenu (supra), this Court categorically held that the initial burden lies o…

Oriental Bank of Commerce, Gurgaon vs. ACIT, New Delhi

In the result, the appeal is dismissed

ITA 5865/DEL/2013[2005-06]Status: DisposedITAT Delhi21 Apr 2017AY 2005-06

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

For Appellant: Sh. K.V.S.R. Krishna, CAFor Respondent: None(application rejected)
Section 271Section 271(1)(c)Section 32Section 43(1)Section 43(6)Section 45(7)

…ith explanation 1 thereto and the judicial pronouncements in the case of B.A. BaSasubramaniam & Bros. Co. v. C1T [2001] i 16 Taxman 842 (SC);C1T v. B.A. Balasubramaniam & Bros. Co. [1985] 152 ITR 529 / 20 Taxman 2i5(Mad.), CIT v. Mussadilal Ram Bharose [1987] 165 ITR 14 /30 Taxman 546H; C1T v.K.R. Sadayappan [1990] 185 ITR 49 / 51 Taxman 304 , Addl. CIT v. Jeevan Lal Sah[!994] 205 ITR 244 / 73 Taxman 182 (SC) and K.P. Madhusudanan v. CIT [2001] 251 ITR 997 118 Taxman 324 (SC), H i- .-.-ell established that whenever there is difference be*-.-;:;^ the returned and assessed income, there is inference of concealment.…

M/S. Mount Everest Mineral Water Limited, New Delhi vs. DCIT, New Delhi

In the result, the appeals of the Revenue and assessee are partly

ITA 1498/DEL/2014[2008-09]Status: DisposedITAT Kolkata31 Jan 2017AY 2008-09

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

For Appellant: Sh. Kanchan Kaushal, CA &For Respondent: Sh. Rajesh Kumar, Sr. DR
Section 143(3)Section 14ASection 271(1)(c)

…s. Zoom Communications Pvt. Ltd., 327 ITR 51 (Del.) (ii). Thakur V. Hari Prasad vs. CIT, 167 ITR 603 (AP) (iii). Union of India vs. Dharmendra Textile Processors, 166 Taxman 65(SC) (iv). K.P. Madhusudan vs. CIT, 251 ITR 99. (v). Mussadilal Ram Bharose’s case, 165 ITR 14 (SC). 5. As far as the disallowance u/s. 14A is concerned, it was noticed that the assessee earned an income of Rs.3,06,59,085/- from dividends and claimed exemption u/s. 10(33) of the Act. As per computation of income, the assessee disallowed a sum of Rs.2,50,000/- in view of section 14A read with Rule 8D of the Act stating that no direct expe…

Mitsui Prime Advanced Composites India Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

In the result, the appeal is allowed

ITA 550/DEL/2016[2010-11]Status: DisposedITAT Delhi28 Apr 2016AY 2010-11

Bench: Shri R.S. Syal, Am & Shri C.M. Garg, Jm Assessment Year : 2010-11

For Appellant: Shri Kanchan Kaushal, CA &For Respondent: Shri Amrendra Kumar, CIT, DR
Section 271(1)(c)

…he return which are not found to be inaccurate. This shows that each and every addition does not lead to imposition of penalty as has been canvassed on behalf of the Revenue. 23. The reliance of the ld. DR on the judgments in CIT vs. Mussadi Lal Ram Bharose 165 ITR 14 (SC) and Calcutta Discount Company Ltd. vs. ITO 41 ITR 191 (SC) is again improper because unlike those decisions, we 27 are not faced with a situation in which the explanation of the assessee for determining the ALP in the manner as done by it, was not bona fide. Similar is the position insofar as the reliance of the ld. DR on CIT vs. Zoom Com…

M/S. Icici Bank Ltd., Mumbai vs. DCIT RG. - 3 (1), Mumbai

ITA 4903/MUM/2005[1993-1994]Status: DisposedITAT Mumbai01 Jan 2016AY 1993-1994
For Appellant: Ms. Aarti Vissanji (AR)For Respondent: Shri Manjunatha R. Swamy (CIT-DR)
Section 143(3)Section 254(1)Section 271(1)Section 271(1)(c)Section 32

…आयकर अपीलीय अिधकरण, ‘ई’ खंडपीठ मुंबई INCOME TAX APPELLATE TRIBUNAL,MUMBAI “E” BENCH सव"ी राजे", लेखा सद" एवं संदीप गोसांई, "ाियक सद" Before S/Sh. Rajendra,Accountant Member & Sandeep Gosain,Judicial Member आयकर अपील सं/.ITA No.4903/M/2005,िनधा"रण वष"/Assessment Year-1993-94 ICICI Bank Limited DCIT- Range-3(1) (erstwhile ICICI Limited) Aayakar Bhavan ICICI Bank Towers Vs M.K. Road Bandra-Kurla Complex Mumbai-400 020. Bandra (East)Mumbai-400 051. PAN:AAACT 1398 K (अपीलाथ" /Appellant) (""थ" / Respondent) िनधा"रती ओर से/Assessee by : Ms. Aarti Vissanji (AR) राज" की ओर से/ Revenue by : Shri Manjunatha R. Swamy…