How many judgments cite CIT v. Purshottamdas T. Patel?

69 judgments on BharatTax cite CIT v. Purshottamdas T. Patel (209 ITR 52), spanning 2020 to 2026.

Which sections of the Income Tax Act does CIT v. Purshottamdas T. Patel come up under?

It is most often cited in judgments turning on Section 153C, Section 143(3), Section 144, Section 115BBE, Section 153A, Section 292C.

CIT v. Purshottamdas T. Patel

209 ITR 52High Court1994#1627 most cited

What is CIT v. Purshottamdas T. Patel authority for?

Assessment is an integrated process that encompasses the determination of both income and tax. Therefore, any statutory approval required for an assessment, such as under Section 153D, must cover both the income computation and the tax computation, not merely one aspect.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2020 to 2026.

Also referred to as

CIT v. Purshottamdas T. Patel · 209 ITR 52 · Section 153D approval · assessment integrated process · income and tax determination · approval of tax computation · Joint Commissioner approval · search assessment procedure · Gujarat High Court · assessment validity

Sections most often in play

Section 153C Section 143(3)Section 144 Section 115BBE Section 153A Section 292C Section 153D Section 132

Issues it is cited on

impermissible avoidance arrangement section 158bd section 245h income tax settlement commission section 245ha section 144a warrant of authorisation section 245c section 153(2a)section 269ss section 153(c)section 90a

Judgments citing CIT v. Purshottamdas T. Patel

Defsys Solutions P.Ltd, New Delhi vs. ACIT, Central Circle-15, New Delhi

In the result the appeal of the assessee in ITA No

ITA 1818/DEL/2023[2020-21]Status: DisposedITAT Delhi17 Oct 2023AY 2020-21

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Rajesh Kumar, CIT-DR

Section 143(3)Section 144CSection 144C(13)Section 156Section 271ASection 274

…and served demand notice, but has also initiated the penalty proceedings. 22. The question whether demand notice is an integral part of the assessment order has been answered by the Hon'ble High Court of Gujarat in the case of CIT Vs. Purshottam Das T Patel 209 ITR 52 wherein the Hon'ble High Court has relied on the decision of the Hon'ble Supreme Court in the case of Kalyan Kumar Ray Vs. CIT 191 ITR 634. The relevant findings of Hon'ble High Court read as under: " 'Assessment’ is one integrated process involving not only the assessment of the total income but also the determination of the tax. The latter is…

Sri. Kullachari Puttamma Nanjundi Vishwakarma, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(4), Bengaluru

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

ITA 951/BANG/2022[2011-12]Status: DisposedITAT Bangalore06 Feb 2023AY 2011-12

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri V. Chandrashekar, AdvocateFor Respondent: Ms. Neera Malhotra, CIT-DR

Section 132Section 132(1)(a)Section 132(2)Section 153ASection 250

…by the Hon’ble Court that once the same has been sent out to the concerned Government Servant, it must have been communicated no matter when he actually received it. 10. The Hon’ble Gujarat High Court in the case of CIT vs. Purshottamdas T Patel reported in 209 ITR 52 (Guj) had held the AO having failed to determine the tax payable on assessed income within the prescribed time u/s. 153 of the I.T.Act, (though the assessment order was passed within the time) the assessment has become time barred. 11. The Hon’ble Kerala High Court in the case of Commissioner of Agricultural Income tax vs. Kappumalai Estate repor…

Ramakrishna Murali, Bangalore vs. Income Tax Officer, Ward-6(3)(1), Bangalore

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

ITA 975/BANG/2022[2012-13]Status: DisposedITAT Bangalore30 Dec 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri Raghavendra Chakravarthy, A.RFor Respondent: Shri K.R. Narayana, D.R

Section 143(3)Section 250Section 271D

…ent out to the concerned Government Servant must be held to have been communicated. no matter when he actually received it." Cr' 3.6 Further reliance was placed on the decision of Hon'ble Gujarat High Court in the case of CIT Vs. Purshottamdas T Patel [1994] 209 ITR 52 [Guj] wherein the Hon'ble High Court has held as under: "In the above case the Hon'ble Court held that the Assessing Officer having failed to determine the tax payable on assessed income within time prescribed under section 153, though the assessment order was passed within time, the assessment had become time barred." 3.7 Further reliance was p…

Advance Technoloies Ltd., Mumbai vs. Dy CIT, Central Circle-2(2), Mumbai

In the result, the appeal is dismissed

ITA 1943/MUM/2020[2007-08]Status: DisposedITAT Mumbai27 May 2022AY 2007-08

Section 143(3)Section 151Section 153

…ened, is not, by any stretch of logic, contemplated at stage. Learned counsel’s submission that the service of assessment order does not constitute a valid service, in the light of Hon’ble Gujarat High Court’s judgment in CIT Vs Purshottamdas T. Patel [(1995) 209 ITR 52 (Guj)], does not merit acceptance either. That was a case in which tax computation was not served on the assessee within permitted time frame, but then in the present case, the tax computation is duly served within the time, and all that is furnished subsequently is the computation of peak income in an annexure. In our considered view, this lapse…

Wipro Limited vs. The Joint Commissioner of Income Tax

WP/20040/2019HC Karnataka25 Aug 2021

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

Section 1Section 143(2)Section 143(3)Section 244ASection 254Section 92C

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 25TH DAY OF AUGUST 2021 BEFORE THE HON’BLE MR. JUSTICE KRISHNA S.DIXIT WRIT PETITION NO.20040/2019 (T-IT) BETWEEN: WIPRO LIMITED, DODDAKANNELLI, SARJAAPUR ROAD, BANGALORE-560 035, REP. BY ITS VICE PRESIDENT – TAXATION, SRI BALASUBRAMANIAN K., SON OF SRI KRISHNAMURTHY, AGED ABOUT 39 YEARS. … PETITIONER (BY SHRI S.GANESH, SR. COUNSEL A/W. SHRI VENKATESH S. ARBATTI, ADVOCATE) AND: 1. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, 2ND FLOOR, INCOME TAX OFFICE, BMTC BUILDING, 8 FEET ROAD, KORAMANGALA,…

Mavenir India Pvt. Ltd. (Earlier Known As Comverse Network System India Pvt. Ltd.), Gurgaon vs. DCIT, Circle- 3(1), Gurgoan

In the result, the appeal filed by the assessee in ITA No

ITA 203/DEL/2020[2015-16]Status: DisposedITAT Delhi29 Sept 2020AY 2015-16

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2015-16]

For Appellant: Shri Ravi Sharma, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT-DR

Section 10ASection 12Section 143(3)Section 144CSection 156

…occasion to decide an identical issue wherein it has been held as under: “18. The question whether demand notice is an integral part of the assessment order has been answered by the Hon'ble High Court of Gujarat in the case of CIT Vs. Purshottam Das T Patel 209 ITR 52 wherein the Hon'ble High Court has relied on the decision of the Hon'ble Supreme Court in the case of Kalyan Kumar Ray Vs. CIT 191 ITR 634. The relevant findings of Hon'ble High Court read as under: "'Assessment’ is one integrated process involving not only the assessment of the total income but also the determination of the tax. The latter is as…

Olympus Medical Systems India Pvt. Ltd., Gurugram vs. DCIT, Circle- 3(1), Gurugram

In the result, appeal of the assessee is allowed

ITA 8892/DEL/2019[2015-16]Status: DisposedITAT Delhi26 Aug 2020AY 2015-16

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[A.Ys 2015-16]

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Shri Anupam Kant Garg, CIT-D.R

Section 143(3)Section 144CSection 153Section 153BSection 156Section 274

…and served demand notice, but has also initiated the penalty proceedings. 18. The question whether demand notice is an integral part of the assessment order has been answered by the Hon'ble High Court of Gujarat in the case of CIT Vs. Purshottam Das T Patel 209 ITR 52 wherein the Hon'ble High Court has relied on the decision of the Hon'ble Supreme Court in the case of Kalyan Kumar Ray Vs. CIT 191 ITR 634. The relevant findings of Hon'ble High Court read as under: " 'Assessment’ is one integrated process involving not only the assessment of the total income but also the determination of the tax. The latter is as…

Perfetti Van Melle India Pvt. Ltd., Gurgaon vs. ACIT, Circle-3(1), Gurgaon

In the result, the appeal of the assessee in ITA No

ITA 9116/DEL/2019[2015-16]Status: DisposedITAT Delhi11 Aug 2020AY 2015-16

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[Assessment Year: 2015-16]

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Shri Anupam Kant Garg, CIT-DR

Section 143(3)Section 144CSection 153Section 153B

Deputy Commissioner of Income Tax, Circle - Agartala, Agartala vs. Shri Subhajit Paul, Agartala

In the result, cross-objection nos

ITA 116/GTY/2018[2014-15]Status: DisposedITAT Guwahati31 Jul 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.116/Gau/2018 ("नधा"रणवष" / Assessment Year:2014-15)

For Appellant: Shri Rockein Saikia, JCIT, Sr. DRFor Respondent: Shri Sanjay Modi, FCA

Section 143(2)Section 143(3)Section 153D

…iable to be quashed. Similar view was also expressed in the following ratios: SHANTI LAL GOD AW AT & ORS Vs. ASSISTANT COMMISSIONER OF INCOME TAX, (2009) 126 TTJ (Jd) 135 COMMISSIONER OF INCOME TAX Vs. PURSHOTTAMDAS T. PATEL, (1994) 120 CTR (Cuj) 332 : (1994) 209 ITR 52 (Guj) JIFFIR AND KAREEM Vs. AGRICULTURAL INCOME TAX OFFICER & ANR., (1999) 240 ITR 587 (Ker) On the above ground it is submitted that, the assessment order passed by the Ld AO is barred by limitation and liable to be quashed.” Decision:- Submission made by the Ld. A.R. was considered carefully with reference to material available on record and the…