CIT v. PVS Beedies Pvt. Ltd.

237 ITR 13Supreme Court of India1999#883 most cited

What is CIT v. PVS Beedies Pvt. Ltd. authority for?

An audit objection that points out a factual error or omission overlooked by the Assessing Officer during the original assessment constitutes tangible material or information justifying the reopening of assessment under Section 147. This principle applies even for reopening beyond four years and is not considered a mere change of opinion.

120

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. PVS Beedies Pvt. Ltd. · Section 147 · Section 148 · reopening assessment · audit objection · factual error · tangible material · beyond four years · change of opinion · income escaping assessment

Sections most often in play

Section 147Section 143(3)Section 148Section 144Section 115JBSection 14ASection 151Section 80P

Issues it is cited on

section 147(b)fresh tangible materialfull and true disclosurebeyond four yearsmere change of opinionkelvinatorfirst proviso to section 147change of opinionmaterial facts necessary for assessmenttangible materialsection 151(2)income escaping assessment

Judgments citing CIT v. PVS Beedies Pvt. Ltd.

DEPUTY COMMISSIONER OF INCOME TAX, YAMUNANAGAR vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 833/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

…gs or from any other officer and the material only provides the background for recording of the reason to believe that the income had escaped assessment. Reference was made to the decision of Hon’ble Supreme Court in the case of CIT vs. PVS Beedies Pvt. Ltd. (237 ITR 13) holding that reopening on the basis of error pointed out by the audit partywas valid. Similar was the decision of Hon’ble Madras High Court in the case of CIT vs. First leasing Co. of India Ltd. (241 ITR 248).In the case of Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the commenc…

DCIT vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 832/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

…gs or from any other officer and the material only provides the background for recording of the reason to believe that the income had escaped assessment. Reference was made to the decision of Hon’ble Supreme Court in the case of CIT vs. PVS Beedies Pvt. Ltd. (237 ITR 13) holding that reopening on the basis of error pointed out by the audit partywas valid. Similar was the decision of Hon’ble Madras High Court in the case of CIT vs. First leasing Co. of India Ltd. (241 ITR 248).In the case of Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the commenc…

THE VED PRAKASH MUKAND LAL EDUCATIONAL SOCIETY,YAMUNANAGAR vs. DCIT, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 825/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

…gs or from any other officer and the material only provides the background for recording of the reason to believe that the income had escaped assessment. Reference was made to the decision of Hon’ble Supreme Court in the case of CIT vs. PVS Beedies Pvt. Ltd. (237 ITR 13) holding that reopening on the basis of error pointed out by the audit partywas valid. Similar was the decision of Hon’ble Madras High Court in the case of CIT vs. First leasing Co. of India Ltd. (241 ITR 248).In the case of Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the commenc…

THE VED PRAKASH MUKAND LAL EDUCATIONAL SOCIETY,YAMUNANAGAR vs. DCIT, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 824/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

…gs or from any other officer and the material only provides the background for recording of the reason to believe that the income had escaped assessment. Reference was made to the decision of Hon’ble Supreme Court in the case of CIT vs. PVS Beedies Pvt. Ltd. (237 ITR 13) holding that reopening on the basis of error pointed out by the audit partywas valid. Similar was the decision of Hon’ble Madras High Court in the case of CIT vs. First leasing Co. of India Ltd. (241 ITR 248).In the case of Raymond Woollen Mills Ltd. vs ITO (236 ITR 34), it was held by Hon’ble Supreme Court that in determining whether the commenc…

DCIT-2(1)(1), MUMBAI, MUMBAI vs. BANK OF BARODA , BANK OF BARODA

In the result, both the appeals filed by the Revenue and both the cross objections

ITA 4913/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri C. Naresh, ARFor Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 115JSection 143(3)Section 147Section 14ASection 244ASection 250Section 36(1)(viia)

…e of opinion” as alleged by the assessee, where there was a reason to believe based on the audit objection that income has escaped assessment. The Ld. DR relied on the decision of the Hon’ble Apex Court in the case of CIT Vs. P.V.S. Beedies Pvt. Ltd. (1999) 237 ITR 13 (SC) wherein it was held that the audit party pointing out factual error or omission in the assessment is permissible for reopening a case which was in accordance with section 147(b) of the Act. 13. The contention of the Learned Authorized Representative (Ld. AR) for the assessee was that there was no new tangible material available with the L…

DCIT-2(1)(1), MUMBAI vs. BANK OF BARODA, MUMBAI

In the result, both the appeals filed by the Revenue and both the cross objections

ITA 4869/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri C. Naresh, ARFor Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 115JSection 143(3)Section 147Section 14ASection 244ASection 250Section 36(1)(viia)

…e of opinion” as alleged by the assessee, where there was a reason to believe based on the audit objection that income has escaped assessment. The Ld. DR relied on the decision of the Hon’ble Apex Court in the case of CIT Vs. P.V.S. Beedies Pvt. Ltd. (1999) 237 ITR 13 (SC) wherein it was held that the audit party pointing out factual error or omission in the assessment is permissible for reopening a case which was in accordance with section 147(b) of the Act. 13. The contention of the Learned Authorized Representative (Ld. AR) for the assessee was that there was no new tangible material available with the L…

PR. COMMISSIONER OF INCOME TAX -4, NEW DELHI vs. M/S NTPC LTD

ITA/113/2026HC Delhi09 Feb 2026

Bench: HON'BLE MR. JUSTICE VINOD KUMAR,HON'BLE MR. JUSTICE DINESH MEHTA

Section 143(3)Section 147Section 260ASection 80

…002] 256 ITR 391 (Delhi), a Division Bench of this court after referring to the decision of Supreme Court in CIT v. P.VS. Beedies (P.) Ltd. [1999] 237 ITR 13/103 Taxman 294, has held as under (at page 393): "In the case of P. V. S. Beedies Pvt. Ltd. [1999] 237 ITR 13, the apex court held that the audit party can point out a fact, which has been overlooked by the Income-tax Officer in the assessment. Though there cannot be any interpretation of law by the audit party, it is entitled to point out a factual error or omission in the assessment and reopening of a case on the basis of factual error or omission…

PR COMMISSIONER OF INCOME TAX - 4, NEW DELHI vs. M/S NTPC LTD

ITA/82/2026HC Delhi09 Feb 2026

Bench: HON'BLE MR. JUSTICE DINESH MEHTA,HON'BLE MR. JUSTICE VINOD KUMAR

Section 143(3)Section 147Section 260ASection 80

…002] 256 ITR 391 (Delhi), a Division Bench of this court after referring to the decision of Supreme Court in CIT v. P.VS. Beedies (P.) Ltd. [1999] 237 ITR 13/103 Taxman 294, has held as under (at page 393): "In the case of P. V. S. Beedies Pvt. Ltd. [1999] 237 ITR 13, the apex court held that the audit party can point out a fact, which has been overlooked by the Income-tax Officer in the assessment. Though there cannot be any interpretation of law by the audit party, it is entitled to point out a factual error or omission in the assessment and reopening of a case on the basis of factual error or omission…

FRESENIUS KABI ONCOLOGY LIMITED,NEW DELHI vs. COMMISSIONER OF INCOME TAX (APPEALS)-26, NEW DELHI

The appeal of the assessee is allowed and the impugned reassessment order is quashed

ITA 2867/DEL/2025[2011-12]Status: DisposedITAT Delhi30 Jan 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwalfresenius Kabi Oncology Vs. Commissioner Of Income Limited, Tax (Appeals)-26, B-310, Som Datt Delhi Chambers-1, Bhikaji Cama Place, New Delhi "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcd 7720 L Appellant .. Respondent

For Appellant: Sh. Aditya Vohra, Adv &For Respondent: Ms. Indu Bala Saini, Sr. DR
Section 115JSection 143(3)Section 148Section 154

…Officer in the ‘reasons to believe’ and such practice of reopening on the basis of audit objections alone with has not been appreciated by Hon’ble Supreme Court for which reliance be placed by ld. Counsel on the decision of CIT Vs. PVS Beedies (P) Ltd:[1999] 237 ITR 13 (SC). We find Assessing Officer has not acted on to P a g e | 6 Fresenius Kabi Oncology Limited (AY: 2011-12) initiate reassessment independently believing income escaped assessment but merely relied the audit report and that itself is fatal for department’s case. 7. Then Ld. Counsel has demonstrated before us on the basis of reply dated 30.01.20…

PANKAJ JINDAL CONTRACTOR,MANSA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-I, BATHINDA, BATHINDA

In the result the appeal of the assessee is allowed

ITA 695/ASR/2024[2014-15]Status: DisposedITAT Amritsar05 Jan 2026AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 695/Asr/2024 Assessment Year: 2014-15 M/S Pankaj Jindal Contractor, Vs. Dcit-Circle-1, Near Vidya Bharti School, Bathinda. Mansa. [Pan:-Aajfp8008L] (Appellant) (Respondent) Appellant By Sh. Sudhir Sehgal, Adv. Respondent By Sh. Charan Dass, Sr. Dr

Section 139(1)Section 143(3)Section 147Section 148Section 148aSection 250Section 282Section 40A(3)Section 68

…book at page 98.” 11. The Ld. DR relied on the order of the CIT ( A ) on merits of the case and has relied on various judicial decisions in the matter of audit objections and has referred to the decision of the Hon’ble Apex court in CIT vs PVS Beedies Pvt Ltd 237 ITR 13 ( SC ) to submit that in this case factual error has been pointed out by the internal audit party relating to cash payments above the permissible limits and such internal audit party information was valid in law. Furthermore, reference was also drawn to the decision of the Hon’ble Apex court in the case of Indian and Eastern Newspaper Society v CI…

NAGARAJAN JAYA,KANCHEEPURAM vs. ITO, WARD-1,, KANCHIPURAM

In the result the appeal of the Assessee is allowed

ITA 1815/CHNY/2025[2011-12]Status: DisposedITAT Chennai05 Jan 2026AY 2011-12

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. P. Chidambaram, AdvocateFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 143(3)Section 147Section 148Section 264

…147 of the Act and contended that when the assessment has been made but the income assessable to tax has been undressed then the same can be subjected to reassessment. 14. The Ld DR has also relied on various case laws as under: 1. CIT Vs PVS Beedies (P) Ltd 237 ITR 13 (SC) 2. Phool Chand Bajrang Lal Vs ITO 203 ITR 456 (SC) 3. ITO Vs TechSpan India (P) Ltd [2018] 92 taxmann.com 361 (SC) 4. Multi Commodity Exchange of India Ltd Vs DCIT 423 ITR 445 (SC) 5. Multi Commodity Exchange of India Ltd Vs DCIT [2018] 91 taxmann.com 265 (Bombay) (HC) 6. S.Subrahmanyan Constructions Co (P) Ltd Vs ACIT [2021] 131 taxmann.com…

M/S AMBAJEE JEWELLERS JABALPUR,JABALPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX JABALPUR-1,, JABALPUR

In the result, appeal of the assessee is partly allowed

ITA 21/JAB/2022[2017-18]Status: DisposedITAT Jabalpur12 Dec 2025AY 2017-18

Bench: Shri Kul Bharatshri Nikhil Choudhary

For Respondent: Shri Shravan Kumar Meena, CIT DR
Section 143(3)Section 144Section 263Section 68

…on of the PCIT is bad in law, because of the audit objection not acceptable, in view of the judgment of the Hon’ble Supreme Court in the case of 11 AY 2017-18 M/s Ambajee jewellers Jabalpur ‘Commissioner of Income Tax vs. P.V.S. Beedies Pvt. Ltd.’ in [1999] 237 ITR 13 (SC). Therefore, while we hold that the jurisdiction of the learned PCIT was improperly exercised in relation to the purchases made from Ajay Rawat, there is no infirmity in the proceedings on account of the remaining issues under consideration. We, therefore, confirm the orders of the learned PCIT to that extent. The appeal of the assessee is acc…

INCOME TAX OFFICER, WARD-4(2), JALANDHAR, , CIVIL LINES vs. SH. BARJESH SINGHAL, MODERN COLONY

In the result, the appeal filed by the revenue is allowed for statistical purpose

ITA 363/ASR/2024[2016-17]Status: DisposedITAT Amritsar13 Oct 2025AY 2016-17

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: None (Written submission)
Section 142(1)Section 143(3)Section 147Section 148Section 250

…on the basis of (information) as per third party (Revenue Audit party) The reopening is otherwise valid being based on third party (Revenue audit party) also as per settled law as under. (i) CIT Vs P.V.S. Beedies (P.) Ltd. [1999] 103 Taxman 294 (SC)/ [1999] 237 ITR 13 (SC)/ [1999] 155 CTR 538 (SC)- "Audit party had merely pointed out a fact which had been overlooked by Assessing Officer and this was not a case of information on a question of law. Reopening of case under section 147(b) on basis of factual information given by internal audit party was valid in law" (ii) Usha International Ltd, vs Assessee on 9 M…

WHEELS INDIA LTD.,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeal filed by the assessee is allowed

ITA 696/CHNY/2025[2012-13]Status: DisposedITAT Chennai26 Aug 2025AY 2012-13

Bench: Ms. Padmavathy. S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.696/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 V. M/S. Wheels India Ltd., The Acit, No.21, Annasalai Patullos Road, Large Taxpayer Unit-1, Chennai-600 002. Chennai. [Pan: Aaacw 0315 K] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 115JSection 142(1)Section 143(2)Section 143(3)

…SC). She further submitted that the assessee failed to disclose the capital nature of these claims, justifying reopening beyond four years and relied upon the judgment of the Hon’ble Supreme Court of India in the case of CIT Vs P.V.S. Beedied Pvt. Ltd. [1999] 237 ITR 13 (SC). She furthermore contended that this is not a case of ‘change of opinion’ for the reason that the AO did not consciously evaluate these issues earlier, making reopening valid. 6. We have heard the rival submissions of the parties. We have also perused the case law citations referred by the parties. We find that assessee during the original…

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

ITA 596/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh30 May 2025AY 2017-18

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

…even if the reassessment was triggered by audit objections, it remains valid so long as the Assessing Officer has applied his independent judgment. This legal position has been confirmed by the Hon’ble Supreme Court in P.V.S. Beedies Pvt. Ltd. v. ACIT [(1999) 237 ITR 13 (SC)] and reaffirmed in Larsen & Toubro Ltd. v. State of Jharkhand & Ors. [2017] 82 taxmann.com 220 (SC). 8.3 By respectfully following the above decisions of the Hon’ble Supreme Court, we hold that the Assessing Officer recorded valid reasons and obtained due approval from the competent authority. Accordingly, we uphold the finding of the Ld. CIT…

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLEU��, PANCHKULA

Appeal is allowed

ITA 595/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh30 May 2025AY 2017-18

…if the\nreassessment was triggered by audit objections, it remains valid so\nlong as the Assessing Officer has applied his independent judgment.\nThis legal position has been confirmed by the Hon'ble Supreme\nCourt in P.V.S. Beedies Pvt. Ltd. v. ACIT [(1999) 237 ITR 13 (SC)] and\nreaffirmed in Larsen & Toubro Ltd. v. State of Jharkhand & Ors. [2017]\n82 taxmann.com 220 (SC).\n8.3 By respectfully following the above decisions of the Hon'ble\nSupreme Court, we hold that the Assessing Officer recorded valid\nreasons and obtained due approval from the competent authority.\nAccordingly, we uphold the finding of the L…

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

ITA 594/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh30 May 2025AY 2016-17

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

…even if the reassessment was triggered by audit objections, it remains valid so long as the Assessing Officer has applied his independent judgment. This legal position has been confirmed by the Hon’ble Supreme Court in P.V.S. Beedies Pvt. Ltd. v. ACIT [(1999) 237 ITR 13 (SC)] and reaffirmed in Larsen & Toubro Ltd. v. State of Jharkhand & Ors. [2017] 82 taxmann.com 220 (SC). 8.3 By respectfully following the above decisions of the Hon’ble Supreme Court, we hold that the Assessing Officer recorded valid reasons and obtained due approval from the competent authority. Accordingly, we uphold the finding of the Ld. CIT…

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA

Appeal is allowed

ITA 593/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh30 May 2025AY 2016-17

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

…even if the reassessment was triggered by audit objections, it remains valid so long as the Assessing Officer has applied his independent judgment. This legal position has been confirmed by the Hon’ble Supreme Court in P.V.S. Beedies Pvt. Ltd. v. ACIT [(1999) 237 ITR 13 (SC)] and reaffirmed in Larsen & Toubro Ltd. v. State of Jharkhand & Ors. [2017] 82 taxmann.com 220 (SC). 8.3 By respectfully following the above decisions of the Hon’ble Supreme Court, we hold that the Assessing Officer recorded valid reasons and obtained due approval from the competent authority. Accordingly, we uphold the finding of the Ld. CIT…

THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT,PANCHKULA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA

Appeal is allowed

ITA 592/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh30 May 2025AY 2016-17

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

…even if the reassessment was triggered by audit objections, it remains valid so long as the Assessing Officer has applied his independent judgment. This legal position has been confirmed by the Hon’ble Supreme Court in P.V.S. Beedies Pvt. Ltd. v. ACIT [(1999) 237 ITR 13 (SC)] and reaffirmed in Larsen & Toubro Ltd. v. State of Jharkhand & Ors. [2017] 82 taxmann.com 220 (SC). 8.3 By respectfully following the above decisions of the Hon’ble Supreme Court, we hold that the Assessing Officer recorded valid reasons and obtained due approval from the competent authority. Accordingly, we uphold the finding of the Ld. CIT…

ASSISTANT COMMISSIONER OF INCOME TAX, PANCHKULA CIRCLE, PANCHKULA, PANCHKULA vs. THE HARYANA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT, PANCHKULA

Appeal is allowed

ITA 591/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh30 May 2025AY 2015-16

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

…even if the reassessment was triggered by audit objections, it remains valid so long as the Assessing Officer has applied his independent judgment. This legal position has been confirmed by the Hon’ble Supreme Court in P.V.S. Beedies Pvt. Ltd. v. ACIT [(1999) 237 ITR 13 (SC)] and reaffirmed in Larsen & Toubro Ltd. v. State of Jharkhand & Ors. [2017] 82 taxmann.com 220 (SC). 8.3 By respectfully following the above decisions of the Hon’ble Supreme Court, we hold that the Assessing Officer recorded valid reasons and obtained due approval from the competent authority. Accordingly, we uphold the finding of the Ld. CIT…

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