CIT v. Ranicherra Tea Co. Ltd.

207 ITR 979High Court1994#2588 most cited

What is CIT v. Ranicherra Tea Co. Ltd. authority for?

An Assessing Officer cannot make a capricious assessment or estimate income/profit without assigning reasons and supporting material, even when rejecting the assessee's books of account or making a best judgment assessment. The Assessing Officer must act judiciously and not based on pure guesswork.

45

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. Ranicherra Tea Co. Ltd. · Ranicherra Tea Co. Ltd. · best judgment assessment · arbitrary assessment · capricious assessment · reasons for assessment · profit estimation · rejection of books · material for estimation · pure guess · Assessing Officer duty · CIT(A) powers · natural justice principles

Also reported as

75 Taxmann 164

Issues it is cited on

section 115besection 256(1)section 256section 80ib(10)project completion methodon money receiptsection 18section 192section 80ibdumb documentssection 44asection 44ad

Judgments citing CIT v. Ranicherra Tea Co. Ltd.

TEJASVI SINGH, DEPUTY COMMISSIONER OF INCOME TAX vs. AMTEK TRANSPORTATION SYSTEMS LTD, HARYANA

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

ITA 1282/DEL/2024[2021-22]Status: DisposedITAT Delhi05 Dec 2025AY 2021-22

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmadcit, Vs. Amtek Transportation Systems Ltd., Delhi. Begampur Khatoula, Gurgaon Khandsa 104, Gurgaon – 122 004 (Haryana). (Pan : Aahca5047K) (Appellant) (Respondent) Assessee By : Shri S. Krishnan, Advocate Revenue By : Shri Amit Jain, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 24.01.2024 For The Assessment Year 2021-22 Raising Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 7.86 Crore Made On Account Of Discrepancy Found In The Sales Turnover Reflected In Form 26As Vis-A-Vis Gross Sales Reported In The Profit & Loss Account By Accepting The Additional Evidence Furnished By The Assessee Without Appreciating The Fact The Assessee Has Been Provided Sufficient Opportunity During The Assessment Proceedings To Furnish The Details In This Regard.

For Appellant: Shri S. Krishnan, AdvocateFor Respondent: Shri Amit Jain, CIT DR

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘A’: NEW DELHI. BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI ANUBHAV SHARMA, JUDICIAL MEMBER DCIT, vs. Amtek Transportation Systems Ltd., Delhi. Begampur Khatoula, Gurgaon Khandsa 104, Gurgaon – 122 004 (Haryana). (PAN : AAHCA5047K) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri S. Krishnan, Advocate REVENUE BY : Shri Amit Jain, CIT DR Date of Hearing : 10.09.2025 Date of Order : 05.12.2025 O R D E R PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER : 1. This appeal is filed by the Revenue against the order of the Learned Commissioner of Income-tax (Appeals)/Natio…

SITA RAM SAINI,CHOMU, JAIPUR vs. ITO WARD 7(3), JAIPUR

In the result, the appeal of the assessee is allowed

ITA 710/JPR/2023[2014-15]Status: DisposedITAT Jaipur01 Jan 2025AY 2014-15

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Mrs. Prabha Rana, (Adv.) &For Respondent: Mrs. Meenakshi Vohra ( Addl. CIT) a
Section 144Section 154Section 250Section 80C

…2. ICICI Bank statement 16-22 3. Bank of Baroda 23-30 4. (2002) 125 Taxman 259 (Gau) (Mag.) ITAT Gauhati 31-34 bench ACIT vs. Kamini Finance & Investement Co. Ltd. IT Appeal No. 240 ( Gauhati) of 1994 October 31,2001 5. (1994) 75 Taxman 164 ( Calcutta)/(1994) 207 ITR 979 35-38 Calcutta/(1995) 124 CTR 113 (Calcutta) (2304.1993) High Court of Calcutta CIT v. Ranicherra Tea Co. Ltd. 6. Reply 18.11.2016 AY 2014-15 39-39 7. Reply of SCN 2.12.2016 AY 2014-15 40-40 8. Reply 143(2) 05.09.2016 AY 2014-15 41-41 9. Cash book AY 2014-15 42-49 10. BOB Ledger AY 2014-15 50-52 11. PNB Ledger AY 2014-15 53-55 12. ICICI Bank Ledg…

RAM KUMAR GUPTA,KOLKATA vs. ACIT, CIR. 43, , KOLKATA

In the result, the appeal of the assessee stands allowed

ITA 309/KOL/2024[2017-18]Status: DisposedITAT Kolkata09 Aug 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.309/Kol/2024 Assessment Year: 2017-18 Ram Kumar Gupta…...…………….....……………………....………....Appellant 67/46, Posta Chowrasta, Kolkata -700007. [Pan: Adrpg8556B] Vs. Acit, Circle-43, Kolkata…...................................................…..…..... Respondent Appearances By: Shri Rajiva Kumar, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit- Dr On Behalf Of P. P. Barman, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 30, 2024 Date Of Pronouncing The Order : August 09, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Confirmation Of Addition Of Rs.1,10,46,000/- Made By The Assessing Officer On Account Of Cash Deposits In The Bank Account Of The Assessee During Demonetization Period. 3. The Brief Facts Of The Case Are That The Assessee Derives Income From Retail Trading In The Name Of M/S R. Kumar & Co. The Assessee Filed His Return Of Income On 28.07.2017 Declaring A Total Income Of Rs.8,19,420/-. The Return Was Selected For Scrutiny & Notices U/S

Section 250Section 44ASection 68

…udicial proceeding in the strict sense, the AO must be guided by the judicial considerations and by the rule of justice, equity and good conscience" [Abdul Kayam Vs. GIT (1933) 1 ITR 375, Kunwarji Ananda Vs. CIT (1931) 5 ITC 417, GIT Vs. Ranicherra Tea (1994) 207 ITR 979}. 1.16 In case of a best judgment assessment "the AO should not be influenced by a desire to punish the assessee for default which attracts the operation of this section, however culpable such default might be" [Jot Ram Sher Singh Vs CIT (1934) 2 ITR 129]. Further, "an assessment framed under this section does not mean that the A.O can make the a…

DCIT,C-7, JAIPUR vs. BHARAT MOHAN RATURI, JAIPUR

In the result, the appeal of the Department is dismissed and that of the C

ITA 413/JPR/2022[2013-14]Status: DisposedITAT Jaipur11 Jul 2023AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No. 413/JP/2022 fu/kZkj.ko"kZ@AssessmentYear :2013-14 The DCIT Circle-7 Jaipur cuke Vs. Shri Bharat Mohan Raturi 161, Indira Colony, Bani Park Jaipur 302 015 (Raj) LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AANPR 7066G vihykFkhZ@Appellant izR;FkhZ@Respondent CO No. 2/JP/2023 (Arising out of vk;djvihy la-@ITA No. 413/JP/2022 ) fu/kZkj.ko"kZ@AssessmentYear :2013-14 Shri Bharat Mohan Raturi 161, Indira

For Appellant: Shri Anil Goya, CA &For Respondent: Mrs. Runi Pal, Addl. CIT-DR
Section 148Section 54Section 54F

…आयकरअपीलीय अधिकरण] जयपुरन्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR JhlanhixkslkbZ]U;kf;dlnL; ,oaJhjkBksMdeys'kt;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: SHRI SANDEEP GOSAIN, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No. 413/JP/2022 fu/kZkj.ko"kZ@AssessmentYear :2013-14 cuke The DCIT Shri Bharat Mohan Raturi Vs. 161, Indira Colony, Bani Park Circle-7 Jaipur 302 015 (Raj) Jaipur LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AANPR 7066G vihykFkhZ@Appellant izR;FkhZ@Respondent CO No. 2/JP/2023 (Arising out of vk;djvihy la-@ITA No. 413/JP/2022 ) fu/kZkj.ko"kZ@AssessmentYe…

GIRIRAJ PRASAD GOYAL,TONK vs. ITO TONK, TONK

In the result, both appeals of the assessee are allowed for statistical

ITA 200/JPR/2023[2014-15]Status: HeardITAT Jaipur05 Jul 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Shrawan Kumar Gupta (Adv.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 143(3)Section 147Section 148Section 24

…sallowing 50% of expenditure debited to the construction account and CIT(A) was justified in deleting the same on the ground that profit rate of 12% declared by the assessee was quite reasonable. Giriraj Prasad Goyal vs. ITO 7.3 In CIT v/s Ranichhera Tea Co. 207 ITR 979 (Cal), it has been held that Assessee filing loss return and failing to produce books of accounts on requisition by the ITO- ITO rejecting loss return and determining the income at nil without assigning any reasons – ITO not justified . Here also the AO disallowed 20% disallowance by not assigning any reasons only on the imaginary basis, when the…

DY. COMMISSIONER OF INCOME TAX, CC, VAPI, VAPI vs. POONAM DEVELOPERS LLP, DADRA & NAGAR HAVELI (UT)

In the result, these Cross-Objections Nos

ITA 320/SRT/2022[2019-20]Status: DisposedITAT Surat26 Jun 2023AY 2019-20

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

Section 143(3)

…see which ranges between 4% to 6%. The ld CIT(A) has to bring on record some material to justify the rate of profit estimated by him and the basis of such estimate. This has been so held by the Hon'ble Calcutta High Court in the case of Ranichera Tea Co. Ltd. 207 ITR 979. The ld CIT(A) has conterminous power, he can do what the Assessing Officer can do. The Assessing Officer cannot make a pure guess as has been held in the case of Dhakeshwari Cotton Mills reported in 26 ITR page 775. Moreover, he has determined the gross profit when for the purpose of computation of total income it is not the gross profit but net…

DY. COMMISSIONER OF INCOME TAX, CC, VAPI, VAPI vs. POONAM DEVELOPERS LLP, DADRA & NAGAR HAVELI (UT)

In the result, these Cross-Objections Nos

ITA 319/SRT/2022[2018-19]Status: DisposedITAT Surat26 Jun 2023AY 2018-19

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

Section 143(3)

…see which ranges between 4% to 6%. The ld CIT(A) has to bring on record some material to justify the rate of profit estimated by him and the basis of such estimate. This has been so held by the Hon'ble Calcutta High Court in the case of Ranichera Tea Co. Ltd. 207 ITR 979. The ld CIT(A) has conterminous power, he can do what the Assessing Officer can do. The Assessing Officer cannot make a pure guess as has been held in the case of Dhakeshwari Cotton Mills reported in 26 ITR page 775. Moreover, he has determined the gross profit when for the purpose of computation of total income it is not the gross profit but net…

DY. COMMISSIONER OF INCOME TAX, CC, VAPI, VAPI vs. POONAM DEVELOPERS LLP, DADRA & NAGAR HAVELI (UT)

In the result, these Cross-Objections Nos

ITA 318/SRT/2022[2017-18]Status: DisposedITAT Surat26 Jun 2023AY 2017-18

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

Section 143(3)

…see which ranges between 4% to 6%. The ld CIT(A) has to bring on record some material to justify the rate of profit estimated by him and the basis of such estimate. This has been so held by the Hon'ble Calcutta High Court in the case of Ranichera Tea Co. Ltd. 207 ITR 979. The ld CIT(A) has conterminous power, he can do what the Assessing Officer can do. The Assessing Officer cannot make a pure guess as has been held in the case of Dhakeshwari Cotton Mills reported in 26 ITR page 775. Moreover, he has determined the gross profit when for the purpose of computation of total income it is not the gross profit but net…

DY. COMMISSIONER OF INCOME TAX, CC, VAPI vs. M/S. M POONAM DEVELOPERS, VALSAD

In the result, these Cross-Objections Nos

ITA 286/SRT/2022[2019-20]Status: DisposedITAT Surat26 Jun 2023AY 2019-20

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

Section 143(3)

…see which ranges between 4% to 6%. The ld CIT(A) has to bring on record some material to justify the rate of profit estimated by him and the basis of such estimate. This has been so held by the Hon'ble Calcutta High Court in the case of Ranichera Tea Co. Ltd. 207 ITR 979. The ld CIT(A) has conterminous power, he can do what the Assessing Officer can do. The Assessing Officer cannot make a pure guess as has been held in the case of Dhakeshwari Cotton Mills reported in 26 ITR page 775. Moreover, he has determined the gross profit when for the purpose of computation of total income it is not the gross profit but net…

DY. COMMISSIONER OF INCOME TAX, CC, VAPI vs. M/S. M POONAM DEVELOPERS, VALSAD

In the result, these Cross-Objections Nos

ITA 285/SRT/2022[2018-19]Status: DisposedITAT Surat26 Jun 2023AY 2018-19

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

Section 143(3)

…see which ranges between 4% to 6%. The ld CIT(A) has to bring on record some material to justify the rate of profit estimated by him and the basis of such estimate. This has been so held by the Hon'ble Calcutta High Court in the case of Ranichera Tea Co. Ltd. 207 ITR 979. The ld CIT(A) has conterminous power, he can do what the Assessing Officer can do. The Assessing Officer cannot make a pure guess as has been held in the case of Dhakeshwari Cotton Mills reported in 26 ITR page 775. Moreover, he has determined the gross profit when for the purpose of computation of total income it is not the gross profit but net…

DY. COMMISSIONER OF INCOME TAX, CC, VAPI vs. M/S. M POONAM DEVELOPERS, VALSAD

In the result, these Cross-Objections Nos

ITA 284/SRT/2022[2016-17]Status: DisposedITAT Surat26 Jun 2023AY 2016-17

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

Section 143(3)

…see which ranges between 4% to 6%. The ld CIT(A) has to bring on record some material to justify the rate of profit estimated by him and the basis of such estimate. This has been so held by the Hon'ble Calcutta High Court in the case of Ranichera Tea Co. Ltd. 207 ITR 979. The ld CIT(A) has conterminous power, he can do what the Assessing Officer can do. The Assessing Officer cannot make a pure guess as has been held in the case of Dhakeshwari Cotton Mills reported in 26 ITR page 775. Moreover, he has determined the gross profit when for the purpose of computation of total income it is not the gross profit but net…

FALGUNI GHOSH,HOWRAH vs. ITO, WARD - 47(1), KOLKATA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 303/KOL/2023[2011-12]Status: DisposedITAT Kolkata12 Jun 2023AY 2011-12

Bench: Dr. Manish Borad & Sonjoy Sarma

Section 144Section 148Section 250

…ng a best judgement assessment, the AO does not process absolute authority to assess any figure he likes, although he is not bound by strict judicial principals, he should be guided rule of justices, equity and good conscience. [CIT Vs. Ranichera Tea Co. Ltd. 207 ITR 979 (Cal)] 3) The authority making a best judgment assessment must make an honest and fair estimate of the income of assessee and through arbitrariness cannot be avoided; the same must not be capricious but should have a reasonable nexus with available material. This view has been expressed in Brij Bhushan Lal Parduman Kumar vs. CIT, reported at 115…

FALGUNI GHOSH,HOWRAH vs. ITO, WARD - 47(1), KOLKATA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 302/KOL/2023[2010-11]Status: DisposedITAT Kolkata12 Jun 2023AY 2010-11

Bench: Dr. Manish Borad & Sonjoy Sarma

Section 144Section 148Section 250

…ng a best judgement assessment, the AO does not process absolute authority to assess any figure he likes, although he is not bound by strict judicial principals, he should be guided rule of justices, equity and good conscience. [CIT Vs. Ranichera Tea Co. Ltd. 207 ITR 979 (Cal)] 3) The authority making a best judgment assessment must make an honest and fair estimate of the income of assessee and through arbitrariness cannot be avoided; the same must not be capricious but should have a reasonable nexus with available material. This view has been expressed in Brij Bhushan Lal Parduman Kumar vs. CIT, reported at 115…

DY. COMMISSIONER OF INCOME TAX, CIRCLE - 01, VARANASI vs. PERFECT TECNO COUNSULTANTS PVT. LTD. , VARANASI

In the result, the appeal of the Revenue is allowed for statistical purposes

ITA 139/VNS/2020[2017-2018]Status: DisposedITAT Varanasi13 Apr 2023AY 2017-2018

Bench: Shri Ramit Kochar & Shri Pavan Kumar Gadaleassessment Year: 2017-18 Dy. Commissioner Of Income Perfect Techno Consultants Pvt. Ltd., Tax, Circle-1, Aayakarbhawan, V. N-1/65-A, Narrotam Nagar Colony, M A Road, Varanasi- Nagwa, Lanka Varanasi-221005,U.P. 221002,U.P. Pan:Aagcp3236N (Appellant) (Respondent) Revenue By: Sh. Amalendunath Mishra, Cit Dr Assessee By: Sh. Mohammad Ashraf, C.A. Date Of Hearing: 11.04.2023 Date Of Pronouncement: 13.04.2023 O R D E R

For Appellant: Sh. Mohammad Ashraf, C.AFor Respondent: Sh. AmalenduNath Mishra, CIT DR
Section 115JSection 142(1)Section 143(2)Section 144Section 250Section 68Section 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL CIRCUIT BENCH, VARANASI BEFORE SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER AND SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER Assessment Year: 2017-18 Dy. Commissioner of Income Perfect Techno Consultants Pvt. Ltd., Tax, Circle-1, AayakarBhawan, v. N-1/65-A, Narrotam Nagar Colony, M A Road, Varanasi- Nagwa, Lanka Varanasi-221005,U.P. 221002,U.P. PAN:AAGCP3236N (Appellant) (Respondent) Revenue by: Sh. AmalenduNath Mishra, CIT DR Assessee by: Sh. Mohammad Ashraf, C.A. Date of hearing: 11.04.2023 Date of pronouncement: 13.04.2023 O R D E R PER SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER: This app…

ACIT, CENTRAL CIRCLE, VAPI, VAPI vs. POONAM DEVELOPERS, VALSAD

In the result, appeal of the Revenue is dismissed whereas appeal filed by the assessee is partly allowed

ITA 27/SRT/2021[2017-18]Status: DisposedITAT Surat06 May 2022AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.15/Srt/2021 & 27/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) (Virtual Court Hearing) M/S. Poonam Developers, Vs. The Acit, Central Circle-1, 402, Amar Chambers, Opp. Lal Vapi. School, Station Road, Valsad- 396001. (Assessee) (Revenue) The Acit, Central Circle-1, Vs. M/S. Poonam Developers, Vapi. 402, Amar Chambers, Opp. Lal School, Station Road, Valsad-396001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfm9582G (Revenue) (Assessee) Shri Hardik Vora, Ar Assessee By Shri Sita Ram Meena, Sr. Dr Respondent By 11/02/2022 Date Of Hearing 06/05/2022 Date Of Pronouncement

Section 115BSection 133ASection 143(3)Section 68

…e which ranges between 4% to 6%. The ld CIT(A) has to bring on record some material to justify the rate of profit estimated by him and the basis of such estimate. This has been so held by the Hon'ble Calcutta High Court in the case of Ranicherra Tea Co. Ltd., 207 ITR 979. The ld CIT(A) has conterminous power, he can do what the assessing officer can do. The assessing officer cannot make a pure guess as has been held in the case of Dhakeshwari Cotton Mills reported in 26 ITR page 775. Moreover, he has determined the gross profit when for the purpose of computation of total income it is not the gross profit but net…

POONAM DEVELOPERS,VALSAD vs. ACIT, CENTRAL CIRCLE-1, VAPI

In the result, appeal of the Revenue is dismissed whereas appeal filed by the assessee is partly allowed

ITA 15/SRT/2021[2017-18]Status: DisposedITAT Surat06 May 2022AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.15/Srt/2021 & 27/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) (Virtual Court Hearing) M/S. Poonam Developers, Vs. The Acit, Central Circle-1, 402, Amar Chambers, Opp. Lal Vapi. School, Station Road, Valsad- 396001. (Assessee) (Revenue) The Acit, Central Circle-1, Vs. M/S. Poonam Developers, Vapi. 402, Amar Chambers, Opp. Lal School, Station Road, Valsad-396001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfm9582G (Revenue) (Assessee) Shri Hardik Vora, Ar Assessee By Shri Sita Ram Meena, Sr. Dr Respondent By 11/02/2022 Date Of Hearing 06/05/2022 Date Of Pronouncement

Section 115BSection 133ASection 143(3)Section 68

…e which ranges between 4% to 6%. The ld CIT(A) has to bring on record some material to justify the rate of profit estimated by him and the basis of such estimate. This has been so held by the Hon'ble Calcutta High Court in the case of Ranicherra Tea Co. Ltd., 207 ITR 979. The ld CIT(A) has conterminous power, he can do what the assessing officer can do. The assessing officer cannot make a pure guess as has been held in the case of Dhakeshwari Cotton Mills reported in 26 ITR page 775. Moreover, he has determined the gross profit when for the purpose of computation of total income it is not the gross profit but net…

BRIDGE & BUILDING CONSTRUCTION CO. PVT. LTD.,KOLKATA vs. ACIT, CENTRAL CIRCLE - 2(1), KOLKATA , KOLKATA

ITA 534/KOL/2018[2014-15]Status: DisposedITAT Kolkata22 Dec 2021AY 2014-15

Bench: Hon’Ble Shri A. T. Varkey, Jm & Shri Manish Borad, Am]

Section 143(2)Section 144

…1 ITA Nos. 374,375,533,534&2116/Kol/2018 Bridge & Building Construction Co. P. Ltd. AYs: 2012-13 to 2014-15 आयकर अपील"य अधीकरण, "यायपीठ –“B” कोलकाता, IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH: KOLKATA [Before Hon’ble Shri A. T. Varkey, JM & Shri Manish Borad, AM] I.T.A. Nos. 374 & 375/Kol/2018 Assessment Years: 2012-13 &2014-15 DCIT, Circle-10(1), Kolkata Vs. M/s. Bridge & Building Construction Co. Pvt. Ltd. (PAN: AADCB0689E) Appellant Respondent I.T.A. Nos. 533/Kol/2018 Assessment Years: 2012-13 M/s. Bridge & Building Vs. DCIT, Central Circle- Construction Co. Pvt. Ltd. 2(1), Kolkata (PAN: AADCB0689E) App…

BRIDGE & BUILDING CONSTRUCTION CO. PVT. LTD.,KOLKATA vs. DCIT, CENTRAL CIRCLE - 2(1), KOLKATA , KOLKATA

ITA 533/KOL/2018[2012-13]Status: DisposedITAT Kolkata22 Dec 2021AY 2012-13

Bench: Hon’Ble Shri A. T. Varkey, Jm & Shri Manish Borad, Am]

Section 143(2)Section 144

…1 ITA Nos. 374,375,533,534&2116/Kol/2018 Bridge & Building Construction Co. P. Ltd. AYs: 2012-13 to 2014-15 आयकर अपील"य अधीकरण, "यायपीठ –“B” कोलकाता, IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH: KOLKATA [Before Hon’ble Shri A. T. Varkey, JM & Shri Manish Borad, AM] I.T.A. Nos. 374 & 375/Kol/2018 Assessment Years: 2012-13 &2014-15 DCIT, Circle-10(1), Kolkata Vs. M/s. Bridge & Building Construction Co. Pvt. Ltd. (PAN: AADCB0689E) Appellant Respondent I.T.A. Nos. 533/Kol/2018 Assessment Years: 2012-13 M/s. Bridge & Building Vs. DCIT, Central Circle- Construction Co. Pvt. Ltd. 2(1), Kolkata (PAN: AADCB0689E) App…

DCIT, CIRCLE - 10(1), KOLKATA , KOLKATA vs. M/S. BRIDGE & BUILDING CONSTRUCTION CO. PVT. LTD., KOLKATA

ITA 375/KOL/2018[2014-15]Status: DisposedITAT Kolkata22 Dec 2021AY 2014-15

Bench: Hon’Ble Shri A. T. Varkey, Jm & Shri Manish Borad, Am]

Section 143(2)Section 144

…1 ITA Nos. 374,375,533,534&2116/Kol/2018 Bridge & Building Construction Co. P. Ltd. AYs: 2012-13 to 2014-15 आयकर अपील"य अधीकरण, "यायपीठ –“B” कोलकाता, IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH: KOLKATA [Before Hon’ble Shri A. T. Varkey, JM & Shri Manish Borad, AM] I.T.A. Nos. 374 & 375/Kol/2018 Assessment Years: 2012-13 &2014-15 DCIT, Circle-10(1), Kolkata Vs. M/s. Bridge & Building Construction Co. Pvt. Ltd. (PAN: AADCB0689E) Appellant Respondent I.T.A. Nos. 533/Kol/2018 Assessment Years: 2012-13 M/s. Bridge & Building Vs. DCIT, Central Circle- Construction Co. Pvt. Ltd. 2(1), Kolkata (PAN: AADCB0689E) App…

DCIT, CIRCLE - 10(1), KOLKATA , KOLKATA vs. M/S. BRIDGE & BUILDING CONSTRUCTION CO. PVT. LTD., KOLKATA

ITA 374/KOL/2018[2012-13]Status: DisposedITAT Kolkata22 Dec 2021AY 2012-13

Bench: Hon’Ble Shri A. T. Varkey, Jm & Shri Manish Borad, Am]

Section 143(2)Section 144

…1 ITA Nos. 374,375,533,534&2116/Kol/2018 Bridge & Building Construction Co. P. Ltd. AYs: 2012-13 to 2014-15 आयकर अपील"य अधीकरण, "यायपीठ –“B” कोलकाता, IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH: KOLKATA [Before Hon’ble Shri A. T. Varkey, JM & Shri Manish Borad, AM] I.T.A. Nos. 374 & 375/Kol/2018 Assessment Years: 2012-13 &2014-15 DCIT, Circle-10(1), Kolkata Vs. M/s. Bridge & Building Construction Co. Pvt. Ltd. (PAN: AADCB0689E) Appellant Respondent I.T.A. Nos. 533/Kol/2018 Assessment Years: 2012-13 M/s. Bridge & Building Vs. DCIT, Central Circle- Construction Co. Pvt. Ltd. 2(1), Kolkata (PAN: AADCB0689E) App…

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CIT v. Ranicherra Tea Co. Ltd. (207 ITR 979) — Cited in 45 Judgments | BharatTax