CIT v. Sam Global Securities

336 ITR 112High Court2011#1300 most cited

What is CIT v. Sam Global Securities authority for?

Additional grounds of appeal that raise purely legal issues and do not require further fact-finding can be admitted for adjudication, even if not raised before the lower authorities, as they go to the root of the matter.

87

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Sam Global Securities · additional grounds · legal issue · root of the matter · admission of appeal · Assessing Officer jurisdiction

Sections most often in play

Section 153ASection 132Section 68Section 132ASection 144Section 148Section 153DSection 139

Issues it is cited on

section 115whsection 5(8)section 115wfsection 115wdsection 115wesection 124(3)closely held companysection 124section 120accumulated profitsrelated party transactionpanchnama

Judgments citing CIT v. Sam Global Securities

Asst CIT Cir 2, Thane vs. Salasar Developers, Thane

The appeals of the Revenue are dismissed

ITA 4513/MUM/2014[2006-07]Status: DisposedITAT Mumbai04 Apr 2017AY 2006-07

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 132Section 132(3)Section 133ASection 143(3)Section 153A

…on 153A(1)(a) of the Act. The expression clearly relates to a person in respect of whom search u/s 132 has been validly initiated as per section 153A itself provides. Our view find supports from Hon’ble Orissa High Court in Siksha “O” Anusandhan vs CIT (2011) 336 ITR 112 (Orissa). The Hon’ble High Court held as under:- “8. Section 132 prescribes that the competent authorities are empowered to permit the authorized officers to enter, search, break open, seize, place marks of identification and take other steps as contemplated under sub-clauses (i) to (v). However, such powers can be exercised against a person upon…

Asst CIT Cir 2, Thane vs. Salasar Developers, Thane

The appeals of the Revenue are dismissed

ITA 4512/MUM/2014[2005-06]Status: DisposedITAT Mumbai04 Apr 2017AY 2005-06

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 132Section 132(3)Section 133ASection 143(3)Section 153A

…on 153A(1)(a) of the Act. The expression clearly relates to a person in respect of whom search u/s 132 has been validly initiated as per section 153A itself provides. Our view find supports from Hon’ble Orissa High Court in Siksha “O” Anusandhan vs CIT (2011) 336 ITR 112 (Orissa). The Hon’ble High Court held as under:- “8. Section 132 prescribes that the competent authorities are empowered to permit the authorized officers to enter, search, break open, seize, place marks of identification and take other steps as contemplated under sub-clauses (i) to (v). However, such powers can be exercised against a person upon…

Asst CIT Cir 2, Thane vs. Salasar Developers, Thane

The appeals of the Revenue are dismissed

ITA 4511/MUM/2014[2004-05]Status: DisposedITAT Mumbai04 Apr 2017AY 2004-05

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 132Section 132(3)Section 133ASection 143(3)Section 153A

…on 153A(1)(a) of the Act. The expression clearly relates to a person in respect of whom search u/s 132 has been validly initiated as per section 153A itself provides. Our view find supports from Hon’ble Orissa High Court in Siksha “O” Anusandhan vs CIT (2011) 336 ITR 112 (Orissa). The Hon’ble High Court held as under:- “8. Section 132 prescribes that the competent authorities are empowered to permit the authorized officers to enter, search, break open, seize, place marks of identification and take other steps as contemplated under sub-clauses (i) to (v). However, such powers can be exercised against a person upon…

Balaji Universal Tradelink P.Ltd, Mumbai vs. DCIT Cen Cir 40, Mumbai

The appeals of the assessee are allowed and that of the Revenue are dismissed

ITA 2183/MUM/2013[2004-05]Status: DisposedITAT Mumbai31 Oct 2016AY 2004-05

Bench: Shri Joginder Singh & Shri Sanjay Arora

Section 132(3)Section 133ASection 143(3)Section 153A

…spect of whom search u/s 132 has been validly initiated as per section 153A itself provides. Our view find supports from ITA Nos.2183 to 2186/Mum/2013 & M/s Balaji Universal Tradelinks Pvt. Ltd. Hon’ble Orissa High Court in Siksha “O” Anusandhan vs CIT (2011) 336 ITR 112 (Orissa). The Hon’ble High Court held as under:- “8. Section 132 prescribes that the competent authorities are empowered to permit the authorized officers to enter, search, break open, seize, place marks of identification and take other steps as contemplated under sub-clauses (i) to (v). However, such powers can be exercised against a person upo…

Commissioner of Income Tax vs. Agriculturl Market Committee

ITTA/119/2011HC Telangana20 Apr 2011

Bench: V.V.S.RAO,RAMESH RANGANATHAN

Commissioner of Income Tax vs. Agriculturl Market Committee

ITTA/118/2011HC Telangana20 Apr 2011

Bench: V.V.S.RAO,RAMESH RANGANATHAN

Commissioner of Income Tax-2 vs. Agricultural Market Committee

ITTA/117/2011HC Telangana20 Apr 2011

Bench: V.V.S.RAO,RAMESH RANGANATHAN