What is CIT v. SFIL Stock Broking Ltd. authority for?

Reassessment proceedings under Section 147 are invalid and void ab initio if initiated based on 'borrowed satisfaction' without the Assessing Officer's independent application of mind, or merely on documents already available on record without fresh tangible material.

How many judgments cite CIT v. SFIL Stock Broking Ltd.?

243 judgments on BharatTax cite CIT v. SFIL Stock Broking Ltd. (325 ITR 285), spanning 2011 to 2026.

Which sections of the Income Tax Act does CIT v. SFIL Stock Broking Ltd. come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 68, Section 250, Section 151.

CIT v. SFIL Stock Broking Ltd. (325 ITR 285)

Ujjala Suppliers Pvt. Ltd., Darjeeling vs. ITO, Ward-2(1), Siliguri

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

ITA 741/KOL/2023[2010-11]Status: DisposedITAT Kolkata07 Dec 2023AY 2010-11

Bench: Sri Rajpal Yadav & Sri Rajesh Kumar

Section 133(6)Section 147Section 148Section 148(2)

…sions of the Act and may kindly be quashed. Ld. A/R relied in defence of his arguments on the decisions of Hon'ble Delhi High Court in the case of ACIT vs. Meenakshi Overseas Pvt. Ltd. [2017] 82 taxmann.com 300 (Del), CIT vs. SFIL Stock Broking Ltd. in [2010] 325 ITR 285 (Del) and Hon'ble Kolkata ITAT in the case of DCIT vs. Great Wall Marketing Pvt. Ltd. in ITA No. 660/KOL/2011 for AY 2002-03 order dated 03.02.2016. 5. Ld. D/R on the other hand, contended that the AO reopened the assessment after receiving information from ITO(Inv.), Unit-3, Kolkata that the assessee has fixed deposits in his bank account which…

Ujjala Suppliers (P) Ltd., Darjeeling vs. ITO, WD-2(1), Siliguri, Matigara

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

ITA 733/KOL/2023[2009-10]Status: DisposedITAT Kolkata07 Dec 2023AY 2009-10

Bench: Sri Rajpal Yadav & Sri Rajesh Kumar

Section 133(6)Section 147Section 148Section 148(2)

…sions of the Act and may kindly be quashed. Ld. A/R relied in defence of his arguments on the decisions of Hon'ble Delhi High Court in the case of ACIT vs. Meenakshi Overseas Pvt. Ltd. [2017] 82 taxmann.com 300 (Del), CIT vs. SFIL Stock Broking Ltd. in [2010] 325 ITR 285 (Del) and Hon'ble Kolkata ITAT in the case of DCIT vs. Great Wall Marketing Pvt. Ltd. in ITA No. 660/KOL/2011 for AY 2002-03 order dated 03.02.2016. 5. Ld. D/R on the other hand, contended that the AO reopened the assessment after receiving information from ITO(Inv.), Unit-3, Kolkata that the assessee has fixed deposits in his bank account which…

Assistant Commissioner of Income Tax, Circle-1, Guwahati vs. Bath and Sanitary, Guwahati

In the result, the appeal of revenue is dismissed

ITA 169/GTY/2020[2012-13]Status: DisposedITAT Guwahati30 Oct 2023AY 2012-13

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 147Section 148Section 68

…eopening of assessment on the 4 Bath & Sanitary, AY 2012-13 ground of mechanical reopening and borrowed satisfaction. The case of the assessee finds support from the decision of Hon’ble Delhi High Court in the case of CIT vs. SFIL Stock Broking Ltd. in [2010] 325 ITR 285 (Del) wherein it was held that the AO has to apply his mind to the information and independently arrived at a belief that income had escaped assessment otherwise the reopening of assessment cannot be sustained. The Hon’ble Bombay High Court in the case of Hindustan Lever Ltd. vs R.B. Wadkar (No. 1) in 2004 137 TAXMAN 479 (Bom) has held the reason…

Shark Packaging (India) Private Limited, Delhi vs. ITO, Ward-23(1), New Delhi

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

ITA 2163/DEL/2022[2008-09]Status: DisposedITAT Delhi17 Oct 2023AY 2008-09

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Anuj Garg, Addl. CIT

Section 147Section 148Section 253Section 46ASection 68Section 69C

…and without any independent application of mind has not been held to be valid some of which are listed below: - Commissioner of Income-tax v. Smt Paramjit Kaur [2009) 311 ITR 38 (Punjab & Haryana)]; Commissioner of Income-tax v. SFIL Stock Broking Ltd [(2010) 325 ITR 285 (Delhi)]; PCIT v. N C Cables Pvt Ltd [2017) 391 ITR 11 (Delhi)] Mrs. Sejal J. Panchal v. Income-tax Officer [2018] 90 taxmann.com 305(Ahmedabad - Trib.) In addition to above noted citations, the ld. counsel has also placed vehement reliance on the judgment of Hon’ble High Court of Delhi in the case of CIT vs. Insecticides (India) Ltd. [(2013) 38…

Shark Packaging (India) Pvt Ltd, New Delhi vs. ITO Ward - 23(1), New Delhi

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

ITA 8310/DEL/2019[2012-13]Status: DisposedITAT Delhi17 Oct 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Anuj Garg, Addl. CIT

Section 147Section 148Section 253Section 46ASection 68Section 69C

…and without any independent application of mind has not been held to be valid some of which are listed below: - Commissioner of Income-tax v. Smt Paramjit Kaur [2009) 311 ITR 38 (Punjab & Haryana)]; Commissioner of Income-tax v. SFIL Stock Broking Ltd [(2010) 325 ITR 285 (Delhi)]; PCIT v. N C Cables Pvt Ltd [2017) 391 ITR 11 (Delhi)] Mrs. Sejal J. Panchal v. Income-tax Officer [2018] 90 taxmann.com 305(Ahmedabad - Trib.) In addition to above noted citations, the ld. counsel has also placed vehement reliance on the judgment of Hon’ble High Court of Delhi in the case of CIT vs. Insecticides (India) Ltd. [(2013) 38…

Shark Packaging (India) Pvt Ltd, New Delhi vs. ITO Ward - 23(1), New Delhi

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

ITA 8309/DEL/2019[2011-12]Status: DisposedITAT Delhi17 Oct 2023AY 2011-12

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Anuj Garg, Addl. CIT

Section 147Section 148Section 253Section 46ASection 68Section 69C

…and without any independent application of mind has not been held to be valid some of which are listed below: - Commissioner of Income-tax v. Smt Paramjit Kaur [2009) 311 ITR 38 (Punjab & Haryana)]; Commissioner of Income-tax v. SFIL Stock Broking Ltd [(2010) 325 ITR 285 (Delhi)]; PCIT v. N C Cables Pvt Ltd [2017) 391 ITR 11 (Delhi)] Mrs. Sejal J. Panchal v. Income-tax Officer [2018] 90 taxmann.com 305(Ahmedabad - Trib.) In addition to above noted citations, the ld. counsel has also placed vehement reliance on the judgment of Hon’ble High Court of Delhi in the case of CIT vs. Insecticides (India) Ltd. [(2013) 38…

Kailash Chand Yadav, 100, Kalu Baba Ki Dhani, Sheoshinghpur, Akoda, Phulera-303338 vs. Income Tax Officer, Ward - 1(2), Jaipur

In the result, the appeal of the assessee is partly allowed

ITA 82/JPR/2023[2010-11]Status: DisposedITAT Jaipur11 Sept 2023AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri S.L. Poddar(Adv.)&For Respondent: Smt. Monisha Choudhary(Addl.CIT)

Section 142(1)Section 148Section 69A

…ed 28.10.2015 Reopening solely on the basis of information received from another AO that the assessee has booked bogus bills but without independent application of mind to the information renders the reopening void. (vi) CIT Vs. SFIL Stock Broking Ltd. (2010) 41 DTR 98 (Del) Reassessment-Reason to believe-Reopening on directions of superior officers-50- called reasons recorded by the AO for reopening assessee's assessment comprises mere information received from Dy. Director of IT (Inv.) followed by directions of the very same officer and the Addl. CIT to initiate proceedings under s. 147- These cannot be the rea…

M/S. Saraff Jewels & Co., Kolkata vs. ITO, Ward-33(1). Kolkata., Kolkata

In the result, the appeal of the assessee is allowed

ITA 651/KOL/2023[2010-11]Status: DisposedITAT Kolkata31 Aug 2023AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 133(6)Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 148(2)

…and therefore the AO has simply relied on the information received from the Investigation Wing and has not applied his mind. In defense of his argument relied on the decision of Hon’ble Delhi High Court in the case of CIT vs. SFIL Stock Broking Ltd. in [2010] 325 ITR 285 (Del) wherein it was held that the AO has to apply his mind to the information and independently arrived at a belief that income had escaped assessment otherwise the reopening of assessment cannot be sustained. The Ld. A.R also submitted that the reasons have to be read as recorded and there cannot be any substitution or addition or deletion to t…

Shri Arun Narula, Ferozepur vs. Assistant Commissioner of Income Tax Central Circle, Amritsar

Appeals are disposed of in the terms and observation made as above

ITA 14/ASR/2022[2014-15]Status: DisposedITAT Amritsar24 May 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 132Section 139(1)Section 143(3)Section 144Section 147Section 68Section 80C

…at he may assess or reassess such income. Thus, the reason to believe escapement of income has necessarily to be that of the AO only and not of any other authority. In <A> CIT vs. SFIL Stock Broking Ltd. (2010) 233 CTR (Del) 69: (2010) 41 DTR (Del) 98: (2010) 325 ITR 285 (Del)</A> , it has been held, inter alia, that the AO cannot reopen a completed assessment merely because he has been directed to do so by a superior officer, therefore too, the direction issued by the learned CFT(A) cannot entitle the AO to initiate proceedings under s. 147 of the Act. 16. ln view of the above, finding, the grievance of the ass…

Shri Arun Narula, Ferozepur vs. Assistant Commissioner Ofd Income Tax Central Circle, Amritsar

Appeals are disposed of in the terms and observation made as above

ITA 13/ASR/2022[2013-14]Status: DisposedITAT Amritsar24 May 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 132Section 139(1)Section 143(3)Section 144Section 147Section 68Section 80C

…at he may assess or reassess such income. Thus, the reason to believe escapement of income has necessarily to be that of the AO only and not of any other authority. In <A> CIT vs. SFIL Stock Broking Ltd. (2010) 233 CTR (Del) 69: (2010) 41 DTR (Del) 98: (2010) 325 ITR 285 (Del)</A> , it has been held, inter alia, that the AO cannot reopen a completed assessment merely because he has been directed to do so by a superior officer, therefore too, the direction issued by the learned CFT(A) cannot entitle the AO to initiate proceedings under s. 147 of the Act. 16. ln view of the above, finding, the grievance of the ass…

Shri Arun Narula, Frozepur vs. Assistant Commissioner of Income Tax Central Circle, Amritsar

Appeals are disposed of in the terms and observation made as above

ITA 12/ASR/2022[2012-13]Status: DisposedITAT Amritsar24 May 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 132Section 139(1)Section 143(3)Section 144Section 147Section 68Section 80C

…at he may assess or reassess such income. Thus, the reason to believe escapement of income has necessarily to be that of the AO only and not of any other authority. In <A> CIT vs. SFIL Stock Broking Ltd. (2010) 233 CTR (Del) 69: (2010) 41 DTR (Del) 98: (2010) 325 ITR 285 (Del)</A> , it has been held, inter alia, that the AO cannot reopen a completed assessment merely because he has been directed to do so by a superior officer, therefore too, the direction issued by the learned CFT(A) cannot entitle the AO to initiate proceedings under s. 147 of the Act. 16. ln view of the above, finding, the grievance of the ass…

Mes. Pallavi Mayur Gandhi, Mumbai vs. ITO - 33(2)(5), Mumbai

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

ITA 2251/MUM/2022[2011-12]Status: DisposedITAT Mumbai19 Apr 2023AY 2011-12

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 148Section 68

…of income. Accordingly he submitted that the reopening of the assessment is bad in law. In support of his contention learned AR placed reliance on following case laws : • PCIT Vs. Shodiman Investments (P) Ltd. (422 ITR 337) • CIT Vs. Sfil Stock Broking Ltd. (325 ITR 285) • Inventors Industrial Corporation Ltd. Vs. CIT (194 ITR 548) • Coronation Agro Industries Ltd. Vs. DCIT (390 ITR 464) 4 Mrs. Pallavi Mayur Gandhi 7. The learned AR then advanced his arguments on merits. He submitted that the assessee has sold 1.20 lakhs shares for a consideration of Rs. 5.45 crores and earned long term capital gains of Rs. 5.…

Assistant Commissioner of Income Tax, Cir.1(1)(1), Surat vs. Enviro Control Pvt. Ltd., Surat

In the result, all the grounds of appeal raised by the revenue are dismissed

ITA 345/SRT/2022[2011-12]Status: DisposedITAT Surat05 Apr 2023AY 2011-12

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Hearing) A.C.I.T., Enviro Control Pvt. Ltd., Circle-1(1)(1), Enviro House, Opp. Bank Of Vs. Surat. Maharashtra, Ghod Dod Road, Surat-395007. Pan No. Aaace 8700 C Appellant/ Assessee Respondent/ Revenue

Section 143(2)Section 143(3)Section 148Section 254(1)

…, the assessee relied upon the decision of Hon'ble Supreme Court in Andaman Timber Industries Vs CCE (2015) 62 taxmann.com 3 (SC) and Dhakeswari Cotton Mills Ltd. Vs CIT (1954) 26 ITR 775 (SC), Hon'ble Delhi High Court in CIT Vs SFIL Stock Broking Ltd. (2010) 325 ITR 285 (Del), Hon'ble Gujarat High Court in Harikishan Sunderlal Virmani Vs DCIT (2017) 88 taxmann.com 548 (Guj). The assessee it is without prejudice contention, submitted that in various decisions by the Higher Courts, it has been held that addition for bogus purchases should be restricted to certain percentage of profit in alleged bogus purchases and…

Assistant Commissioner of Income Tax, Central Circle-1, Guwahati vs. Abci Infrastructures Private Limited, Kolkata

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

ITA 1/GTY/2023[2013-14]Status: HeardITAT Guwahati03 Apr 2023AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

For Appellant: (1) That on the facts and in the circumstances of the case

Section 143(3)Section 147Section 148Section 153Section 153C

…m different Hon’ble High Courts. We may make a reference of the Hon’ble Delhi High Court decisions in the case of CIT –vs.- SFIL Stock 31 Assessment Year: 2013-2014 & Assessment Year: 2013-2014 ABCI Infrastructure Pvt. Limited Broking Limited reported in 325 ITR 285 (Del.), Pr. CIT – vs.- G And G Pharma India Limited reported in 384 ITR 147 (Del.). We do not deem it necessary to recite and recapitulate the proposition laid down in all these decisions but suffix to make an observation that common emphasis in all these decisions is to the effect that reasons for the formation of belief must have a rational con…

Abci Infrastructures Private Limited, Kolkata vs. Assistant Commissioner of Income Tax, Central Circle-1, Guwahati

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

ITA 40/GTY/2022[2013-14]Status: HeardITAT Guwahati03 Apr 2023AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

For Appellant: (1) That on the facts and in the circumstances of the case

Section 143(3)Section 147Section 148Section 153Section 153C

…m different Hon’ble High Courts. We may make a reference of the Hon’ble Delhi High Court decisions in the case of CIT –vs.- SFIL Stock 31 Assessment Year: 2013-2014 & Assessment Year: 2013-2014 ABCI Infrastructure Pvt. Limited Broking Limited reported in 325 ITR 285 (Del.), Pr. CIT – vs.- G And G Pharma India Limited reported in 384 ITR 147 (Del.). We do not deem it necessary to recite and recapitulate the proposition laid down in all these decisions but suffix to make an observation that common emphasis in all these decisions is to the effect that reasons for the formation of belief must have a rational con…

Deepak Jain, C-Scheme vs. ITO Ward 2(1), Bhagwan Das Road

In the result, appeal of the assessee is allowed

ITA 196/JPR/2021[2013-14]Status: DisposedITAT Jaipur23 Mar 2023AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Smt Monisha Chaudhary (Addl. CIT) a

Section 132Section 142(1)Section 143(2)Section 143(3)Section 148Section 44ASection 68

…hat, in the below mentioned judicial pronouncements, Hon’ble Delhi High Court has held that Information received from the Investigation Wing cannot per se be considered to be a tangible material for warranting reopening:- 1.11.i SFIL Stock Broking Ltd. [2010] 325 ITR 285 (Delhi) 1.11.ii Insecticides (India) Ltd. [2013] 357 ITR 330 (Delhi) 1.11.iii Krown Agro Foods (P.) Ltd. [2015] 375 ITR 460 (Delhi) 1.12. Thus, what was required and expected, as per the settled principles of reopening, was corroboration, checking and cross checking of the information, received from the Investigation Wing, with independent eviden…

Shri Madho Lal Saini, Jaipur vs. ITO, Ward-2(3), Jaipur

In the result, the appeals of the assessees are allowed

ITA 238/JPR/2020[2007-08]Status: DisposedITAT Jaipur06 Mar 2023AY 2007-08

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

For Appellant: Shri Rajeev Sogani (CA) &For Respondent: Shri S. Najmi (CIT)

Section 139(1)Section 147Section 148Section 151Section 250Section 54BSection 54FSection 69

…formation received from the Investigation Wing, as the same cannot be considered as a tangible material, warranting reopening, reliance is placed on the following judicial pronouncements- Shri Madho Lal Saini and Others. 1.6.1. SFIL Stock Broking Ltd. [2010] 325 ITR 285 (Delhi) 1.6.2. Insecticides (India) Ltd. [2013] 357 ITR 330 (Delhi) 1.6.3. Krown Agro Foods (P.) Ltd. [2015] 375 ITR 460 (Delhi) 1.6.4. RMG Polyvinyl (I)B Ltd. [2017] 83 taxmann.com 348 (Delhi) 1.6.5. Meenakshi Overseas Pvt. Ltd. [2017] 395 ITR 677 (Delhi) 1.7. In the case of Manzil Dinesh Kumar Shah [2018] 406 ITR 326 (Gujarat), the High Court,…

Manish Parasrampuria, Kolkata vs. A.O., NFAC / D.C.I.T., Circle-43, Kolkata

In the result, appeal of the assessee is partly allowed

ITA 654/KOL/2022[2015-2016]Status: DisposedITAT Kolkata23 Feb 2023AY 2015-2016

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2015-16

For Appellant: Shri Siddarth Agarwal, AdvocateFor Respondent: Smt. Ranu Biswas, Addl. CIT, DR

Section 10(38)Section 111ASection 142(1)Section 143(3)Section 144BSection 147Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH KOLKATA BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2015-16 Manish Parasrampuria A.O. NFAC/DCIT, Circle-43, C/o, Bhandari B. C. & Co. Kolkata. 1/1A, BiplabiAnukul Chandra Vs. Street, Princep Street, Kolkata-700072. (PAN: AFXPP4472M) (Appellant) (Respondent) Present for: Appellant by : Shri Siddarth Agarwal, Advocate Respondent by : Smt. Ranu Biswas, Addl. CIT, DR Date of Hearing : 10.01.2023 Date of Pronouncement : 23.02.2023 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee i…

DCIT 13(1)(2), Mumbai vs. Pebble Bay Developers P.Ltd, Mumbai

In the result, appeal of the In the result, appeal of the Revenue is allowed for statistical purposes, is allowed for statistical purposes, whereas the application of the assessee under rule 27 is ...

ITA 5744/MUM/2017[2008-09]Status: DisposedITAT Mumbai21 Oct 2022AY 2008-09

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2008-09 Dy. Commissioner Of Income- M/S Pebble Bay Developers Tax-13(1)(2), Pvt. Ltd., 2Nd Floor, Room No. 218, Vs. Raheja Chambers, Linking Aayakar Bhavan, M.K. Road, Road, Main Avenue Santacruz Mumbai-400020. (West), Mumbai-400054. Pan No. Aaccg 1645 E Appellant Respondent Revenue By : Ms. Vranda Matkari, Dr Assessee By : Mr. Nishit Gandhi, Ar Date Of Hearing : 26/08/2022 Date Of Pronouncement : 21/10/2022

For Appellant: Mr. Nishit Gandhi, ARFor Respondent: Ms. Vranda Matkari, DR

Section 143(1)Section 148Section 69C

…come has escaped assessment can be stated to have escaped assessment can be stated to have been formed based on such reasons as recorded." been formed based on such reasons as recorded." CIT w/s SFIL Stock Broking Lid. CIT w/s SFIL Stock Broking Lid. - (2010)325 ITR 285(Del) (2010)325 ITR 285(Del) M/s Pebble Bay Developers Pvt. Ltd. M/s Pebble Bay Developers Pvt. Ltd. 27 Held dismissing the appeal of the Dept. as follows at para 10.: Held dismissing the appeal of the Dept. as follows at para 10.: Held dismissing the appeal of the Dept. as follows at para 10.: ". From the above, it is clear that the A0 referred…

M/S. Raj Metal Co., Delhi vs. ITO, New Delhi

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

ITA 639/DEL/2017[2007-08]Status: DisposedITAT Delhi17 Oct 2022AY 2007-08

Bench: Shri N.K. Billaiya

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 147Section 148Section 153ASection 69C

…01. The facts indicated above do not show that SS Ltd. is a non-existing and a fictitious entity/person. For the reasons stated above, writ of certiorari is issued quashing the proceedings under s. 148” 12. In the case of CIT vs. SFIL Stockbroking Co. (2010) 325 ITR 285 (Del) also the Hon’ble High Court has quashed the reopening proceedings on the ground that from the reasons it is not discernible as to whether the Assessing Officer has applied his mind to the information and independently arrived at a belief that income has escaped assessment. The Hon’ble Court has held as under:- “The first sentence of the so…

CIT v. SFIL Stock Broking Ltd.

What is CIT v. SFIL Stock Broking Ltd. authority for?

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

Judgments citing CIT v. SFIL Stock Broking Ltd.

Ujjala Suppliers Pvt. Ltd., Darjeeling vs. ITO, Ward-2(1), Siliguri

Ujjala Suppliers (P) Ltd., Darjeeling vs. ITO, WD-2(1), Siliguri, Matigara

Assistant Commissioner of Income Tax, Circle-1, Guwahati vs. Bath and Sanitary, Guwahati

Shark Packaging (India) Private Limited, Delhi vs. ITO, Ward-23(1), New Delhi

Shark Packaging (India) Pvt Ltd, New Delhi vs. ITO Ward - 23(1), New Delhi

Shark Packaging (India) Pvt Ltd, New Delhi vs. ITO Ward - 23(1), New Delhi

Kailash Chand Yadav, 100, Kalu Baba Ki Dhani, Sheoshinghpur, Akoda, Phulera-303338 vs. Income Tax Officer, Ward - 1(2), Jaipur

M/S. Saraff Jewels & Co., Kolkata vs. ITO, Ward-33(1). Kolkata., Kolkata

Shri Arun Narula, Ferozepur vs. Assistant Commissioner of Income Tax Central Circle, Amritsar

Shri Arun Narula, Ferozepur vs. Assistant Commissioner Ofd Income Tax Central Circle, Amritsar

Shri Arun Narula, Frozepur vs. Assistant Commissioner of Income Tax Central Circle, Amritsar

Mes. Pallavi Mayur Gandhi, Mumbai vs. ITO - 33(2)(5), Mumbai

Assistant Commissioner of Income Tax, Cir.1(1)(1), Surat vs. Enviro Control Pvt. Ltd., Surat

Assistant Commissioner of Income Tax, Central Circle-1, Guwahati vs. Abci Infrastructures Private Limited, Kolkata

Abci Infrastructures Private Limited, Kolkata vs. Assistant Commissioner of Income Tax, Central Circle-1, Guwahati

Deepak Jain, C-Scheme vs. ITO Ward 2(1), Bhagwan Das Road

Shri Madho Lal Saini, Jaipur vs. ITO, Ward-2(3), Jaipur

Manish Parasrampuria, Kolkata vs. A.O., NFAC / D.C.I.T., Circle-43, Kolkata

DCIT 13(1)(2), Mumbai vs. Pebble Bay Developers P.Ltd, Mumbai

M/S. Raj Metal Co., Delhi vs. ITO, New Delhi