CIT v. Shree Manjunathesware Packing Products

231 ITR 53Supreme Court of India1998#599 most cited

What is CIT v. Shree Manjunathesware Packing Products authority for?

The term 'record' under Section 263(1) of the Income Tax Act includes all material available to the Commissioner at the time of his examination, not merely the records that were available to the Assessing Officer when the original assessment order was passed.

163

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Shree Manjunathesware Packing Products · Section 263 · meaning of record · revisional power · material available to Commissioner · erroneous and prejudicial · inadequate enquiry · 231 ITR 53 · scope of 263(1) · examination by CIT

Sections most often in play

Section 263Section 143(3)Section 147Section 148Section 151Section 10(37)Section 142(1)Section 145A(b)

Issues it is cited on

inadequate enquirylack of enquirydoctrine of mergersection 263(1)malabar industrialrevision u/s 263non application of minderroneous and prejudicialmercantile system of accountingsection 263section 26income-tax officer

Judgments citing CIT v. Shree Manjunathesware Packing Products

MADAN MOHAN RAO PUVVADA,HYDERABAD vs. ITO., WARD-5(1), HYDERABAD

In the result, appeal of the Assessee is dismissed

ITA 1152/HYD/2024[2017-18]Status: DisposedITAT Hyderabad04 Mar 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1152/Hyd/2024 Assessment Year 2017-2018 Madan Mohan Rao The Income Tax Puvvada, Hyderabad. Officer, Ward-5(1), Vs. Pin – 500 063. Hyderabad. Pan Agjpp4754H Telangana. Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri P Murali Mohan Rao, Ca राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 11.02.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order

For Appellant: Sri P Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 147Section 263

…During the course of assessment proceedings on this issue despite the information was very well with the Assessing Officer. He has relied upon the Judgment of Hon’ble Supreme Court in the case of CIT vs. Manjunathesware Packing Products & Camphor Works [1998] 231 ITR 53 (SC) and submitted that it was held that the revisional power conferred on the Commissioner u/sec.263 is of wide amplitude. It enables the Commissioner to call for and examine the record of any proceedings under the Act and to make or cause to make such enquiry as he deems necessary in order to find out if any order passed by the Assessing Officer…

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 494/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh24 Feb 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing Products, [1998] 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous.' 5. In the present case, inquiries were certainly conducted by the Assessing Officer. It is not a case of no inquiry. The order under Section 263 itself records that the Dir…

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 488/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing Products, [1998] 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous.' 5. In the present case, inquiries were certainly conducted by the Assessing Officer. It is not a case of no inquiry. The order under Section 263 itself records that the Dir…

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 290/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing Products, [1998] 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous.' 5. In the present case, inquiries were certainly conducted by the Assessing Officer. It is not a case of no inquiry. The order under Section 263 itself records that the Dir…

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 289/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing Products, [1998] 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous.' 5. In the present case, inquiries were certainly conducted by the Assessing Officer. It is not a case of no inquiry. The order under Section 263 itself records that the Dir…

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 288/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing Products, [1998] 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous.' 5. In the present case, inquiries were certainly conducted by the Assessing Officer. It is not a case of no inquiry. The order under Section 263 itself records that the Dir…

M/S GANESH DASS HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 287/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing Products, [1998] 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous.' 5. In the present case, inquiries were certainly conducted by the Assessing Officer. It is not a case of no inquiry. The order under Section 263 itself records that the Dir…

SH. ARVAIL SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 286/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing Products, [1998] 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous.' 5. In the present case, inquiries were certainly conducted by the Assessing Officer. It is not a case of no inquiry. The order under Section 263 itself records that the Dir…

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. RUSSEL CREDIT LIMITED

ITAT/153/2025HC Calcutta20 Feb 2026

Bench: HON'BLE JUSTICE RAJARSHI BHARADWAJ,HON'BLE JUSTICE UDAY KUMAR

Section 143(3)Section 260ASection 263

…jurisprudence. Appellate forums, including the Income Tax Appellate Tribunal (ITAT), operate within the confines of the record as it stood before lower authorities. As held in CIT v. Shree Manjunatheswara Packing Products & Camphor Works reported in (1998) 231 ITR 53 (SC), a new plea altering the character of the transaction cannot be sprung at the appellate level without prior ventilation. Here, the absence of any conversion finding in the AO's assessment or PC's revision order bars the revenue from pivoting to this argument, preventing a backdoor re-characterization of the gains. 13. Even on merits, th…

JHV CONSTRUCTION CO. PVT. LTD.,KOLKATA vs. D.C.I.T., CC - 2(2), KOLKATA, KOLKATA

In the result, the appeal filed by the assessee is partly allowed but the order of the Pr

ITA 1289/KOL/2024[2014-2015]Status: DisposedITAT Kolkata09 Feb 2026AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 132Section 143(3)Section 153ASection 2(22)(e)Section 263Section 68

…ee Enterprise v. Addl. CIT [1975] 99 ITR 375 (Del) and the decision of the Hon'ble Supreme Court in the case of ITA No.: 1289/KOL/2024 Assessment Year: 2014-15 JHV Construction Co. Pvt. Ltd. CIT v. Shree Manjunathesware Packing Products & Camphor Works [1998] 231 ITR 53/96 Taxman 1 and has set aside the order of the directions. The Ld. DR relied upon the order of the Ld. Pr. CIT(Central) and requested that the same may be upheld. 8. We have considered the submissions made, gone through the facts of the case and perused the record and the order of the Ld. CIT(A). It has been held in Commissioner of Income Tax. vs.…

BHARGAB ENGINEERING WORKS,HOWRAH vs. PCIT, CENTRAL KOLKATA 2, , KOLKATA

In the result, the appeal of the assessee is dismissed

ITA 1161/KOL/2025[2018-2019]Status: DisposedITAT Kolkata28 Nov 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 133ASection 143(3)Section 147Section 148Section 263

…7-88 (Supreme Court), Rampyari Devi Saraogi v. CIT [1968] 67 ITR 84 and Smt. Tara Devi Aggarwal v. CIT [1973] 88 ITR 323 (Supreme Court), Gee Ve Enterprise v. Addl. CIT [1975] 99 ITR 375 and CIT v. Shree Manjunathesware Packing Products & Camphor Works [1998] 231 ITR 53/96 Taxman 1 (Supreme Court) and having regard to the facts and circumstances of the case and in the light of the aforesaid decision of the Hon’ble Supreme Court and the Hon’ble High Courts and considering the amendment in section 263 of the Income Tax Act w.e.f. 01.06.2015, he held that the assessment order under section 147 r.w.s. 143(3) of the A…

MANJU RAKESH JAIN,MUMBAI vs. PCIT, MUMBAI-20, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 2280/MUM/2025[2020-2021]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-2021

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2020-21 Manju Rakesh Jain, Pcit, Mumbai-20 704-A, Highland Park, Lokhanwala 418, 4Th Floor, Piramal Chambers, Vs. Complex, Andheri West, Lalbaug, Parel, Mumbai-400058. Mumbai-400012. Pan No. Aaepj 9613 N Appellant Respondent

For Appellant: Mr. Rajesh Kumar Yadav, CIT-DRFor Respondent: Mr. Rakesh Joshi, CA
Section 143(3)Section 144BSection 263Section 57

…evisional jurisdiction exercised revisional jurisdiction 12. Shree Manjunathesware Packing Products & Camphor 12. Shree Manjunathesware Packing Products & Camphor 12. Shree Manjunathesware Packing Products & Camphor Works Vs CIT [1998] 96 Taxman 1 (SC)/[1998] 231 ITR 53 Works Vs CIT [1998] 96 Taxman 1 (SC)/[1998] 231 ITR 53 Works Vs CIT [1998] 96 Taxman 1 (SC)/[1998] 231 ITR 53 (SC)/[1997] 143 CTR 406 (SC) (SC)/[1997] 143 CTR 406 (SC) Hon'ble Supreme Court held that word 'record' used in Hon'ble Supreme Court held that word 'record' used in Hon'ble Supreme Court held that word 'record' used in section 263(1) woul…

THE CITIZEN CO-OP-SOCIETY LIMITED,HYDERABAD vs. DCIT., CIRCLE-9(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

ITA 388/HYD/2025[2020-21]Status: DisposedITAT Hyderabad30 Jul 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.388/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) The Citizen Cooperative Vs. Dy.Cit Society Limited, Hyderabad Circle 9 (1) Pan:Aaaat3952F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ravi Bharadwaj, Ca राज" व "ारा/Revenue By:: Shri Narender Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 07/07/2025 घोषणा की तारीख/Pronouncement: 30/07/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Revision Order Dated 13/02/2025 Of The Learned Pr. Cit Passed U/S 263 Of The Act For The A.Y.2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Order Passed By The Learned Principal Commissioner Of Income Tax (Pcit) - Iv U/S 263 Of The Act Is Erroneous Both In Law & Facts Of The Case. 2. The Order Passed By The Learned Principal Commissioner Of Income Tax (Pcit) U/S 263 Of The Act Is Bad In Law & Need To Be Quashed.

For Appellant: Shri Ravi Bharadwaj, CAFor Respondent: : Shri Narender Kumar Naik, CIT (DR)
Section 142(1)Section 143(3)Section 263Section 80P

…cludes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing & Products Camphor Works [1998] 231 ITR 53 / 98 Taxman 1 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous. 18. It is in this context that the Supreme Court in Malabar Industrial Co. Ltd. v. Commissioner of Income Tax, [2000] 243 ITR 83 / 109 Taxman 66 (SC), had obse…

SHAH RAKESH BHIKHABHAI (HUF),AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

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

ITA 415/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad18 Jul 2025AY 2018-19

Bench: Shri T.R Senthil Kumar & Shri Narendra Prasad Sinha

For Appellant: Shri Vivek Chavda, ARFor Respondent: Shri A P Singh, CIT. DR
Section 142(1)Section 143(3)Section 80G

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD BEFORE SHRI T.R SENTHIL KUMAR, JUDICIAL MEMBER And SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER I.T.A. No.415/Ahd/2023 (Assessment Year: 2018-19) Shah Rakesh Bhikhabhai(HUF), Vs. The Principal (Through karta Shri Rakesh B Commissioner of Shah), Income Tax, Basement Harikrupa Shopping Ahmedabad-1, Centre, Ahmedabad. Nr. City Gold Cinema, Ashram Road, Ahmedabad-380006. [PAN No.AAIHS4031D] (Appellant) .. (Respondent) Appellant by : Shri Vivek Chavda, AR Respondent by: Shri A P Singh, CIT. DR Date of Hearing 28.04.2025 Date of Pronouncement 18.07.2025 O R…

ASIAN INSTITUTE OF GASTROENTEROLOGY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2020-2021 and 2021-2022 are allowed

ITA 610/HYD/2025[2021-22]Status: DisposedITAT Hyderabad11 Jul 2025AY 2021-22

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, S. VenugopalFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 14ASection 263

…cludes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing & Products Camphor Works [1998] 231 ITR 53 / 98 Taxman 1 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous. 18. It is in this context that the Supreme Court in Malabar Industrial Co. Ltd. v. Commissioner of Income Tax, [2000] 243 ITR 83 / 109 Taxman 66 (SC), had obse…

PUESH KUMAR GUPTA,DELHI vs. PR. CIT, CENTRAL-3, JHANDEWALAN, NEW DELHI

In the result, the appeal of the assessee is dismissed

ITA 945/DEL/2021[2016-17]Status: DisposedITAT Delhi20 Jun 2025AY 2016-17
For Appellant: \nNoneFor Respondent: \nSh. Sunil Kumar Yadav, CIT-DR
Section 10(38)Section 143(3)Section 263

…ompany, the same was to be considered as record for the purposes of\nexercising revisionary power u/s 263 of the Act. He referred to the decision of\nthe Hon'ble Apex Court in the case of CIT Vs. Shree Manjunathesware Packing\nProducts & Camphor Works, (1997) 231 ITR 53 (SC), which, he pointed out,\nheld that it was open to the Commissioner to take into consideration all the\nrecords available at the time of examination by him. Accordingly, he held the\nassessment order passed to be erroneous causing prejudice to the Revenue on\naccount of the Assessing Officer's failure to verify and act upon the piece of\ninfor…

HEMANT FABRICS PVT. LTD.,NEW DELHI vs. PR.CIT, PANCHKULA

The appeal of the assessee is allowed

ITA 206/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh25 Mar 2025AY 2018-19
For Appellant: \nShri Ajay Jain, C.AFor Respondent: \nShri Rohit Sharma, CIT DR
Section 133ASection 142(1)Section 143(2)Section 143(3)Section 263

…t stands at the time\nwhen the order in question was passed by the Assessing Officer but also the\nrecord as it stands at the time of examination by the Commissioner of Income-\ntax [see CIT vs. Shree Manjunathesware Packing Products and Camphor\nWorks [1998] 231 ITR 53 (SC)]. Nothing bars/prohibits the Commissioner of\nIncome-tax from collecting and relying upon new/additional material/evidence\nto show and state that the order of the Assessing Officer is erroneous.\"\nITA No.206/CHD/2023\nΑ.Υ.2018-19\n17\n16. In the light of above, if we peruse the impugned order,\nthen it would reveal that 1d. Commissioner has…

PRAVIN BABANRAO TAMBE,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-4, PUNE, PUNE

In the result, the appeal filed by the assessee is dismissed as not maintainable

ITA 692/PUN/2023[2013-14]Status: DisposedITAT Pune11 Mar 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.692/Pun/2023 िनधा"रण वष" / Assessment Year : 2013-14 Pravin Babanrao Tambe, Vs. Pcit, Pune-4. Sr. No.14, Shree Datta Colony, Akashwani, Hadapsar, Pune- 411028. Pan : Aimpt5087G Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri Ajay Kumar Keshari Date Of Hearing : 12.12.2024 Date Of Pronouncement : 11.03.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 31.03.2021 Passed By Ld. Pr.Cit, Pune- 4 [‘Ld. Pcit’] U/S 263 Of The It Act For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. Ld Cit Erred In Law & On Facts In Invoking Jurisdiction Under Section 263 & Setting Aside Assessment Order For Fresh Assessment On The Ground That Assessment Has Been Framed

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 143(2)Section 143(3)Section 148Section 263Section 48

…s vs. Add CIT 1975 CTR (Del) 61 (1975) 90 ITR 375 (Del), CIT vs. South India Shipping Corp. Ltd. (1998) 147 CTR (Mad) 433 (1996) 233 ITR 546 (Mad). CIT V. M.M. Khambhatwala (1992) 195 ITR 144 (u), CIT v. Shree Manjunathesware Packing Products & Camphor Works, 231 ITR 53. 6. In the light of the detailed discussion made hereinabove, it is evident that the Assessing Officer failed to make necessary enquiries and verifications with regard to the facts of the case on account of which the assessment order u/s 143(3) r.w.s. 147 of the Income Tax Act, 1961 dated 21/12/2018 of the Income-tax Act. 1961 is erroneous in so f…

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD vs. LYCOS INTERNET LIMITED,, HYDERABAD

In the result, appeal filed by the assessee is allowed

ITA 1550/HYD/2017[2012-13]Status: DisposedITAT Hyderabad22 Jan 2025AY 2012-13

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1550/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Asstt. Commissioner Of Vs. Lycos Internet Ltd Income Tax, Circle 16 (1) Hyderabad Hyderabad Pan:Aaacl5827B (Appellant) (Respondent) आ.अपी.सं /Ita No.1769/Hyd/2018 (िनधा"रण वष"/Assessment Year: 2012-13) Lycos Internet Ltd Vs. Asstt. Commissioner Of Hyderabad Income Tax, Circle 16 (1) Pan:Aaacl5827B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 16/12/2024 घोषणा की तारीख/Pronouncement: 22/01/2025 आदेश/Order Per Vijay Pal Raothese Are Two Appeals, One By The Department Against The Order Dated 23/06/2017 Of The Learned Cit (A) & Another By The Assessee Against The Revision Order Dated 26/02/2018 Passed

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B Bala Krishna, CIT(DR)
Section 14ASection 263

…ITA Nos 1550 and 1769 LYCOS Internet Ltd आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad Before Shri Vijay Pal Rao, Vice-President A N D Shri Madhusudan Sawdia, Accountant Member आ.अपी.सं /ITA No.1550/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Asstt. Commissioner of Vs. Lycos Internet Ltd Income Tax, Circle 16 (1) Hyderabad Hyderabad PAN:AAACL5827B (Appellant) (Respondent) आ.अपी.सं /ITA No.1769/Hyd/2018 (िनधा"रण वष"/Assessment Year: 2012-13) Lycos Internet Ltd Vs. Asstt. Commissioner of Hyderabad Income Tax, Circle 16 (1) PAN:AAACL5827B Hyderabad…

WINDOW TECHNOLOGIES PVT. LTD.,KOLKATA vs. PCIT (CENTRAL) - 2, KOLKATA, KOLKATA

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

ITA 1060/KOL/2024[2019-2020]Status: DisposedITAT Kolkata25 Sept 2024AY 2019-2020

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2019-20

For Appellant: Akkal Dudhewala, A.RFor Respondent: Subhendu Datta, CIT-DR
Section 133ASection 143(3)Section 263Section 32

…83, 87-88 (SC) affirming the Hon'ble Kerala High Court’s decision in 198 ITR 611 v.Rampyari Devi Saraogi vs. CIT [1968] 67 ITR 84 & Smt. Tara Devi Aggarwal vs. CIT [1973] 88 ITR 323 (SC) vi.CIT vs. Shree Manjunathesware Packing Products & Camphor Works [1998] 231 ITR 53/96 Taxman 1 6. In the written submissions filed before us, the assessee has submitted as under: The appellant has preferred the present appeal against the order dated 12.03.2024 passed by the Ld. Pr. Commissioner of Income -Tax ('PCIT)-2, Kolkata u/s 263 of the Income Tax Act (in short the 'Act') for AY 2019-20. 2. The sole grievance of the appe…

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