How many judgments cite CIT v. Shri Ram Singh?

180 judgments on BharatTax cite CIT v. Shri Ram Singh (306 ITR 343), spanning 2012 to 2026.

Which sections of the Income Tax Act does CIT v. Shri Ram Singh come up under?

It is most often cited in judgments turning on Section 148, Section 147, Section 143(3), Section 142(1), Section 68, Section 139(1).

CIT v. Shri Ram Singh

306 ITR 343High Court2008#534 most cited

What is CIT v. Shri Ram Singh authority for?

The Assessing Officer cannot assess or reassess any other income under Section 147 if the original grounds for issuing the Section 148 notice are not sustained. Jurisdiction to add other income discovered during reassessment proceedings arises only if the income for which the notice was initially issued is successfully assessed or reassessed.

180

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Shri Ram Singh · 306 ITR 343 · Section 147 · Section 148 · reassessment jurisdiction · original grounds not sustained · income escaping assessment · scope of reassessment · Jet Airways principle · Explanation 3 Section 147

Also reported as

174 Taxmann 438217 CTR 3458 DTR 118

Sections most often in play

Section 148 Section 147 Section 143(3)Section 142(1)Section 68 Section 139(1)Section 144B Section 234B

Issues it is cited on

section 147(1)section 13(1)(c)(ii)section 148(2)section 32(1)(iia)clarificatory amendment section 140 income escaping assessment kelvinator fresh tangible material section 234d reason to believe additional depreciation

Judgments citing CIT v. Shri Ram Singh

M/S. Bansiwala Iron & Steel Rolling Mills, Jaipur vs. DCIT, Circle-3, Jaipur

In the result, this appeal of the assessee is allowed

ITA 1388/JPR/2019[2008-09]Status: DisposedITAT Jaipur15 Sept 2021AY 2008-09

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1388/Jp/2019 Fu/Kzkj.K O"Kz@Assessment Year :2008-09 Cuke M/S Bansiwala Iron & Steel Rolling Mills, D.C.I.T., 2Nd Floor, Somani Building, S.C. Link Vs. Circle-3, Road, Loha Mandi, Jaipur. Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Aadfb 2375 A Appellant Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Mahendra Gargieya & Shri Dewang Gargieya (Advs) Jktlo Dh Vksj Ls@ Revenue By: Shri Rajendra Singh (Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 06/09/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 15/09/2021 Vkns'K@ Order

For Appellant: Shri Mahendra Gargieya &For Respondent: Shri Rajendra Singh (CIT-DR)

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 234ASection 69

…other alleged escaped income could be considered. In other words, existence of the escaped income in the reasons, is sin quo non for valid jurisdiction to consider a new item of income not stated in the reasons. 5.1 In CIT v/s Shri Ram Singh (2008) 8 DTR 118/306 ITR 343(Raj HC) (DPB 39-47), which was based on the law prior to the availability of Explanation 3, it was held: “Reassessment - Scope - Addition in respect of items other than the one on which notice is given -It is only when, in proceedings u/s 147 the AO assesses or reassesses any income chargeable to tax, which has escaped assessment for any assessm…

J.D. Sons Steel Pvt. Ltd., Faridabad vs. ACIT, Faridabad

In the result, the appeal of the assessee is allowed

ITA 1061/DEL/2015[2009-10]Status: DisposedITAT Delhi31 Aug 2021AY 2009-10

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri Rajesh Jain, CAFor Respondent: Shri Umesh Takiyar, Sr.D.R

Section 139Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 148(1)Section 148(2)Section 68

…g the F.Y. 2006-0?. Tne quantum of entries i.e. 50 Lacs has been specifically mentioned and thus to this extent the appellant's reliance on a judgment of Delhi High Court in the case of CIT vs. Insecticides (India) Ltd. 357 ITR 330 (Delhi), Ranbaxy Lab vs CIT 306 ITR 343 (Del) can be clearly distinguished from the case of the instant case. The reasons recorded by the AO are as below: "There is an information with the Assessing Officer received from the DIT(lnv.)-ll, New Delhi that assessed has obtained accommodation entires for Rs.50,00,000/- during the financial year 2008-09 relevant to Asstt. Year 2009-10, from…

S.A.Bhimaraja, Chennai vs. ITO, Chennai

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

ITA 3414/CHNY/2016[2008-09]Status: DisposedITAT Chennai23 Jul 2021AY 2008-09

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 3414/Chny/2016 िनधा"रण वष" / Assessment Year: 2008-09

For Appellant: Shri T. Banusekar, CAFor Respondent: Shri G. Johnson, Addl.CIT

Section 2(14)(a)

…on of the Hon’ble High Court of Madras in the case of M/s. Martech Peripherals Pvt. Ltd. vs. DCIT, [2017] 394 ITR 733. The case laws relied upon by the assessee are as under:- 1) CIT v Dr. Devendra Gupta [2008] 220 CTR 629 (Raj) 2) CIT v Shri Ram Singh [2008] 306 ITR 343 (Raj) 3) CIT v Jet Airways (I) Ltd [2011] 331 ITR 236 (Bom) 4) Ranbaxy Laboratories Ltd v CIT [2011] 336 ITR 136 (Del) 5) CIT v Mohmed Juned Dadani [2013] 355 ITR 172 6) Oriental Bank of Commerce v AdCIT [2014] 90 CCH 27 Del High Court 7) PVP Ventures Limited v ACIT [2015] 94 CCH 0147 (Chennai HC) 10. The ld.DR on the other hand strongly opposin…

Sh. Jeet Singh, Gurgaon vs. ITO, Gurgaon

In the result, appeal of the Assessee allowed

ITA 3068/DEL/2017[2008-09]Status: DisposedITAT Delhi24 Jun 2021AY 2008-09

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Mahavir Singh, C.AFor Respondent: Ms. Anima, Sr. D.R

Section 147Section 148

…s any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of proceedings. Learned counsel relied upon the case of Jet Airways (supra) and also Commissioner of Income Tax v. Shri Ram Singh (2008) 306 ITR 343 (Raj) and Commissioner 16 ITA.No.3068/Del./2017 Shri Jeet Singh, Gurgaon. of Income Tax v. Dr. Devender Gupta 174 Taxman 438 (Raj.). Reliance was also placed in the case of C.J. International Hotels Ltd. v. ITO being ITA No. 2736/Del./2006 dated 24th October, 2008. 13. Similar contention was raised before the Division Bench of Bombay High Court…

M/S Merlins, Kolkata vs. A.C.I.T., Cilcle-31, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1999/KOL/2019[2013-14]Status: DisposedITAT Kolkata23 Jun 2021AY 2013-14

Bench: Shri P.M. Jagtap(Kz)] [Through Virtual Court] I.T.A. No. 1999/Kol/2019 Assessment Year: 2013-14 M/S. Merlins......................................…………………………..................................................Appellant 22, Prince Anwar Shah Road, Kolkata – 700 033. [Pan: Aatfm 9672 P] Vs Acit, Circle – 31, Kolkata...................…………………………………………………..............Respondent Kolkata. Appearances By: Shri Rakesh Jain, Ar Appearing On Behalf Of The Assessee. Shri Jayanta Khanra, Jcit, Sr. Dr Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : May 13, 2021 Date Of Pronouncing The Order : June 23, 2021 Order

Section 143(1)Section 143(3)Section 147Section 148Section 14ASection 80H

…of those proceedings had ceased to survive. To arrive at this conclusion, Hon’ble Delhi High Court relied on the decision of Hon’ble Rajasthan High Court in the case of CIT vs Shri 4 I.T.A. No. 1999/Kol/2019 Assessment Year: 2013-14 M/S. MERLINS Ram Singh 306 ITR 343 wherein after considering the effect of Explanation 3 to Section 147 inserted with effect from 01.04.1989 by the Finance No. 2 Act, 2009 it was held as under: “... it is only when, in proceedings under section 147 the Assessing Officer, assesses or reassesses any income chargeable to tax which has escaped assessment for any assessment year, with…

Shri Vijay Kumar Agarwal, Jaipur vs. Income Tax Officer, Ward-4-2, Jaipur

In the result, this appeal of the assessee is allowed

ITA 59/JPR/2019[2011-12]Status: DisposedITAT Jaipur24 May 2021AY 2011-12

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 59/Jp/2019 Fu/Kzkj.K O"Kz@Assessment Year :2011-12 Vijay Kumar Agarwal, Cuke I.T.O., Vs. 7/58, Vidhyadhar Nagar, Ward 4(2), Jaipur. Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Advpa 6150 F Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Pravin Kr. Saraswat (Ca) Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 15/03/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 24/05/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A), Ajmer Dated 27/12/2018 For The A.Y. 2011-12 In The Matter Of Order Passed U/S 143(3) Read With Section 147 Of The Income Tax Act, 1961 (In Short, The Act), Wherein Following Grounds Have Been Taken. “1. The Learned C.I.T. (A) Has Erred For Not Considering The Issue For Validity Of Issue Notice U/S 148 Of I.T. Act, 1961, While There Was No Escapement Of Income On Part Of Assessee. The Initiation Of Proceedings Was Only On Behest Of I.T.O. Ward 3(2), Who Has Intimated To A.O. For Advancement Of Loan Rs.53,95,000/- Given By Assessee To Pooja Agarwal, While Concern A.O. Has Accepted Said Loan In Her Hands After Detailed Examination. Hence Initiation Of 2

For Appellant: Shri Pravin Kr. Saraswat (CA)For Respondent: Smt. Rooni Paul (Addl.CIT)

Section 143(3)Section 147Section 148Section 148(2)Section 151

…to the plenitude of its legislative powers to do so, the provisions of section 147(1) as they stood after the amendment of 1-4-1989 continue to hold the field” b) Hon’ble Rajasthan High Court in the case of Commissioner of Income-tax v. Shri Ram Singh [2008] 306 ITR 343 (See PB No. 35 to 41) held: “If in the course of proceedings under section 147, the Assessing Officer were to come to conclusion that any income chargeable to tax which, according to his "reason to believe", had escaped assessment for any assessment year, did not escape assessment, then the mere fact, that the Assessing Officer entertained a reas…

Smt. Sushila Chachan C/O- Shrawan Kumar Gupta, Advocate, 416, Surya Chamber Radio Market Nehru Bazar, Jaipur vs. ITO Ward-4(2), Jaipur

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

ITA 683/JPR/2019[2009-10]Status: DisposedITAT Jaipur30 Mar 2021AY 2009-10

For Appellant: Shri Shrawan Kumar Gupta (C.A.)For Respondent: Smt. Monisha Choudhary (ACIT) a

Section 133(6)Section 143(3)Section 145(3)Section 147Section 148Section 234A

…any other addition in terms of disallowance of construction expenses as well as 5 Smt. Sushila Chachan vs. ITO transfer expenses and trading addition so made by him. In support, the reliance was placed on the following decisions:- 1. CIT vs. Shri Ram Singh 306 ITR 343 (Raj. HC) 2. CIT vs. Jet Airways (I) Ltd. 331 ITR 236 (Bom. HC) 3. Ranbaxy Laboratories Ltd. vs. CIT 336 ITR 136 (Del. HC) 6. It was accordingly submitted that there is no justifiable basis for acquiring jurisdiction by the Assessing Officer by invoking the provisions of Section 148 of the Act and therefore, notice so issued and consequent pro…

Smt. Sheela Yogi, Jaipur vs. Income Tax Officer, Jaipur

In the result, ground no. 3 & 4 of the assessee’s appeal are allowed

ITA 398/JPR/2018[2010-11]Status: DisposedITAT Jaipur02 Feb 2021AY 2010-11

Bench: Him Under Rule 46A Of The Income Tax Act, 1962. 2(I) On The Facts & Circumstances Of The Case & In Law Also Ld. Lower Authorities Grossly Erred In Initiating Reassessment Proceedings U/S 147 Of The Act.

For Appellant: Sh. Vedant Agarwal (Adv.)For Respondent: Smt. Runi Pal (JCIT)

Section 131Section 133(6)Section 143(2)Section 147Section 68

…of section 147 and the decision of the Hon’ble Rajasthan High Court continues to hold the field and the relevant findings read as under: “14. The second line of precedent is reflected in a judgment of the Rajasthan High Court in CIT v. Shri Ram Singh [2008] 306 ITR 343 . The Rajasthan High Court construed the words used by Parliament in section 147 particularly the words that the Assessing Officer 'may assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings' under section 147. The Rajastha…

Indo Enterprise Pvt.Ltd, Latur vs. Pr. Commissioner of Income Tax -2, Aurangabad

In the result, appeal of the assessee is allowed

ITA 751/PUN/2019[2010-11]Status: DisposedITAT Pune11 Jan 2021AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury

For Appellant: Shri Rajan R. VoraFor Respondent: Shri Deepak Garg

Section 143(3)Section 194CSection 263Section 297Section 40A(2)Section 40A(2)(b)

…me of issuing notice u/s.148 of the Act. In answer to this, we find the Hon‟ble Jurisdictional High Court in the case of CIT Vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 ( Bom.) and the Hon‟ble Rajasthan High Court in the case of CIT Vs. Shri Ram Singh (2008) 306 ITR 343 (Raj.) has held that when no addition was made regarding the item in respect of which reasons were recorded for reopening of the assessment, the Commissioner could not exercise his jurisdiction u/s.263 of the Act in order to bring to tax other items of additions. The Hon‟ble Jurisdictional High Court vide Para 14 of the said decision has held as…

Designarch Infrastructure P.Ltd, New Delhi vs. ITO, Ward-7(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 8199/DEL/2019[2010-11]Status: DisposedITAT Delhi21 Oct 2020AY 2010-11

Bench: Sh. K. N. Charydr. B. R. R. Kumar(Through Video Conferencing) Ita No. 8199/Del/2019 : Asstt. Year : 2010-11 Designarch Infrastructure Pvt. Ltd., Vs. Income Tax Officer, L-7A(Lgf), South Extension, Part-Ii, Ward-7(1), New Delhi-110049 New Delhi-110002 (Appellant) (Respondent) Pan No. Aacfi4218C Assessee By : Sh. Raj Kumar, Ca Revenue By : Sh. Jagdish Singh, Sr. Dr Date Of Hearing: 12.10.2020 Date Of Pronouncement: 21.10.2020

For Appellant: Sh. Raj Kumar, CAFor Respondent: Sh. Jagdish Singh, Sr. DR

Section 127(1)Section 143(3)Section 147Section 148Section 151Section 68

…sess or reassess any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of proceedings. Learned counsel relied upon the case of Jet Airways (I) Ltd. (supra) and also CIT v. Shri Ram Singh[2008] 306 ITR 343 (Raj.) and CIT v. Dr. Devender Gupta [2008] 174 Taxman 438 (Raj.). Reliance was also placed in the case of C.J. International Hotels Ltd. v. ITO being IT Appeal No. 2736/Del./2006 dated 24- 10-2008. 13. Similar contention was raised before the Division Bench of Bombay High Court in the case of Jet Airways (I) Ltd. (supra). The Court referred to t…

A.C.I.T., Central Circle-4(2), Kolkata vs. Smt. Madhu Neotia, Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 2144/KOL/2019[2006-07]Status: DisposedITAT Kolkata14 Aug 2020AY 2006-07

Bench: Shri P.M. Jagtap, Hon’Ble(Kz) & Shri S. S. Godara, Hon’Ble] [Through Virtual Court]

Section 147Section 148Section 14A

…ing of assessments. Reliance in support of this contention was placed on behalf of the assessees on the decision of Hon’ble Rajasthan High 4 I.T.A. Nos. 2143 & 2144/Kol/2019 Shri Harsh Vardhan Neotia & Smt. Madhu Neotia Court in the case of Shri Ram Singh 306 ITR 346 and the decision of Hon’ble Punjab & Haryana High Court in the case of Atlas Cycle Industries 180 ITR 319. The assessee also relied on the decision of Kolkata Bench of ITAT in the case of Dipti Mehta vs ITO (ITA No. 2032/Kol/2018 dated 01.03.2019) to contend that this legal position propounded in the various judicial pronouncements was further st…

A.C.I.T., Central Circle-4(2), Kolkata vs. Shri Harsh Vardhan Neotia, Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 2143/KOL/2019[2006-07]Status: DisposedITAT Kolkata14 Aug 2020AY 2006-07

Bench: Shri P.M. Jagtap, Hon’Ble(Kz) & Shri S. S. Godara, Hon’Ble] [Through Virtual Court]

Section 147Section 148Section 14A

Shri Pappu Qureshi, Jaipur vs. Income Tax Officer, Ward-4-5, Jaipur

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

ITA 314/JPR/2019[2010-11]Status: DisposedITAT Jaipur28 Apr 2020AY 2010-11

For Appellant: Shri S.C. Jain (C.A.)For Respondent: Miss Chanchal Meena (JCIT)

Section 143(2)Section 144Section 147Section 148Section 44A

…n the A.O. was satisfied about the deposits and withdrawals in cash in the bank account there was no reason to make any further addition by application of N.P. rate. In support, reliance was placed on the following decisions:- • CIT v/s Shri Ram Singh (2008) 306 ITR 343. • Ranbaxy Laboratories Ltd v/s Commissioner of Income Tax (2011) 336 ITR 136 (Del) • CIT v/s Jet Airways India Ltd. (2011) 331 ITR 236 (Bom) • CIT v/s Adhunik Niryat Ispat Limited (2011) 63 DTR 212 (Del) 11. It was accordingly submitted that under the circumstances, the entire proceedings taken by the Assessing Officer resorting to make additio…

Sheela Foam Ltd., New Delhi vs. DCIT, Central Circle- 6, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4096/DEL/2018[2005-06]Status: DisposedITAT Delhi27 Apr 2020AY 2005-06

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am आयकर अपील सं. / Ita No.4096/Del/2018 "नधा"रण वष" / Assessment Year 2005-06 Sheela Foam Ltd., C-55, Preet Vihar, Vikas Marg, New Delhi-110092. ..........अपीलाथ"/Appellant Pan-Aaacs0189B Vs The Dcit, Central Circle-6, …………. ""यथ" / Respondent New Delhi-110016

For Appellant: Sh. Ajay Vohra, Sr.AdvFor Respondent: Sh. Saras Kumar, Sr.DR

Section 1Section 143(3)Section 147Section 148Section 68

…ny other issue though the reasons for such issue had not been included in the reasons recorded under s. 148(2). 14. The second line of precedent is reflected in a judgment of the Rajasthan High Court in CIT vs. Shri Ram Singh (2008) 217 CTR (Raj) 345 : (2008) 306 ITR 343 (Raj). The Rajasthan High Court construed the words used by Parliament in s. 147 particularly the words that the AO 'may assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings' under s. 147.The Rajasthan High Court held as…

M/S K R Construction, Mumbai vs. Pr CIT Central-3, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 7615/MUM/2019[2014-15]Status: DisposedITAT Mumbai28 Feb 2020AY 2014-15

Bench: Shri Saktijit Dey & Shri G. Manjunathak.R.Construction Vs. Principal Commissioner Of Basement, Hinal Residency Income Tax-Central-3 19Th Floor Datta Mandir Road Dahanukar Wadi Air India Building Kandivali(W) Nariman Point Mumbai-400 067 Mumbai-400 021

Section 147Section 148Section 151Section 263

…ntends do so, a fresh notice u/s 148 would be necessary, the legality of which would be tested in the event of a challenge by the assessee. A similar view has been expressed by the Hon’ble 17 K.R.Construction Rajasthan High court in case of shri. Ram Singh (306 ITR 343) and Punjab & Haryana High Court in case of Atlas Cycle Industries (180 ITR 319). The Hon’be Delhi High Court in case of Software Consultants (21 Taxmann.com 155) held that where the AO did not make any additions on issues inrespect of which reasons were recordrd for issue of notice u/s 148, a general inference is that the Ao could not have made…

Prakash Ramji Gavali, Mumbai vs. ITO 3(2), Thane

In the result, the appeal is allowed, in the terms indicated above

ITA 1087/MUM/2019[2008-09]Status: DisposedITAT Mumbai17 Dec 2019AY 2008-09

Section 143(3)Section 147Section 148Section 148(2)

…income in respect of any other issue though the reasons for such issue had not been included in the reasons recorded under section 148(2). 14. The second line of precedent is reflected in a judgment of the Rajasthan High Court in CIT v. Shri Ram Singh [2008] 306 ITR 343 . The Rajasthan High Court construed the words used by Parliament in section 147 particularly the words that the Assessing Officer 'may assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings' under section 147. The Rajastha…

Krishna Print Pack, Meerut vs. ITO, Ward-1(3), Meerut

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

ITA 5135/DEL/2018[2009-10]Status: DisposedITAT Delhi26 Sept 2019AY 2009-10

Bench: Shri R.K. Pandaassessment Year: 2009-10 Krishna Print Pack, Vs. Ito, 172, Anup Nagar, Fazalpur, Ward-1(3), Rhotak Road, Meerut. Meerut, Uttar Pradesh. Pan: Aagfk2165A (Appellant) (Respondent) Assessee By : Shri C.S. Anand, Advocate Revenue By : Shri S.L. Anuragi, Sr.Dr Date Of Hearing : 07.08.2019 Date Of Pronouncement : 26.09.2019 Order

For Appellant: Shri C.S. Anand, AdvocateFor Respondent: Shri S.L. Anuragi, Sr.DR

Section 133(6)Section 147oSection 148Section 40A(3)

…made disallowance u/s 40A(3) which was certainly not the basis for initiating the 6 proceedings u/s 147 of the Act. Therefore, such addition cannot be sustained in law. For the above proposition, he relied on the following decisions:- (i) CIT vs. Ram Singh, 306 ITR 343 (Raj); (ii) CIT vs. Jet Airways (P) Ltd., 331 ITR 236 (Bom); (iii) Ranbaxy Laboratories Ltd. vs. CIT, 336 ITR 136 (Del); and (iv) CIT vs. Adhunik Niryat Ispat Ltd., 63 DTR 212 (Del). 8. He accordingly submitted that both legally and factually the addition made by the Assessing Officer is not sustainable. 9. The ld. DR, on the other hand, heavil…

ACIT Central Circle, Salem vs. Thriveni Earthmovers Pvt. Ltd., Salem

In the result, the appeal filed by the Revenue in ITA

ITA 2283/CHNY/2018[2014-15]Status: DisposedITAT Chennai25 Sept 2019AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. M. Srinivasa Rao, IRS, CIT

Section 143(3)Section 148

…s been supported by the background which led to the insertion to Explanation 3 to section 147. Parliament must be regarded as being aware of the interpretation that was placed on the words 'and also' by the Rajasthan High Court in CIT v. Shri Ram Singh [2008] 306 ITR 343 (Raj). Parliament has not taken away the basis of that decision. While it is open to Parliament, having regard to the plenitude of its legislative powers to do so, the provisions of section 147 as they stood after the amendment of April 1, 1989, continue to hold the field." This decision of Hon’ble Bombay High Court was referred to by the Hon’ble…

ACIT Central Circle, Salem vs. Thriveni Earthmovers Pvt. Ltd., Salem

In the result, the appeal filed by the Revenue in ITA

ITA 2282/CHNY/2018[2013-14]Status: DisposedITAT Chennai25 Sept 2019AY 2013-14

For Appellant: Shri. M. Srinivasa Rao, IRS, CIT

Section 143(3)Section 148

ACIT Central Circle, Salem vs. Thriveni Earthmovers Pvt. Ltd., Salem

In the result, the appeal filed by the Revenue in ITA

ITA 2281/CHNY/2018[2012-13]Status: DisposedITAT Chennai25 Sept 2019AY 2012-13

For Appellant: Shri. M. Srinivasa Rao, IRS, CIT

Section 143(3)Section 148