What is CIT v. SPL’s Siddhartha Ltd. authority for?

Reassessment proceedings under Section 147 are invalid if the sanction required under Section 151 is obtained mechanically, without independent application of mind by the sanctioning authority, or is based on borrowed satisfaction.

How many judgments cite CIT v. SPL’s Siddhartha Ltd.?

164 judgments on BharatTax cite CIT v. SPL’s Siddhartha Ltd. (345 ITR 223), spanning 2015 to 2026.

Which sections of the Income Tax Act does CIT v. SPL’s Siddhartha Ltd. come up under?

It is most often cited in judgments turning on Section 143(3), Section 147, Section 148, Section 151, Section 133A, Section 142(1).

CIT v. SPL’s Siddhartha Ltd. (345 ITR 223)

Amitabh Bansal, Delhi vs. ITO, Ward- 46(4), New Delhi

In the result, all the 03 appeals of the assessees are partly allowed

ITA 7804/DEL/2018[2015-16]Status: DisposedITAT Delhi11 Feb 2019AY 2015-16

Bench: Shri H.S. Sidhuay: 2015-16 Amitabh Bansal, Vs. Ito, Ward 46(4), C/O Kapil Goel, Advocate, New Delhi F-26/124, Sector-7, Rohini, Delhi (Pan: Actpb6786D) (Appellant) (Respondent) Ay: 2015-16 Anjul Bansal, Vs. Ito, Ward 46(4), C/O Kapil Goel, Advocate, New Delhi F-26/124, Sector-7, Rohini, Delhi (Pan: Allpb6364J) (Appellant) (Respondent) Ay: 2015-16 Daya Bansal, Vs. Ito, Ward 48(1), C/O Kapil Goel, Advocate, New Delhi F-26/124, Sector-7, Rohini, Delhi (Pan: Aalpb6363R) (Appellant) (Respondent) Assessee By : Sh. Kapil Goel, Adv. Revenue By : Sh. S.L. Anuragi, Sr. Dr.

For Appellant: Sh. Kapil Goel, AdvFor Respondent: Sh. S.L. Anuragi, Sr. DR

Section 10(38)Section 139Section 143(2)Section 68Section 69C

…rinciple of law that if a particular authority has been designated to perform an action on any particular issue, then it is that authority alone who should do that action. We draw support from various decision of Honorable High courts in 346 ITR 343 ( Bom) , 345 ITR 223 ( del ) and also of the Honourable supreme court Anirudhsinhji Karansinhji Jadeja v. State of Gujarat [1995] 5 SCC 302 where in hon. Supreme court held as under :- ― 13. It has been stated by Wade and Forsyth in ‘Administrative Law‘, 7th Edition at pages 358 and 359 under the heading ‘SURRENDER, ABDICATION, DICTATION‘ and sub- heading "Power in…

Anjul Bansal, Delhi vs. ITO, Ward- 46(4), New Delhi

In the result, all the 03 appeals of the assessees are partly allowed

ITA 7802/DEL/2018[2015-16]Status: DisposedITAT Delhi11 Feb 2019AY 2015-16

Bench: Shri H.S. Sidhuay: 2015-16 Amitabh Bansal, Vs. Ito, Ward 46(4), C/O Kapil Goel, Advocate, New Delhi F-26/124, Sector-7, Rohini, Delhi (Pan: Actpb6786D) (Appellant) (Respondent) Ay: 2015-16 Anjul Bansal, Vs. Ito, Ward 46(4), C/O Kapil Goel, Advocate, New Delhi F-26/124, Sector-7, Rohini, Delhi (Pan: Allpb6364J) (Appellant) (Respondent) Ay: 2015-16 Daya Bansal, Vs. Ito, Ward 48(1), C/O Kapil Goel, Advocate, New Delhi F-26/124, Sector-7, Rohini, Delhi (Pan: Aalpb6363R) (Appellant) (Respondent) Assessee By : Sh. Kapil Goel, Adv. Revenue By : Sh. S.L. Anuragi, Sr. Dr.

For Appellant: Sh. Kapil Goel, AdvFor Respondent: Sh. S.L. Anuragi, Sr. DR

Section 10(38)Section 139Section 143(2)Section 68Section 69C

…rinciple of law that if a particular authority has been designated to perform an action on any particular issue, then it is that authority alone who should do that action. We draw support from various decision of Honorable High courts in 346 ITR 343 ( Bom) , 345 ITR 223 ( del ) and also of the Honourable supreme court Anirudhsinhji Karansinhji Jadeja v. State of Gujarat [1995] 5 SCC 302 where in hon. Supreme court held as under :- ― 13. It has been stated by Wade and Forsyth in ‘Administrative Law‘, 7th Edition at pages 358 and 359 under the heading ‘SURRENDER, ABDICATION, DICTATION‘ and sub- heading "Power in…

ACIT, New Delhi vs. Sh. Suresh Kumar Gupta, New Delhi

Appeals of the assessee are allowed accordingly

ITA 4950/DEL/2015[2007-08]Status: DisposedITAT Delhi21 Dec 2018AY 2007-08

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri R.S. Singhvi, CAFor Respondent: Shri Sanjay Goel, CIT DR

Section 147Section 148Section 151(2)Section 68

…e had argued that even otherwise Section 292B of the Act precluded the assessee's objection as to the jurisdictional infirmity of the notice. This was repelled by the ITAT itself. It relied upon a Division Bench ruling in CIT v. S.P.L's Siddhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.)/17 taxmann.com 138 (Delhi). 4. The Revenue contends that the ITAT fell into error and relies upon the proviso to Section 151(1) to say that in all cases where re-assessment is proposed, the approval of the highest authorities such as the Principal Chief Commissioner, Principal Commissioner or the Commissioner, is essential…

Chaturbhai Nanubhai Dudhat, Ankleshwar vs. The Income Tax Officer, Ward-4, Bharuch

In the result, all appeals of the assesses are allowed

ITA 953/AHD/2014[2005-06]Status: DisposedITAT Surat16 Nov 2018AY 2005-06

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Piyush Chajed, ARFor Respondent: Smt.Smita Nair, Sr.DR

Section 148Section 151

…the Chief Commissioner or Commissioner. Such requirement cannot be seen as technical. Compliance of such requirement is therefore, necessary before issuance of notice under section 148 of the Act. Delhi High Court in case of CIT v. SPL's Sidhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.) 17 taxmann.com 138 (Delhi)held and observed as under :- ITA No.2677/Ahd/2013 and 8 Others 5 "Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other circumstances than those as defined. It is also established p…

Chaturbhai Nanubhai Dudhat, Ankleshwar vs. The Income Tax Officer, Ward-4, Bharuch

In the result, all appeals of the assesses are allowed

ITA 952/AHD/2014[2004-05]Status: DisposedITAT Surat16 Nov 2018AY 2004-05

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Piyush Chajed, ARFor Respondent: Smt.Smita Nair, Sr.DR

Section 148Section 151

…the Chief Commissioner or Commissioner. Such requirement cannot be seen as technical. Compliance of such requirement is therefore, necessary before issuance of notice under section 148 of the Act. Delhi High Court in case of CIT v. SPL's Sidhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.) 17 taxmann.com 138 (Delhi)held and observed as under :- ITA No.2677/Ahd/2013 and 8 Others 5 "Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other circumstances than those as defined. It is also established p…

Chandreshbhai Anandbhai Devani, Ankleshwar vs. The Dy.CIT, Bharuch Circle, Bharuch

In the result, all appeals of the assesses are allowed

ITA 951/AHD/2014[2005-06]Status: DisposedITAT Surat16 Nov 2018AY 2005-06

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Piyush Chajed, ARFor Respondent: Smt.Smita Nair, Sr.DR

Section 148Section 151

…the Chief Commissioner or Commissioner. Such requirement cannot be seen as technical. Compliance of such requirement is therefore, necessary before issuance of notice under section 148 of the Act. Delhi High Court in case of CIT v. SPL's Sidhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.) 17 taxmann.com 138 (Delhi)held and observed as under :- ITA No.2677/Ahd/2013 and 8 Others 5 "Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other circumstances than those as defined. It is also established p…

Chandreshbhai Anandbhai Devani, Ankleshwar vs. The Dy.CIT, Bharuch Circle, Bharuch

In the result, all appeals of the assesses are allowed

ITA 950/AHD/2014[2004-05]Status: DisposedITAT Surat16 Nov 2018AY 2004-05

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Piyush Chajed, ARFor Respondent: Smt.Smita Nair, Sr.DR

Section 148Section 151

…the Chief Commissioner or Commissioner. Such requirement cannot be seen as technical. Compliance of such requirement is therefore, necessary before issuance of notice under section 148 of the Act. Delhi High Court in case of CIT v. SPL's Sidhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.) 17 taxmann.com 138 (Delhi)held and observed as under :- ITA No.2677/Ahd/2013 and 8 Others 5 "Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other circumstances than those as defined. It is also established p…

Shri Himatbhai Anandbhai Devani, Ankleshwar vs. The Dy.CIT, Bharuch Circle, Bharuch

In the result, all appeals of the assesses are allowed

ITA 2872/AHD/2013[2005-06]Status: DisposedITAT Surat16 Nov 2018AY 2005-06

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Piyush Chajed, ARFor Respondent: Smt.Smita Nair, Sr.DR

Section 148Section 151

…the Chief Commissioner or Commissioner. Such requirement cannot be seen as technical. Compliance of such requirement is therefore, necessary before issuance of notice under section 148 of the Act. Delhi High Court in case of CIT v. SPL's Sidhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.) 17 taxmann.com 138 (Delhi)held and observed as under :- ITA No.2677/Ahd/2013 and 8 Others 5 "Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other circumstances than those as defined. It is also established p…

Shri Jaysukhbhai Nanubhai Dudhat, Ankleshwar vs. The Income Tax Officer, Ward-3, Bharuch

In the result, all appeals of the assesses are allowed

ITA 2871/AHD/2013[2005-06]Status: DisposedITAT Surat16 Nov 2018AY 2005-06

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Piyush Chajed, ARFor Respondent: Smt.Smita Nair, Sr.DR

Section 148Section 151

…the Chief Commissioner or Commissioner. Such requirement cannot be seen as technical. Compliance of such requirement is therefore, necessary before issuance of notice under section 148 of the Act. Delhi High Court in case of CIT v. SPL's Sidhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.) 17 taxmann.com 138 (Delhi)held and observed as under :- ITA No.2677/Ahd/2013 and 8 Others 5 "Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other circumstances than those as defined. It is also established p…

Jayagauri Chandresh Devani, Ankleshwar vs. The Income Tax Officer, Ward-4, Bharuch

In the result, all appeals of the assesses are allowed

ITA 2679/AHD/2013[2004-05]Status: DisposedITAT Surat16 Nov 2018AY 2004-05

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Piyush Chajed, ARFor Respondent: Smt.Smita Nair, Sr.DR

Section 148Section 151

…the Chief Commissioner or Commissioner. Such requirement cannot be seen as technical. Compliance of such requirement is therefore, necessary before issuance of notice under section 148 of the Act. Delhi High Court in case of CIT v. SPL's Sidhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.) 17 taxmann.com 138 (Delhi)held and observed as under :- ITA No.2677/Ahd/2013 and 8 Others 5 "Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other circumstances than those as defined. It is also established p…

Shri Himatbhai Anandbhai Devani, Ankleshwar vs. The Dy.CIT, Bharuch Cirsle, Bharuch

In the result, all appeals of the assesses are allowed

ITA 2678/AHD/2013[2004-05]Status: DisposedITAT Surat16 Nov 2018AY 2004-05

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Piyush Chajed, ARFor Respondent: Smt.Smita Nair, Sr.DR

Section 148Section 151

…the Chief Commissioner or Commissioner. Such requirement cannot be seen as technical. Compliance of such requirement is therefore, necessary before issuance of notice under section 148 of the Act. Delhi High Court in case of CIT v. SPL's Sidhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.) 17 taxmann.com 138 (Delhi)held and observed as under :- ITA No.2677/Ahd/2013 and 8 Others 5 "Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other circumstances than those as defined. It is also established p…

Shri Jaysukhbhai Nanubhai Dudhat, Ankleshwar vs. The Income Tax Officer, Ward-3, Bharuch

In the result, all appeals of the assesses are allowed

ITA 2677/AHD/2013[2004-05]Status: DisposedITAT Surat16 Nov 2018AY 2004-05

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Piyush Chajed, ARFor Respondent: Smt.Smita Nair, Sr.DR

Section 148Section 151

…the Chief Commissioner or Commissioner. Such requirement cannot be seen as technical. Compliance of such requirement is therefore, necessary before issuance of notice under section 148 of the Act. Delhi High Court in case of CIT v. SPL's Sidhartha Ltd. [2012] 345 ITR 223/204 Taxman 115 (Mag.) 17 taxmann.com 138 (Delhi)held and observed as under :- ITA No.2677/Ahd/2013 and 8 Others 5 "Thus, if authority is given expressly by affirmative words upon a defined condition, the expression of that condition excludes the doing of the Act authorised under other circumstances than those as defined. It is also established p…

Sushil Bansal, New Delhi vs. ACIT, Circle- 57(1), New Delhi

In the result, the appeal is dismissed

ITA 4441/DEL/2017[2013-14]Status: DisposedITAT Delhi23 Oct 2018AY 2013-14

Bench: : Shri Amit Shukla & Shri L.P. Sahuassessment Year: 2013-14

Section 132Section 147Section 148Section 151Section 69C

…0.07.2017 that the approval has been taken from the Pr.CIT, same is also not in consonance with the law laid down with regard to the approval to be taken for reopening. 18. Reliance is placed on the following judgements: • CIT vs. SPL’s Siddhartha Ltd. (2012) 345 ITR 223 (Del) • Yum Restaurants vs. DDIT, W.P. © 1353/2013, dt. 31.08.2017 • CIT vs. Soyuz Industrial Resources ltd. ITA 158/2015, dt. 27.02.2015 • Pr. CIT vs. N.C. Cables (2017) 391 ITR 11 (Del) Q ON MERITS On receiving the information from the investigation wing, the A.O. issued summons to the assessee and recorded his statement (PB Pg. 10-12). In re…

Smt. Tripat Kaur, New Delhi vs. ACIT, New Delhi

Accordingly, the appeal filed by the assessee is partly allowed

ITA 2835/DEL/2015[2012-13]Status: DisposedITAT Delhi09 Oct 2018AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishismt. Tripat Kaur Vs. The Assistant A-29, Friends Colony, East Commissioner Of Income New Delhi Tax Pan: Aaapk8020A Central Circle- 14 New Delhi (Appellant) (Respondent)

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Amit Jain, Sr. DR

Section 143Section 154Section 271Section 271A

…principle of law that if a particular authority has been designated to perform an action on any particular issue, then it is that authority alone who should do that action. We draw support from various decision of Honorable High courts in 346 ITR 343 ( Bom) , 345 ITR 223 ( del ) and also of the Honourable supreme court Anirudhsinhji Smt. Tripat Kaur Vs The Assistant Commissioner of Income Tax Central Circle- 14 New Delhi Page 41 of 44 Karansinhji Jadeja v. State of Gujarat [1995] 5 SCC 302 where in hon. Supreme court held as under :- ― 13. It has been stated by Wade and Forsyth in ‘Administrative Law‘, 7th Edi…

M/S. Cygnus Investment & Finance Pvt. Ltd., Kolkata vs. ACIT, Central Circle - 3(3), Kolkata

In the result, appeal of the assessee is allowed

ITA 117/KOL/2018[2008-09]Status: DisposedITAT Kolkata18 May 2018AY 2008-09

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi)

Section 143(3)Section 147Section 148Section 151(1)Section 250

…be sustained in law. [Para 7] Under similar circumstances, the Lucknow Bench of the ITAT in the case of Balbir Singh, being ITA No. 880/K/2014, dt. 13/03/2015, wherein the judgement of the Delhi High Court in the case of CIT vs. SPL’s Siddhartha Ltd. [2012] 345 ITR 223 (Delhi) wherein it has been held as follows:- It was apparent from records that the Assessing Officer had specifically sought the approval of the Commissioner only. Therefore, it could not be said that the Joint Commissioner/Additional Commissioner had granted the approval. Further, no doubt, the file was routed through Additional Commissioner.…

Adinath Metals, Mumbai vs. Income Tax Officer-31(1)(1), Mumbai

In the result, appeal of assessee is allowed for statistical purpose

ITA 6008/MUM/2017[2007-08]Status: DisposedITAT Mumbai12 Feb 2018AY 2007-08

Bench: Shri R.C.Sharma, Am M/S. Adinath Metals Vs. The Income Tax Officer Opp. Choudhary Hardware 31(1)(1), Mumbai Near Pooja Bar & Restaurant I.B.Patel Road, Goregaon (E) Mumbai-400063 Pan/Gir No. Aaffa8271N Appellant) .. Respondent) Assessee By Shri Piyush Chhajed Revenue By Ms. N. Hemalatha

Section 143Section 143(3)Section 147Section 148Section 151Section 151(1)Section 690Section 69C

…come Tax only. Therefore, there is no sanction obtained of commissioner of income tax as required by proviso to Section 151(1). Accordingly reopening was not valid. In this regard reliance was placed on the following judgements. - SPL'S Siddhartha Ltd, [2012] 345 ITR 223, Honorable High Court of Delhi . - DSJ Communication Ltd, 41 taxmann.com 151, Honorable High Court of Bombay - Vinay Enterprises, ITA No. 6441/Mum/2011, Honorable ITAT Mumbai 6. 1 have considered rival contentions and carefully gone through the orders of the authorities below. Principally, I agree with the contention of learned AR that in case,…

Dongfang Electric Corporation, Kolkata vs. DCIT, International Taxation 1(1), Kolkata

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

ITA 487/KOL/2015[2010-2011]Status: DisposedITAT Kolkata25 Oct 2017AY 2010-2011

Bench: Sri N.V. Vasudevan & Sri J. Sudhakar Reddy]

Section 143(3)

…ed by the assessee for the Assessment Year 2010-11. Reliance was placed on the following case laws:- • Strategic Credit Capital Pvt. Ltd. & Ors., Versus Ratnakar Bank Ltd. [395 ITR 391] • Amiya Bala Paul vs. CIT (2003) 6 SCC 342 • SPL’s Siddhartha Ltd [2012] 345 ITR 223 5.3. He submitted that there is no reference made by the AO to the TPO, in terms of section 92 CA of the Act, the assessment order for the Assessment Year 2009-10, was required to be passed by 31/12/ 2012, and as the assessment order was passed on 31/01/2014, the assessment is barred by limitation and that similar is the position for assessmen…

Dongfang Electric Corporation, Kolkata vs. DDIT (It)-1(1), Kolkata

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

ITA 572/KOL/2014[2009-2010]Status: DisposedITAT Kolkata25 Oct 2017AY 2009-2010

Bench: Sri N.V. Vasudevan & Sri J. Sudhakar Reddy]

Section 143(3)

…ed by the assessee for the Assessment Year 2010-11. Reliance was placed on the following case laws:- • Strategic Credit Capital Pvt. Ltd. & Ors., Versus Ratnakar Bank Ltd. [395 ITR 391] • Amiya Bala Paul vs. CIT (2003) 6 SCC 342 • SPL’s Siddhartha Ltd [2012] 345 ITR 223 5.3. He submitted that there is no reference made by the AO to the TPO, in terms of section 92 CA of the Act, the assessment order for the Assessment Year 2009-10, was required to be passed by 31/12/ 2012, and as the assessment order was passed on 31/01/2014, the assessment is barred by limitation and that similar is the position for assessmen…

ACIT 13(3)(2), Mumbai vs. Vaman International P.Ltd, Mumbai

The appeal of the assessee is partly allowed in terms of our aforesaid observations

ITA 1506/MUM/2017[2007-08]Status: DisposedITAT Mumbai27 Sept 2017AY 2007-08

Bench: Shri R.C.Sharma, Am & Shri Ravish Sood, Jm आयकर अपील सं./ I.T.A. Nos.1040 & 1041/Mum/2017 (निर्धारण वर्ा / Assessment Year: (2007-08 & 2008-09) M/S. Vaman International Pvt. Dy. Commissioner Of Ltd. 119, 1St Floor, Durian बिधम/ Income Tax-13(3)(2), Industrial Estate, Goregaon Mumbai. Vs. Mulund Link Road, Goregaon East, Mumbai-400063. स्थायीलेखासं./जीआइआरसं./ Pan/Gir No. Aabcv5464F (अपीलाथी/Appellant) (प्रत्यथी / Respondent) :

For Appellant: Shri Vijay Mehta &For Respondent: Shri Rajat Mittal, D.R

Section 143(3)Section 147Section 148

…esaid contention that the sanction of the appropriate authority before issuing the notice u/s 148 was an indispensable statutory requirement, therein relied on the judgment of the Hon’ble High Court of Delhi in the case of CIT Vs. SPL‘S Siddhartha Ltd’ (2012) 345 ITR 223 (Del). The Ld. A.R further to buttress his aforesaid contention, also placed reliance on the order of the Hon’ble High Court of Bombay in the case of DSJ Communication Ltd. Vs. DCIT, Circle 2(1) and Anr. (CWP No. 722 of 2011, dt 13.09.2012). 8. The Ld. A.R. adverting to the merits of the case submitted that both of the lower authorities had proc…

Tangent Furniture P.Ltd, Mumbai vs. DCIT 13(3)(2), Mumbai

The appeal of the assessee is partly allowed in terms of our aforesaid observations

ITA 1042/MUM/2017[2007-08]Status: DisposedITAT Mumbai27 Sept 2017AY 2007-08

Bench: Shri R.C.Sharma, Am & Shri Ravish Sood, Jm आयकर अपील सं./ I.T.A. Nos.1040 & 1041/Mum/2017 (निर्धारण वर्ा / Assessment Year: (2007-08 & 2008-09) M/S. Vaman International Pvt. Dy. Commissioner Of Ltd. 119, 1St Floor, Durian बिधम/ Income Tax-13(3)(2), Industrial Estate, Goregaon Mumbai. Vs. Mulund Link Road, Goregaon East, Mumbai-400063. स्थायीलेखासं./जीआइआरसं./ Pan/Gir No. Aabcv5464F (अपीलाथी/Appellant) (प्रत्यथी / Respondent) :

For Appellant: Shri Vijay Mehta &For Respondent: Shri Rajat Mittal, D.R

Section 143(3)Section 147Section 148

…esaid contention that the sanction of the appropriate authority before issuing the notice u/s 148 was an indispensable statutory requirement, therein relied on the judgment of the Hon’ble High Court of Delhi in the case of CIT Vs. SPL‘S Siddhartha Ltd’ (2012) 345 ITR 223 (Del). The Ld. A.R further to buttress his aforesaid contention, also placed reliance on the order of the Hon’ble High Court of Bombay in the case of DSJ Communication Ltd. Vs. DCIT, Circle 2(1) and Anr. (CWP No. 722 of 2011, dt 13.09.2012). 8. The Ld. A.R. adverting to the merits of the case submitted that both of the lower authorities had proc…

CIT v. SPL’s Siddhartha Ltd.

What is CIT v. SPL’s Siddhartha Ltd. authority for?

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

Judgments citing CIT v. SPL’s Siddhartha Ltd.

Amitabh Bansal, Delhi vs. ITO, Ward- 46(4), New Delhi

Anjul Bansal, Delhi vs. ITO, Ward- 46(4), New Delhi

ACIT, New Delhi vs. Sh. Suresh Kumar Gupta, New Delhi

Chaturbhai Nanubhai Dudhat, Ankleshwar vs. The Income Tax Officer, Ward-4, Bharuch

Chaturbhai Nanubhai Dudhat, Ankleshwar vs. The Income Tax Officer, Ward-4, Bharuch

Chandreshbhai Anandbhai Devani, Ankleshwar vs. The Dy.CIT, Bharuch Circle, Bharuch

Chandreshbhai Anandbhai Devani, Ankleshwar vs. The Dy.CIT, Bharuch Circle, Bharuch

Shri Himatbhai Anandbhai Devani, Ankleshwar vs. The Dy.CIT, Bharuch Circle, Bharuch

Shri Jaysukhbhai Nanubhai Dudhat, Ankleshwar vs. The Income Tax Officer, Ward-3, Bharuch

Jayagauri Chandresh Devani, Ankleshwar vs. The Income Tax Officer, Ward-4, Bharuch

Shri Himatbhai Anandbhai Devani, Ankleshwar vs. The Dy.CIT, Bharuch Cirsle, Bharuch

Shri Jaysukhbhai Nanubhai Dudhat, Ankleshwar vs. The Income Tax Officer, Ward-3, Bharuch

Sushil Bansal, New Delhi vs. ACIT, Circle- 57(1), New Delhi

Smt. Tripat Kaur, New Delhi vs. ACIT, New Delhi

M/S. Cygnus Investment & Finance Pvt. Ltd., Kolkata vs. ACIT, Central Circle - 3(3), Kolkata

Adinath Metals, Mumbai vs. Income Tax Officer-31(1)(1), Mumbai

Dongfang Electric Corporation, Kolkata vs. DCIT, International Taxation 1(1), Kolkata

Dongfang Electric Corporation, Kolkata vs. DDIT (It)-1(1), Kolkata

ACIT 13(3)(2), Mumbai vs. Vaman International P.Ltd, Mumbai

Tangent Furniture P.Ltd, Mumbai vs. DCIT 13(3)(2), Mumbai