CIT v. Sun Engineering Works (P) Ltd.

198 ITR 297Supreme Court of India1992#61 most cited

What is CIT v. Sun Engineering Works (P) Ltd. authority for?

A court's pronouncement derives its scope and color from the specific questions involved in the case, thus, due regard must always be given to the questions framed before the court when interpreting its judgment.

814

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2007 to 2026.

Also referred to as

CIT v. Sun Engineering Works · 198 ITR 297 · Supreme Court 1992 · judgment interpretation · scope of decision · questions framed · judicial precedent · Section 147 · reassessment · income escaping assessment

Also reported as

64 Taxmann 442107 CTR 209

Sections most often in play

Section 143(3)Section 147Section 148Section 153ASection 132Section 143(2)Section 143(1)Section 14A
Read the full judgment

Issues it is cited on

section 2(viii)section 56(viii)section 45(5)(c)section 155(16)section 23(1a)section 104section 45(5)(b)section 145b(1)section 194lakeyman insurancesection 160section 23(2)

Judgments citing CIT v. Sun Engineering Works (P) Ltd.

Deputy Commissioner of Income-Tax, Bengaluru vs. Coffee Day Enterprises Limited, Bengaluru

In the result, all the COs by assessee in CO

ITA 783/BANG/2024[2017-18]Status: DisposedITAT Bangalore23 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Sri C. Ramesh, A.RFor Respondent: Smt. S, Praveena, D.R
Section 1Section 132Section 143(3)Section 148Section 14ASection 153ASection 154Section 234B(3)Section 234D

…ch was whether in the course of reassessment of an escaped item of income an assessee could seek review in respect of an item which stood concluded in the original assessment order, the Supreme Court in the case of Sun Engineering Works Pvt. Ltd. Vs CIT (1992)198 ITR 297 has held that "the proceedings under S.147 of the Act are for the -benefit of the Revenue and not an assessee and are aimed at garnering the 'escaped income' of an assessee". ITA Nos.780 to 785/Bang/2024 & CO Nos.15 to 18/Bang/2024 M/s. Coffee Day Enterprises Ltd., Bangalore ITA Nos.786 to 791/Bang/2024 & CO Nos.19 to 23/Bang/2024 M/s. Coffee Da…

DCIT, Central Circle-1(3), Bengaluru, Bangalore vs. Coffee Day Enterprises, Bengaluru

In the result, all the COs by assessee in CO

ITA 782/BANG/2024[2016-17]Status: DisposedITAT Bangalore23 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Sri C. Ramesh, A.RFor Respondent: Smt. S, Praveena, D.R
Section 1Section 132Section 143(3)Section 148Section 14ASection 153ASection 154Section 234B(3)Section 234D

…ch was whether in the course of reassessment of an escaped item of income an assessee could seek review in respect of an item which stood concluded in the original assessment order, the Supreme Court in the case of Sun Engineering Works Pvt. Ltd. Vs CIT (1992)198 ITR 297 has held that "the proceedings under S.147 of the Act are for the -benefit of the Revenue and not an assessee and are aimed at garnering the 'escaped income' of an assessee". ITA Nos.780 to 785/Bang/2024 & CO Nos.15 to 18/Bang/2024 M/s. Coffee Day Enterprises Ltd., Bangalore ITA Nos.786 to 791/Bang/2024 & CO Nos.19 to 23/Bang/2024 M/s. Coffee Da…

Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru vs. Coffee Day Enterprises Limited, Bengaluru

ITA 781/BANG/2024[2015-16]Status: DisposedITAT Bangalore23 Jul 2024AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Sri C. Ramesh, A.R
Section 1Section 132Section 143(3)Section 148Section 14ASection 153ASection 154Section 234B(3)Section 234D

…ch was whether in the course of reassessment of an escaped item of income an assessee could seek review in respect of an item which stood concluded in the original assessment order, the Supreme Court in the case of Sun Engineering Works Pvt. Ltd. Vs CIT (1992)198 ITR 297 has held that "the proceedings under S.147 of the Act are for the -benefit of the Revenue and not an assessee and are aimed at garnering the 'escaped income' of an assessee". While interpreting the provisions of section 147, different High Courts have held differently, i.e., some have held that the second part of sectión 147 is to be read in conj…

DCIT, Central Circle-1(3), Bengaluru vs. Coffee Day Enterprises Limited, Bengaluru

ITA 780/BANG/2024[2011-12]Status: DisposedITAT Bangalore23 Jul 2024AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Sri C. Ramesh, A.R
Section 1Section 132Section 143(3)Section 148Section 14ASection 153ASection 154Section 234B(3)Section 234D

…ch was whether in the course of reassessment of an escaped item of income an assessee could seek review in respect of an item which stood concluded in the original assessment order, the Supreme Court in the case of Sun Engineering Works Pvt. Ltd. Vs CIT (1992)198 ITR 297 has held that "the proceedings under S.147 of the Act are for the -benefit of the Revenue and not an assessee and are aimed at garnering the 'escaped income' of an assessee". Page 14 of 26 While interpreting the provisions of section 147, different High Courts have held differently, i.e., some have held that the second part of sectión 147 is to b…

ITO-22(1)(6), Mumbai vs. Ahuja Tower Co Operative Housing Society Ltd., Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 1060/MUM/2024[2018-19]Status: DisposedITAT Mumbai20 Jun 2024AY 2018-19

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri Anil SatheFor Respondent: Shri Harmesh Lal, Sr. DR
Section 143Section 143(3)Section 250Section 80PSection 80P(2)(d)

…e Supreme Court. Thus, we are of the considered opinion that the reliance placed upon the aforesaid decisions by the AO is completely misplaced. In this regard, following observations of Hon’ble Supreme Court in CIT v/s Sun Engineering Private Limited, [1992] 198 ITR 297 (SC), becomes relevant: “It is neither desirable nor permissible to pick out a word or a sentence from the judgment of the Court, divorced from the context of the question under consideration and treat it to be the complete 'law' declared by the Court. The judgment must be read as a whole and the observations from the judgment have to be consider…

Income Tax Officer-22(1)(6), Mumbai vs. Ahuja Tower Co Operative Housing Society Limited, Mumbai

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

ITA 859/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Jun 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri Anil SatheFor Respondent: Shri Sunny Kachhwaha
Section 142(1)Section 143(2)Section 250Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA no.644/Mum./2024 (Assessment Year : 2020-21) Ahuja Tower Co-operative Housing Society Ltd Plot No. 1087 and 1088, Ahuja ……………. Appellant Tower Co-operative Housing Society, Rajabhau Anant Desai Marg, Prabhadevi, Maharashtra PAN – AAFAA0125L v/s Income Tax Officer-22(1)(6) Room No.108, Piramal Chamber, ……………. Respondent Lal Baug, Parel, Maharashtra-400012. ITA no.859/Mum./2024 (Assessment Year : 2020-21) Income Tax Officer-22(1)(6) Room No.108, Piramal…

Ahuja Tower Co-Operative Housing Society Limited, Mumbai vs. Jurisdiction Ward 22(1)(6), Piramal Chamber, Mumbai

ITA 644/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Jun 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri Anil SatheFor Respondent: Shri Sunny Kachhwaha
Section 142(1)Section 143(2)Section 250Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA no.644/Mum./2024 (Assessment Year : 2020-21) Ahuja Tower Co-operative Housing Society Ltd Plot No. 1087 and 1088, Ahuja Tower Co-operative Housing Society, Rajabhau Anant Desai Marg, Prabhadevi, Maharashtra PAN - AAFAA0125L Appellant Income Tax Officer-22(1)(6) Room No.108, Piramal Chamber, Lal Baug, Parel, Maharashtra-400012. Respondent v/s ITA no.859/Mum./2024 (Assessment Year : 2020-21) Income Tax Officer-22(1)(6) Room No.108, Piramal Chamber, Lal Bau…

ITO, WD.9(1), Kolkata vs. M/S Maharaj Vincom Pvt. Ltd., Kolkata

ITA 35/KOL/2021[2009-10]Status: DisposedITAT Kolkata15 May 2024AY 2009-10

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.35/Kol/2021 Assessment Year: 2009-10 Ito, Ward-9(1), Kolkata……………….......................…...……………....Appellant Vs. M/S Maharaj Vincom Pvt. Ltd……............…..........................…..…..... Respondent 69, Jamunalal Bajaj Street, Kolkata- 700007. [Pan: Aafcm6496E] C.O. No.6/Kol/2023 (A/O I.T.A. No.35/Kol/2021) Assessment Year: 2009-10 M/S Maharaj Vincom Pvt. Ltd……............…..........................…....... Cross-Objector 69, Jamunalal Bajaj Street, Kolkata- 700007. [Pan: Aafcm6496E] Vs Ito, Ward-9(1), Kolkata …………..….......................…...……………....Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Assessee. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Department. Date Of Concluding The Hearing : March 07, 2024 Date Of Pronouncing The Order : May 15, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: This Appeal By The Revenue & Corresponding Cross-Objection By The Assessee Have Been Preferred Against The Order Dated 08.09.2020 Of The Commissioner Of Income Tax (Appeals)-7, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

Section 143(1)Section 143(3)Section 147Section 250Section 263

…ment for the assessment year 1996-97 under section 143 it was found that the claim of license fee made by the assessee was erroneous and should have been disallowed. 14. The diametrically opposite position had arisen in CIT v. Sun Engg. Works (P.) Ltd. [1992] 198 ITR 297 (SC). It was held that "in the reassessment proceedings, it is not open to an assessee to seek a review of the concluded item, unconnected with the escapement of income, for the purpose of computation of the income escaping assessment; and, therefore, the Tribunal was right in holding that the respondent was not entitled to reagitate the question…

M/S. Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Ltd), Mumbai vs. Dy Comm of Income Tax- Central Circle-7(2), Mumbai

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 320/MUM/2023[2012-13]Status: DisposedITAT Mumbai05 Apr 2024AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

For Appellant: Shri S. S. Nagar & Shri BFor Respondent: Dr. Mahesh Akhade (DR)
Section 132Section 143(2)Section 153A

…tertained by the Assessing Officer in the absence of the same finding a place either in return of income or in the revised return of income. It is further submitted that in view of the decision of the Apex Court in CIT v. Sun Engineering Works (P.) Ltd.[1992] 198 ITR 297/64 Taxman 442 a re-assessment consequent to re-opening of the assessment cannot lead to reduction of income which had been originally assessed to tax. In the above view, it is submitted that the impugned order of the Tribunal is not justified and admission of the appeal is warranted. …… 10. The reliance on the decision of the Apex Court in Sun En…

DCIT, CC-7(2), Mumbai vs. M/S. Patanjali Foods Ltd., ( Formerly Known As Ruchi Soya Industries Ltd, Mumbai

In the result, the appeal and cross objections of the assessee are

ITA 1176/MUM/2023[2012-13]Status: DisposedITAT Mumbai05 Apr 2024AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2012-13) Dcit, Central Circle-7(2) Room No. 637, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020. बनाम / M/S. Patanjali Foods Ltd Vs. (Formerly Known As Ruchi Soya Industries Ltd) 616, Tulsiani Chambers, Nariman Point, Mumbai- 400021. Cross Objection No.51/Mum/2023 (Arising Out Of I.T. A. No. 1172/Mum/2023) (निर्धारण वर्ष / Assessment Year: 2010-11) M/S. Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Ltd) 616, Tulsiani Chambers, Nariman Point, Mumbai- 400021. बनाम / Dcit, Central Circle-7(2) Vs. Room No. 637, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020. & आयकर अपील सं/ I.T. A. No. 320/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2012-13) M/S. Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Ltd) बनाम / Vs. Dcit, Central Circle-7(2) Room No. 637, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020. 616, Tulsiani Chambers, Nariman Point, Mumbai- 400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaci1220M 2

For Appellant: Shri S. S. Nagar & Shri BFor Respondent: Dr. Mahesh Akhade (DR)
Section 132Section 143(2)Section 153A

…tertained by the Assessing Officer in the absence of the same finding a place either in return of income or in the revised return of income. It is further submitted that in view of the decision of the Apex Court in CIT v. Sun Engineering Works (P.) Ltd.[1992] 198 ITR 297/64 Taxman 442 a re-assessment consequent to re-opening of the assessment cannot lead to reduction of income which had been originally assessed to tax. In the above view, it is submitted that the impugned order of the Tribunal is not justified and admission of the appeal is warranted. 10. The reliance on the decision of the Apex Court in Sun Engin…

DCIT, CC-7(2), Mumbai vs. M/S. Patanjali Foods Ltd., ( Formerly Known As Ruchi Soya Industries Ltd, Mumbai

ITA 1175/MUM/2023[2012-13]Status: DisposedITAT Mumbai05 Apr 2024AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2012-13) Dcit, Central Circle-7(2) Room No. 637, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020. बनाम / M/S. Patanjali Foods Ltd Vs. (Formerly Known As Ruchi Soya Industries Ltd) 616, Tulsiani Chambers, Nariman Point, Mumbai- 400021. Cross Objection No.51/Mum/2023 (Arising Out Of I.T. A. No. 1172/Mum/2023) (निर्धारण वर्ष / Assessment Year: 2010-11) M/S. Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Ltd) 616, Tulsiani Chambers, Nariman Point, Mumbai- 400021. बनाम / Dcit, Central Circle-7(2) Vs. Room No. 637, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020. & आयकर अपील सं/ I.T. A. No. 320/Mum/2023 (निर्धारण वर्ष / Assessment Year: 2012-13) M/S. Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Ltd) बनाम / Vs. Dcit, Central Circle-7(2) Room No. 637, 6Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020. 616, Tulsiani Chambers, Nariman Point, Mumbai- 400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaci1220M 2

For Appellant: Shri S. S. Nagar & Shri BFor Respondent: Dr. Mahesh Akhade (DR)
Section 132Section 143(2)Section 153A

…tertained by the Assessing Officer in the absence of the same finding a place either in return of income or in the revised return of income. It is further submitted that in view of the decision of the Apex Court in CIT v. Sun Engineering Works (P.) Ltd.[1992] 198 ITR 297/64 Taxman 442 a re-assessment consequent to re-opening of the assessment cannot lead to reduction of income which had been originally assessed to tax. In the above view, it is submitted that the impugned order of the Tribunal is not justified and admission of the appeal is warranted. 10. The reliance on the decision of the Apex Court in Sun Engin…

DCIT, CC-7(2), Mumbai vs. M/S. Patanjali Foods Ltd., ( Formerly Known As Ruchi Soya Industries Ltd, Mumbai

In the result, the appeal and cross objections of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 1172/MUM/2023[2010-11]Status: DisposedITAT Mumbai05 Apr 2024AY 2010-11

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T. A. No. 1172/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2010-11) & आयकर अपील सं/ I.T. A. No. 1175/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) & आयकर अपील सं/ I.T. A. No. 1176/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13)

For Appellant: Shri S. S. Nagar & Shri BFor Respondent: Dr. Mahesh Akhade (DR)
Section 132Section 143(2)Section 153A

…tertained by the Assessing Officer in the absence of the same finding a place either in return of income or in the revised return of income. It is further submitted that in view of the decision of the Apex Court in CIT v. Sun Engineering Works (P.) Ltd.[1992] 198 ITR 297/64 Taxman 442 a re-assessment consequent to re-opening of the assessment cannot lead to reduction of income which had been originally assessed to tax. In the above view, it is submitted that the impugned order of the Tribunal is not justified and admission of the appeal is warranted. …… 10. The reliance on the decision of the Apex Court in Sun En…

Jaswant Singh Yadav, Gurugram vs. ITO, Ward 2(2), Gurgaon

In the result, the appeal of the assessee in ITA No

ITA 1973/DEL/2021[2010-11]Status: DisposedITAT Delhi03 Apr 2024AY 2010-11

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Sanjay Agarwal, CAFor Respondent: Ms. Sapna Bhatia, CIT- DR
Section 143(3)Section 147Section 148Section 263

…der section 147." 12. The Division Bench in Ranbaxy Laboratories Limited (supra)considered the judgment of the Supreme Court in the case of V. Jagmohan Rao versus CIT and EPT, (1970) 75 ITR 373(SC) and CIT versus Sun Engineering Works Private Limited, (1992) 198 ITR 297 (SC) and has then elucidated: "18. We are in complete agreement with the reasoning of the Division Bench of the Bombay High Court in the case of CIT v. Jet Airways (I) Limited [2011] 331 ITR 236 (Bom). We may also note that the heading of section 147 is "income escaping assessment" and that of section 148 "issue of notice where income escaped as…

Chiripal Industries Limited, Ahmedabad vs. The Dy.CIT., Circle-1(1)(2), Ahmedabad

In the result, the appeal of the assessee is partly allowed for the statistical purposes

ITA 708/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad02 Apr 2024AY 2014-15

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita No. 708/Ahd/2023 धििाधरणवरध/Asstt. Year: 2014-2015 Chirpal Industries Limited, D.C.I.T, Chirpal House, Vs. Circle-1(1)(2), Shivranjani Cross Road, Ahmedabad. Satellight, Ahmedabad-380015. Pan: Aaacc8513B

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Ankit Jain, Sr.DR
Section 116JSection 143(3)Section 148Section 80Section 80I

…case on hand. 13. On the other hand, the ld. DR before us opposed to admit the additional ground of appeal raised by the assessee in the light of the ratio of the judgment of Hon’ble Supreme Court in the case of CIT v. Sun Engineering Works (P.) Ltd. [1992] 198 ITR 297 (SC) 14. We have heard the rival contentions of both the parties and perused the materials available on record. At the outset, we note that the issue raised by the assessee in the additional ground of appeal is identical to the issue in the case of M/s Jindal worldwide limited cited above where in the ITAT has observed as under: 11. We shall now…

ACIT, Central Circle-1(1), Hyderabad vs. Ncc Limited, Hyderabad

Accordingly, we delete the same. Thus, this ground is partly allowed

ITA 80/HYD/2017[2011-12]Status: DisposedITAT Hyderabad31 Jan 2024AY 2011-12

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

For Appellant: Shri Vijay Mehta, CA &For Respondent: Shri K. Madhusudan, CIT(DR)
Section 143(1)

…ich are later years to AY 2008-09. (c) Further, each assessment is separate as per the ROI filed under 153A, therefore, no fresh deduction/set off can be given in at this stage. Reliance is placed on SC decisions in the case of M/s. Sun Engineering works Ltd. 198 ITR 297 (SC). 24. We have heard the rival contention of the parties and perused the material available on record and the judgements cited by the respective parties. In the present case, search and seizure action was carried out in the residential premises of one Shri Mukhesh Sharma in July, 2008. During the course of search, certain documents were found…

ACIT, Central Circle-1(1), Hyderabad vs. Ncc Limited, Hyderabad

Accordingly, we delete the same. Thus, this ground is partly allowed

ITA 79/HYD/2017[2010-11]Status: DisposedITAT Hyderabad31 Jan 2024AY 2010-11

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

For Appellant: Shri Vijay Mehta, CA &For Respondent: Shri K. Madhusudan, CIT(DR)
Section 143(1)

…ich are later years to AY 2008-09. (c) Further, each assessment is separate as per the ROI filed under 153A, therefore, no fresh deduction/set off can be given in at this stage. Reliance is placed on SC decisions in the case of M/s. Sun Engineering works Ltd. 198 ITR 297 (SC). 24. We have heard the rival contention of the parties and perused the material available on record and the judgements cited by the respective parties. In the present case, search and seizure action was carried out in the residential premises of one Shri Mukhesh Sharma in July, 2008. During the course of search, certain documents were found…

ACIT, Central Circle-1(1), Hyderabad vs. Ncc Limited, Hyderabad

Accordingly, we delete the same. Thus, this ground is partly allowed

ITA 78/HYD/2017[2009-10]Status: DisposedITAT Hyderabad31 Jan 2024AY 2009-10

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

For Appellant: Shri Vijay Mehta, CA &For Respondent: Shri K. Madhusudan, CIT(DR)
Section 143(1)

…ich are later years to AY 2008-09. (c) Further, each assessment is separate as per the ROI filed under 153A, therefore, no fresh deduction/set off can be given in at this stage. Reliance is placed on SC decisions in the case of M/s. Sun Engineering works Ltd. 198 ITR 297 (SC). 24. We have heard the rival contention of the parties and perused the material available on record and the judgements cited by the respective parties. In the present case, search and seizure action was carried out in the residential premises of one Shri Mukhesh Sharma in July, 2008. During the course of search, certain documents were found…

ACIT, Central Circle-1(1), Hyderabad vs. Ncc Limited, Hyderabad

Accordingly, we delete the same. Thus, this ground is partly allowed

ITA 77/HYD/2017[2008-09]Status: DisposedITAT Hyderabad31 Jan 2024AY 2008-09

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

For Appellant: Shri Vijay Mehta, CA &For Respondent: Shri K. Madhusudan, CIT(DR)
Section 143(1)

…ich are later years to AY 2008-09. (c) Further, each assessment is separate as per the ROI filed under 153A, therefore, no fresh deduction/set off can be given in at this stage. Reliance is placed on SC decisions in the case of M/s. Sun Engineering works Ltd. 198 ITR 297 (SC). 24. We have heard the rival contention of the parties and perused the material available on record and the judgements cited by the respective parties. In the present case, search and seizure action was carried out in the residential premises of one Shri Mukhesh Sharma in July, 2008. During the course of search, certain documents were found…

Ncc Limited, Hyderabad vs. DCIT, Central Circle-1(1), Hyderabad

Accordingly, we delete the same. Thus, this ground is partly allowed

ITA 75/HYD/2017[2010-11]Status: DisposedITAT Hyderabad31 Jan 2024AY 2010-11

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

For Appellant: Shri Vijay Mehta, CA &For Respondent: Shri K. Madhusudan, CIT(DR)
Section 143(1)

…ich are later years to AY 2008-09. (c) Further, each assessment is separate as per the ROI filed under 153A, therefore, no fresh deduction/set off can be given in at this stage. Reliance is placed on SC decisions in the case of M/s. Sun Engineering works Ltd. 198 ITR 297 (SC). 24. We have heard the rival contention of the parties and perused the material available on record and the judgements cited by the respective parties. In the present case, search and seizure action was carried out in the residential premises of one Shri Mukhesh Sharma in July, 2008. During the course of search, certain documents were found…

Ncc Limited, Hyderabad vs. DCIT, Central Circle-1(1), Hyderabad

Accordingly, we delete the same. Thus, this ground is partly allowed

ITA 74/HYD/2017[2009-10]Status: DisposedITAT Hyderabad31 Jan 2024AY 2009-10

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

For Appellant: Shri Vijay Mehta, CA &For Respondent: Shri K. Madhusudan, CIT(DR)
Section 143(1)

…ich are later years to AY 2008-09. (c) Further, each assessment is separate as per the ROI filed under 153A, therefore, no fresh deduction/set off can be given in at this stage. Reliance is placed on SC decisions in the case of M/s. Sun Engineering works Ltd. 198 ITR 297 (SC). 24. We have heard the rival contention of the parties and perused the material available on record and the judgements cited by the respective parties. In the present case, search and seizure action was carried out in the residential premises of one Shri Mukhesh Sharma in July, 2008. During the course of search, certain documents were found…