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 366,470 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 Central Circle-1(1), Ahmedabad, Gujarat vs. Bhaveshkumar Girishbhai Bhandari, Ahmedabad, Gujarat

In the result, the appeal of the Department is allowed and the order of

ITA 978/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2016-17
For Respondent: Shri Abhijit Sr.DR
Section 132Section 143(1)Section 143(3)Section 144BSection 147Section 250Section 37(1)Section 68

…आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ "B", अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. BRR KUMAR, VICE PRESIDENT AND SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER 1. आयकर अपील सं/ITA No.977/Ahd/2025 Asst.Year 2018-19 2. आयकर अपील सं/ITA No.978/Ahd/2025 Asst.Year 2016-17 3. आयकर अपील सं/ITA No.979/Ahd/2025 Asst.Year 2018-19 1. Dy.CIT Central Circle-1(1) Ahmedabad – 380 009 2-3.Dy.CIT Central Circle-1(1) Ahmedabad – 380 009 बनाम/ v/s. 1. Girishkumar Amratlal Bhandari HUF Nava Bazar Himatnagar Himatnagar – 383 001 Dist.Sabarkantha PAN: AADHB 2136 F 2-3.Bhaveshkumar Girishbhai Bhandari…

Deputy Commissioner of Income -Tax Central Circle-1(1), Ahmedabad, Gujarat vs. Girishkumar Amratlal Bhandari HUF, Himatnagar, Gujarat

In the result, the appeal of the Department is allowed and the order of

ITA 977/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2018-19
For Respondent: Shri Abhijit Sr.DR
Section 132Section 143(1)Section 143(3)Section 144BSection 147Section 250Section 37(1)Section 68

…आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ "B", अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. BRR KUMAR, VICE PRESIDENT AND SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER 1. आयकर अपील सं/ITA No.977/Ahd/2025 Asst.Year 2018-19 2. आयकर अपील सं/ITA No.978/Ahd/2025 Asst.Year 2016-17 3. आयकर अपील सं/ITA No.979/Ahd/2025 Asst.Year 2018-19 1. Dy.CIT Central Circle-1(1) Ahmedabad – 380 009 2-3.Dy.CIT Central Circle-1(1) Ahmedabad – 380 009 बनाम/ v/s. 1. Girishkumar Amratlal Bhandari HUF Nava Bazar Himatnagar Himatnagar – 383 001 Dist.Sabarkantha PAN: AADHB 2136 F 2-3.Bhaveshkumar Girishbhai Bhandari…

Gitaben Dineshbhai Patel, Ahmedabad vs. ITO Ward 5(3)(1), Ahmedabad

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

ITA 717/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Anil Kshatriya, AdvocateFor Respondent: Shri Abhijit, Sr. DR
Section 10(38)Section 144BSection 147Section 148Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. BRR KUMAR, VICE PRESIDENT & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. No.717/Ahd/2025 (Assessment Year: 2017-18) Gitaben Dineshbhai Patel, Vs. Income Tax Officer, 2nd Floor, Anison Building, Ward-5(3)(1), Swastik Society, Navrangpura, Ahmedabad Ahmedabad-380009 Now Income Tax Officer, Ward-1(2)(1), Ahmedabad [PAN No.ABEPP8382M] (Appellant) .. (Respondent) Appellant by : Shri Anil Kshatriya, Advocate Respondent by: Shri Abhijit, Sr. DR 14.08.2025 Date of Hearing Date of Pronouncement 04.11.2025 O R D E R PER SIDDHARTHA NAUTIYAL - JUDICIA…

Vapi Marchant Saving and Credit Co-Op Society Limited, Vapi vs. Income Tax Officer, Ward-9, Vapi

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

ITA 838/SRT/2023[2010-11]Status: DisposedITAT Surat30 Oct 2025AY 2010-11

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2010-2011 Vapi Merchant Saving & Credit Ito Ward-9, Co-Op Society Ltd., Income Tax Office, Nr. Vaishali Office No. 130, First Floor, Varun Vs. Char Rasta, Nh-8, Gidc, Complex, Opp. Reliance Super Vapi-396191. Market Gidc, Vapi-396195. Pan No. Aaaav 3925 E Appellant Respondent

For Appellant: Mr. J.K. Chandnani, Sr. DRFor Respondent: Mr. Hem Chhajed, AR
Section 139Section 139(1)Section 148Section 80A(5)Section 80P(2)(a)Section 8O

…see and refered to the decision of to the decision of the Hon’ble Supreme Court in the case of Sun Engineering Works P the Hon’ble Supreme Court in the case of Sun Engineering Works P the Hon’ble Supreme Court in the case of Sun Engineering Works P Ltd (1992) 198 ITR 297 ,320(SC) Ltd (1992) 198 ITR 297 ,320(SC) wherein it is held that proceeding wherein it is held that proceeding under section 147 are for the benefit of the R 147 are for the benefit of the Revenue and not for the evenue and not for the assessee. The Assessing Officer rejected claim of the assessee on assessee. The Assessing Officer rejected claim…

DCIT, Central Circle-8(1), Mumbai vs. Ei Resorts & Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3926/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Oct 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon‟ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer‟s act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

DCIT, Central Circle-8(1), Mumbai vs. E I Resorts and Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3886/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon‟ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer‟s act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Tarun Nandkumar Seksaria, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3239/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Ei Beneficiary Trust, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3230/Mum/2025

ITA 3236/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Oct 2025AY 2018-19
Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief, which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Ei Beneficiary Trust, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3230/Mum/2025

ITA 3235/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief, which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Ei Beneficary Trust, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3230/Mum/2025 Govind

ITA 3234/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Oct 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon‟ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer‟s act of extrapolating entries found in one year to reopen other years is precisely the mischief, which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Govind Corporation, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3230/Mum/2025

ITA 3231/MUM/2025[2021-22]Status: DisposedITAT Mumbai28 Oct 2025AY 2021-22
Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief, which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Govind Corporation, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3230/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief, which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Tarun Nandkumar Seksaria, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3216/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under Section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Tarun Nandkumar Seksaria, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3215/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Oct 2025AY 2016-17
Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under Section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Ei Resorts and Clubs Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3213/Mum/2025

ITA 3213/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13
Section 132Section 132(4)Section 69A

…his mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under Section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

Kailash Gahlot, New Delhi vs. DCIT, Central Circle-4, New Delhi

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

ITA 3431/DEL/2023[2015-16]Status: DisposedITAT Delhi24 Oct 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.3431/Del./2023, A.Y. 2015-16 Kailash Gahlot Deputy Commissioner Of C-6/6172, Vasant Kunj, Income Tax, New Delhi Vs. Central Circle-4, Pan: Aajpg2849N New Delhi (Appellant) (Respondent) Appellant By Sh. Vinod Kumar Bindal, Ca Sh. Anmol Jha, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 24/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2015-16 Is Directed Against The Order Dated 30.09.2023 Of The Commissioner Of Income Tax (Appeals)-23, New Delhi [‘Cit(A)’].

Section 115BSection 132(4)Section 153DSection 69C

…he points of arguments canvassed by both the sides. Though there is plethora of judicial precedents on this aspect, it will suffice here to reproduce the relevant part of the judgment of the Hon’ble Supreme Court in the case of Sun Engineering Works (P) Ltd.; 198 ITR 297, which is self-explanatory: “It is neither desirable nor permissible to pick out a word or sentence from the judgment of this court, divorced from the context the question under consideration and treat it to be the complete law declared by this court. ….”. 24. In the case of UOI & Ors. v. Dhanwanti Devi & Ors; 6 SCC 44, the Hon’ble Supreme Court…

DCIT, Central Circle-8(1), Mumbai vs. The Estate Investment Company Pvt Ltd, Mumbai

3012/Mum/2025

ITA 3936/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

…his mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

DCIT, Central Circle-8(1), Mumbai vs. The Estate Investment Company Pvt Ltd, Mumbai

ITA 3928/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

…his mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this count too, the reassessments lack legal sanctity.…

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3228/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

…his mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon'ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. 62 ITA No.3012/Mum/2025 and others The Estate Investment Company Pvt. Ltd. and others The Assessing Officer's act of extrapolating entries found in one year to reopen other years is precisely the mischief which…

The Estate Investment Company Private Limited, Mumbai vs. DCIT Central Circle 8(1), Mumbai

3012/Mum/2025

ITA 3227/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

…This mechanical transposition of entries across assessment years, without verifying the temporal correlation of the alleged transactions, amounts to impermissible telescoping of facts. The Hon‘ble Supreme Court in CIT v. Sun Engineering Works (P) Ltd. [(1992) 198 ITR 297 (SC)] held that reopening under section 147 cannot be used as a ploy for roving verification or fishing enquiry into completed matters. The Estate Investment Company Pvt. Ltd. and others The Assessing Officer‘s act of extrapolating entries found in one year to reopen other years is precisely the mischief which the Court sought to prevent. On this…