How many judgments cite CIT v. Vatika Township Pvt. Ltd.?

1,558 judgments on BharatTax cite CIT v. Vatika Township Pvt. Ltd. (367 ITR 466), spanning 2010 to 2026.

Which sections of the Income Tax Act does CIT v. Vatika Township Pvt. Ltd. come up under?

It is most often cited in judgments turning on Section 143(3), Section 115BBE, Section 142(1), Section 143(2), Section 143(1), Section 250.

CIT v. Vatika Township Pvt. Ltd.

367 ITR 466Supreme Court of India2014#25 most cited

What is CIT v. Vatika Township Pvt. Ltd. authority for?

Taxing statutes are presumed to operate prospectively unless a clear contrary intention for retrospective application is evident. The law applicable for determining tax liability is that which stands on the first day of the assessment year, following the principle that law looks forward, not backward (lex prospicit non respicit).

1,558

judgments rely on this decision, according to BharatTax’s citation analysis of 383,853 Indian tax judgments — from 2010 to 2026.

Also referred to as

CIT v. Vatika Township Pvt. Ltd. · 367 ITR 466 · retrospective amendment · prospective operation · interpretation of taxing statutes · tax law applicability · lex prospicit non respicit · assessment year · law looks forward · section 143(1)

Also reported as

1 SCC 1109 DTR 33271 CTR 1

Sections most often in play

Section 143(3)Section 115BBE Section 142(1)Section 143(2)Section 143(1)Section 250 Section 69 Section 200A

Read the full judgment

Issues it is cited on

retrospective amendment section 43b section 43 section 115 section 139 section 11 undisclosed income section 143(1)section 132 section 13 previous year section 15

Judgments citing CIT v. Vatika Township Pvt. Ltd.

Ashish Bhargava, Jaipur vs. DCIT, Jaipur

In the result, the appeal of the assessee is allowed

ITA 875/JPR/2025[2017-18]Status: DisposedITAT Jaipur08 Sept 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Vinok Kumar Gupta, C.AFor Respondent: Shri Dharam Singh Meena, JCIT

Section 115BSection 139Section 143(2)Section 143(3)Section 145(3)Section 68

…o effect from 01.04.2017. 4. This amendment enhancing the tax rate from 30% to 60% (plus surcharge and cess) is a substantive change in law, not merely procedural or clarificatory. As held by the Hon’ble Supreme Court in CIT v. Vatika Township (P) Ltd. (2014) 367 ITR 466 (SC), any amendment which increases the tax burden on the assessee must be applied prospectively, not retrospectively. 5. Since the relevant transactions of cash deposit occurred before the amendment came into force (i.e., during November 2016), the enhanced rate of 60% under Section 115BBE cannot be retrospectively applied to the present case.…

Roman Catholic Church of St. Paul, Mumbai vs. ITO Exem.Ward 2(2), Mumbai

In the result, the appeal by the assessee is treated as allowed for statistical purposes

ITA 3396/MUM/2025[2023-24]Status: DisposedITAT Mumbai28 Aug 2025AY 2023-24

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2023-24 Roman Catholic Church Of St. Income Tax Officer (Exem.), Paul Ward 2(2) St Paul Church, Vs. Dr. Ambedkar Road, Dadar, Mumbai - 400014 (Pan : Aaatr2742L) (Appellant) (Respondent)

For Appellant: Shri Haridas Bhat, CAFor Respondent: Shri Annavaram Kosuri, CIT DR

Section 10Section 11Section 11(2)Section 11(2)(a)Section 115BSection 12ASection 143Section 143(1)Section 143(3)

…ments will take effect from 1st April, 2023 and will accordingly apply in relation to the assessment year 2023-24 and subsequent assessment years, [Clauses 4 and 5]" 19. We find the Hon'ble Supreme Court in the case of CIT vs. Vatika Township Pvt. Ltd. (2014) 367 ITR 466 (SC) on the issue of interpretation of taxing statutes about retrospective amendment and prospective amendment, has held as under: 14 Roman Catholic Church of St. Paul AY 2023-24 "30. A legislation, be it a statutory Act or a statutory Rule or a statutory Notification, may physically consists of words printed on papers. However, conceptually it…

ACIT(CC)-7(3), Mumbai vs. Lotus Logistics and Developers Private Limited, Mumbai

In the result, appeal by the Revenue is dismissed and cross objection of the assessee is partly allowed

ITA 137/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19

For Appellant: Shri Rushabh Mehta and Shri Niraj Soni, CAsFor Respondent: Shri Aditya M. Rai, Sr. DR

Section 143(3)Section 37(1)Section 43CSection 68Section 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2018-19 ACIT(CC)-7(3), Lotus Logistics and Developers Mumbai Private Limited 301, 13th Level, Lotus Trade Centre, Vs. New Link Road, Near D N Nagar Metro Station, Andheri-west Mumbai – 700013 (PAN : AABCL1198G) (Appellant) (Respondent) CO. No. 28/MUM/2025 (Arising out of ITA No. 137/Mum/2025) Assessment Year: 2018-19 Lotus Logistics and ACIT(CC)-7(3), Developers Private Limited Mumbai 301, 13th Level, Lotus Trade Centre, New Link Road, Near Vs. D N Nagar M…

Sharath Kumar Reddy Sareddy, Wanaparthy, Mahabub Nagar vs. Income Tax Officer, Ward -1, Mahabubnagar

In the result, appeal filed by the assessee is dismissed

ITA 1096/HYD/2024[2022-23]Status: DisposedITAT Hyderabad20 Aug 2025AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1096/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2022-23) Shri Sharath Kumar Reddy Vs. Income Tax Officer Sareddy, Wanaparthy Ward – 1 Mahbubnagar Mahbubnagar Pan:Hpwps0712H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 16/07/2025 घोषणा की तारीख/Pronouncement: 20/08/2025 आदेश/Order

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR

Section 115BSection 194BSection 58(4)

…mitted that when the amendment provides a specific date of its applicability, then the same cannot be treated as retrospective in nature. He has then relied upon the judgment of the Hon'ble Supreme Court in the case of CIT vs. Vatika Township (P) Ltd reported 367 ITR 466 (S.C) that the Hon'ble Supreme Court has held that one of the established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation. Therefore, the law passed today cannot be applied the events of past. The learned DR then relied upon the Pune Bench of the Tribunal dated 25/01…

Rajendra Kumar Agrawal, Jaipur vs. ACIT Cen Cir 1, C-Scheme, Jaipur

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

ITA 538/JPR/2025[2017-2018]Status: DisposedITAT Jaipur12 Aug 2025AY 2017-2018

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Rajesh Tetuka, Adv., ARFor Respondent: Sh. Gaurav Awasthi, JCIT, Sr. DR

Section 115BSection 143(3)Section 250Section 68

…vant to the assessment year 2017-18, therefore, the demand computed was not only arbitrary but inflated. 25 Rajendra Kumar Agrawal vs. ACIT That reliance has been place on the decision of Hon'ble Supreme Court in the case of Vatika Township (P) Ltd. [2014] 367 ITR 466 (SC) observed that of the various rules guiding how a legislation must be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation. The idea behind the rule is that a current law should govern current activities, which is based on the principle of…

Infosys Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1530/BANG/2024[2013-14]Status: DisposedITAT Bangalore06 Aug 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2013-14

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt Srinandini Das – CIT - DR

Section 10ASection 143(3)Section 250Section 254Section 80A(5)

…T (2015) 53 taxmann.com 362 (Delhi-Trib) wherein it was held as under- “6. We are also alive to the fact that the insertion of rule 10 BA, particularly in view of recent Hon'ble Supreme Court's judgment in the case of CIT v. Vatika Townships (P.) Ltd. [2014] 367 ITR 466/49 taxmann.com 249, is required to be held as retrospective in effect. Going by this rule, as we noted in the case of Toll Global Forwarding (supra), the 50:50 business model, as is said to have been adopted by the assessee, would meet arm's length test. It thus appears to be free from doubt that 50:50 business model, as has been adopted by many…

Deputy Commissioner of Income Tax, Chennai vs. Shriprop Properties Private Limited, Bangalore

ITA 1283/CHNY/2025[2018-19]Status: DisposedITAT Chennai25 Jul 2025AY 2018-19

Bench: Shri George George K & Ms Padmavathy S, Am

For Appellant: Mrs. S. Ananthan, CA (virtually)For Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 143(3)Section 153CSection 250Section 40A(2)(b)Section 56(2)(x)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, CHENNAI BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 1172/Chny/2025 (Assessment Year: 2018-19) SPL Shelters Private Limited. DCIT, CC-1(4), New No. 9, Lakshmi Neela Rite Investigation Building, Choice Chamber, Bazullah Road, Chennai-600034. Vs. T. Nagar, Chennai-600017. PAN: AAVCS5350D Appellant) : Respondent) I.T.A. No. 1273/Chny/2025 (Assessment Year: 2018-19) Deputy Commissioner of Income SPL Shelters Private Limited. Tax, CC-1(4) New No. 9, Lakshmi Neela Rite No. 46, Investigation Building, Income Choice Chamber, Bazullah Road…

Deputy Commissioner of Income Tax, Chennai vs. Spl Shelters Private Limited, Chennai

ITA 1273/CHNY/2025[2018-19]Status: DisposedITAT Chennai25 Jul 2025AY 2018-19

Bench: Shri George George K & Ms Padmavathy S, Am

For Appellant: Mrs. S. Ananthan, CA (virtually)For Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 143(3)Section 153CSection 250Section 40A(2)(b)Section 56(2)(x)

Spl Shelters Pvt. Ltd., Bangalore vs. DCIT, Central Circle-1(4), Chennai

ITA 1172/CHNY/2025[2018-19]Status: DisposedITAT Chennai25 Jul 2025AY 2018-19

Bench: Shri George George K & Ms Padmavathy S, Am

For Appellant: Mrs. S. Ananthan, CA (virtually)For Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 143(3)Section 153CSection 250Section 40A(2)(b)Section 56(2)(x)

Sai Jankalyan Education Sanstha, Mumbai vs. ITO Exem Ward 2(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 3397/MUM/2025[2023-24]Status: DisposedITAT Mumbai25 Jul 2025AY 2023-24

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Shri Haridas Bhat, A/RFor Respondent: Shri Swapnil Choudhary, Sr. D/R

Section 10Section 11Section 11(2)Section 115BSection 12ASection 143Section 143(1)Section 143(3)

…nts will take effect from 1st April, 2023 and will accordingly apply in relation to the assessment year 2023-24 and subsequent assessment years. [Clauses 4 and 5 ] ” 6. We find the Hon'ble Supreme Court in the case of CIT vs. Vatika Township Pvt. Ltd. (2014) 367 ITR 466 (SC) on the issue of interpretation of taxing statutes about retrospective amendment and prospective amendment, has held as under:- 30. A legislation, be it a statutory Act or a statutory Rule or a statutory Notification, may physically consists of words printed on papers. However, conceptually it is a great deal more than an ordinary prose. The…

Shri Vasupujya Swami Maharaj Temple Trust, Pune vs. ITO (Exemption) Ward 1(2), Pune

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

ITA 1288/PUN/2025[2023-24]Status: DisposedITAT Pune22 Jul 2025AY 2023-24

Bench: Dr.Manish Borad

For Appellant: Shri Pramod S. ShingteFor Respondent: Date of hearing

Section 11Section 11(2)Section 11(3)Section 12ASection 143(1)Section 143(1)(a)Section 250

…ents will take effect from 1st April, 2023 and will accordingly apply in relation to the assessment year 2023-24 and subsequent assessment years. [Clauses 4 and 5 ]” 19. We find the Hon'ble Supreme Court in the case of CIT vs. Vatika Township Pvt. Ltd. (2014) 367 ITR 466 (SC) on the issue of interpretation of taxing statutues about retrospective amendment and prospective amendment, has held as under: “30. A legislation, be it a statutory Act or a statutory Rule or a statutory Notification, may physically consists of words printed on papers. However, conceptually it is a great deal more than an ordinary prose. The…

Shri Ishwarlal Gulabchand Vardhamantap Ayambil Trust, Pune vs. ITO Ward 7(1), Pune

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

ITA 1287/PUN/2025[2023-24]Status: DisposedITAT Pune22 Jul 2025AY 2023-24

Bench: Dr.Manish Borad

For Appellant: Shri Pramod S. ShingteFor Respondent: Date of hearing

Section 11Section 11(2)Section 11(3)Section 12ASection 143(1)Section 143(1)(a)Section 250

Albert Joseph Rozario, Mumbai vs. ITO, Int. Tax, Circle 4(1)(1), Mumbai

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

ITA 1168/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jul 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Albert Joseph Rozario, Ito, (Int. Tax), Circle-4(1)(1), B-311, 5Th Wing, Room No. 629, 6Th Floor, Inlaks Park, Vs. Kautilya Bhavan, Yari Road, Versova, C-41 To C-43, G Block, Andheri West, Bandra Kurla Complex, Mumbai-400058 Bandra East, Pan : Afvpr6139P Mumbai-400051 (Appellant) (Respondent) For Assessee : Shri Dharan Gandhi For Revenue : Shri Sridhar G. Menon, Sr.Dr Date Of Hearing : 01-05-2025 Date Of Pronouncement : 22-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Final Assessment Order Passed By The Assessing Officer U/S 147 R/W 144C(13) Of The Act Dt. 30-12-2024, Consequent To The Directions Given By The Ld. Drp-1, Mumbai-3, U/S 144C(5) Of The Act, Dated 30-11-2024 Pertaining To Assessment Year (Ay.) 2018-19. 2. Briefly The Facts Of The Case Are That Basis Information Available Through The Insight Portal That The Assessee Had Purchased Immoveable Properties Amounting To Rs. 8,31,45,549/- & Has Received Interest

For Appellant: Shri Dharan GandhiFor Respondent: Shri Sridhar G. Menon, Sr.DR

Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 56(2)(x)Section 69

…ich are not validly initiated. Without a valid approval, entire reassessment proceeding gets vitiated. Moreover, it is well settled, that an assessment creates a vested right [CED v. M.A. Merchant 1989 Supp (1) SCC 499; [2014] CIT vs. Vatika Township (P.) Ltd.367 ITR 466(SC)]. A notice/ order, which is not validly sanctioned, cannot be deemed to be 14 validly sanctioned by way of a retrospective amendment. This will frustrate the very object/ purpose behind having a valid sanction/approval at the time of issuance of notice or passing of order, with the prior approval of a senior officer. It was submitted that the…

Shree Dadar Digamer Jain Mumuksho Mandal, Mumbai vs. CIT(Exemption) Ward 2(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2446/MUM/2025[2023-24]Status: DisposedITAT Mumbai15 Jul 2025AY 2023-24

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2023-24 Shri Dadar Digamber Jain The Cit (Exemption), Mumukshu Mandal, Ward-2(3), 271/293, 271/293, Vs. Mumbai. N.C. Kelkar Road, Opp: Shivaji Park, P.O. Dadar (West) Mumbai-400028. Pan : Aacts8044A (Appellant) (Respondent) For Assessee : Shri A.N. Shah For Revenue : Shri Annavaram Kosuri Date Of Hearing : 11-06-2025 Date Of Pronouncement : 15-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld.Addl/Jcit(A)-2, Delhi [„Ld.Cit(A)‟], Dated 05-03-2025, Pertaining To Assessment Year (Ay) 2023-24, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

For Appellant: Shri A.N. ShahFor Respondent: Shri Annavaram Kosuri

Section 11(2)Section 11(3)Section 11(3)(c)Section 143(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “D” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER Assessment Year : 2023-24 Shri Dadar Digamber Jain The CIT (Exemption), Mumukshu Mandal, Ward-2(3), 271/293, 271/293, vs. Mumbai. N.C. Kelkar Road, Opp: Shivaji Park, P.O. Dadar (West) Mumbai-400028. PAN : AACTS8044A (Appellant) (Respondent) For Assessee : Shri A.N. Shah For Revenue : Shri Annavaram Kosuri Date of Hearing : 11-06-2025 Date of Pronouncement : 15-07-2025 O R D E R PER VIKRAM SINGH YADAV, A.M : This is an appeal filed by the assessee against the…

Vardhman Polytex Limited, Ludhiana vs. DCIT(TDS), Ludhiana

In the result, appeal of the Assessee is allowed

ITA 1090/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh08 Jul 2025AY 2015-16

Bench: The Ld. Cit(A), Nfac, Delhi. Though Notices Were Issued Electronically Through The E-Filing Portal, The Assessee Contended That Such Notices Were Neither Brought To Their Knowledge Nor Received Through Any Alternative Means Such As Email Or Physical Intimation. Consequently, The Appeal Was Dismissed Ex Parte. It Was Further Submitted That The Issue Involved In The Present Appeal Is Legal In Nature & Does Not Require Examination Of Disputed Facts; Hence, The Matter May Be Adjudicated On Merits Without The Necessity Of A Remand To The Lower Authorities.

For Appellant: Shri Ashish Aggarwal, C.A (Virtual)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 194CSection 194C(6)Section 201Section 201(1)Section 250Section 44A

…nt years. The statute itself is prospective in nature, and no indication has been provided by the legislature to suggest otherwise. The settled principle of law, as laid down by the Hon’ble Supreme Court in the case of CIT v. Vatika Township Pvt. Ltd. [(2014) 367 ITR 466 (SC)], is that a substantive amendment which creates a new obligation or imposes a new burden cannot be construed to operate retrospectively, unless the statute explicitly provides for such retrospective operation. 9.2 The Hon’ble Gujarat High Court, in Principal Commissioner of Income Tax v. Asian Mills Pvt. Ltd. (2021), held that failure to fi…

DCIT Circle-5(1), Kolkata vs. S K Sarawagi and Company Pvt Ltd, Kolkata

Appeals are partly allowed

ITA 151/KOL/2024[2016-17]Status: DisposedITAT Kolkata25 Jun 2025AY 2016-17

Bench: The O/O Pcit-2, Kolkata 23.01.2024 Certificate Of Filing 2Nd Appeal Was Received From The O/O Pr. Cit-2, Kolkata 24.01.2024 Necessary Hardcopies Of Documents/ Paper/ Details Required For Filing 2Nd Appeal Before The Hon'Ble Itat, Kolkata Were Collected & Prepared. 25.01.2024 2Nd Appeal Was Filed

Section 250Section 92B

…Guarantee are not covered within the definition of international transaction. It is submitted that applying 'doctrine of fairness' as explained by the Supreme Court of India in the case CIT v. Vatika Township (P.) Ltd. [2014] 49 taxmann.com 249/227 Taxman 121/367 ITR 466 the explanation ought to be read as prospective in its application and retrospective in its effect such that it will also cover within its ambit guarantees issued prior to the introduction of the Explanation by Finance Act, 2012. [Para 70] ■ A new Enactment or an Amendment meant to explain the earlier Act has to be considered retrospective. The…

DCIT, Circle-5(1), Kolkata vs. S K Sarawagi and Company Private Limited, Kolkata

Appeals are partly allowed

ITA 150/KOL/2024[2015-16]Status: DisposedITAT Kolkata25 Jun 2025AY 2015-16

Bench: The O/O Pcit-2, Kolkata 23.01.2024 Certificate Of Filing 2Nd Appeal Was Received From The O/O Pr. Cit-2, Kolkata 24.01.2024 Necessary Hardcopies Of Documents/ Paper/ Details Required For Filing 2Nd Appeal Before The Hon’Ble Itat, Kolkata Were Collected & Prepared. 25.01.2024 2Nd Appeal Was Filed

Section 250Section 92B

Yashwantrao Chavan Maharashtra Open University, Nashik vs. Exemption Circle, A Bad, Aurangabad

ITA 505/PUN/2025[2023-24]Status: DisposedITAT Pune23 Jun 2025AY 2023-24

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 11Section 11(3)Section 12ASection 139(1)Section 143(1)

…No.794/Bang/2019 8. Referring to the following decision, he submitted that the amendment should be considered prospectively and the condition for utilization as existed in the year of accumulation has to be applied: a) CIT vs. Vatika Township Pvt. Ltd. (2015) 367 ITR 466 9. Referring to the following decisions, he submitted that the issue being a debatable one, no adjustment can be made by the CPC u/s 143(1) of the Act: a) CIT vs. M/s. Mekins Agro Products Ltd. vide ITTA No.111 of 2003 b) Khatau Junkar Ltd. & Anr. vs. Pathania & Anr reported in 196 ITR 55 (Bom) 10. He accordingly submitted that the order of the L…

Anupam, Barnala vs. Income Tax Officer, Barnala

In the result, Assessee’s appeal is allowed

ITA 442/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh09 Jun 2025AY 2017-18

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

For Appellant: Shri Sarabjit Garg, C.AFor Respondent: Shri Rohit Sharma, CIT DR (Virtual)

Section 115BSection 133ASection 263

…pplied to transactions concluded before that. 4. That the appellant relies on decision of -large Bench judgment of Hon'ble Supreme Court in case of CIT vs. Vatika Township P. Ltd.as reported in [2014] 49 taxmann.com 249 (SC)/[2014] 227 Taxman 121 (SC)/[2014] 367 ITR 466 (SC)/[2014] 271 CTR 1 (SC)[15- 09-2014] whereby the Hon'ble Court laid down General Principles concerning retrospectivity, para 31 of which reads as under:- "31. Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to h…

Himalayan Buddhist Cultural Association, Delhi vs. ITO, New Delhi

Appeal is allowed

ITA 2299/DEL/2025[2023-24]Status: DisposedITAT Delhi03 Jun 2025AY 2023-24

Bench: Shri Satbeer Singh Godaraassessment Year: 2023-24 Himalayan Buddhist Cultural Vs. Income Tax Officer, Association, New Delhi B-4, Ladakh Buddhist Vihara, Tarav Devi Colony, Bela Road, New Delhi Pan : Aaath1948L (Appellant) (Respondent) Assessee By Sh. R.S. Singhvi, Ca Sh. Rajat Garg, Ca Department By Sh. Akhilesh Kumar Yadav, Sr. Dr

Section 11Section 11(2)Section 11(3)Section 11(3)(c)Section 143(1)Section 143(1)(a)

…e first day of the assessment year is applicable for determining the tax liability for that assessment year. This is a well-established principle, upheld by the Supreme 2 | P a g e Court in numerous judgments, including CIT v. Vatika Township Pvt. Ltd. [2014] 367 ITR 466 (SC). 5.6 The appellant's reliance on the decision of Hon'ble ITAT Bangalore in the case of M/s Phulchand Gulabchand Charitable Trust vs. Income Tax Officer Ward-2 is not relevant as the facts and applicable law in that case were different. Similarly, the judgments of the Supreme Court in the cases of Commissioner of Income Tax vs. Vinay Cement L…