CIT v. Vegetable Products Ltd.

88 ITR 192Supreme Court of India1973#5 most cited

What is CIT v. Vegetable Products Ltd. authority for?

When two equally plausible interpretations of a taxing provision are possible, or when conflicting views exist from non-jurisdictional High Courts, the interpretation that favors the assessee must be adopted.

2,642

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2005 to 2026.

Also referred to as

CIT v. Vegetable Products Ltd. · 88 ITR 192 · statutory interpretation · benefit of doubt assessee · two reasonable constructions · conflicting views · assessee favour · Section 143(3) · Section 153C · Section 153A · Section 144

Also reported as

169 Taxmann 454

Sections most often in play

Section 143(3)Section 153CSection 153ASection 144Section 115BBESection 132Section 250Section 80P(2)(d)

Issues it is cited on

section 200a(1)section 234esection 200asection 200section 20section 201section 234section 23section 28section 151section 131undisclosed income

Judgments citing CIT v. Vegetable Products Ltd.

VANGALA ADILAKSHMI ,HYDERABAD vs. ITO, WARD -6(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 2222/HYD/2025[2016-17]Status: DisposedITAT Hyderabad17 Apr 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.2222/Hyd/2025 Assessment Year 2016-2017 Adilakshmi Vangala, The Income Tax Officer, Hyderabad – 500 045. Ward-6(1), Vs. Telangana. Hyderabad – 500 028. Telangana. Pan Acrpv6738R (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri R. Mohan Kumar, Advocate राज" व "ारा/Revenue By : Sri Karthik Manickam, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 08.04.2026 घोषणा की तारीख/Pronouncement: 17.04.2026 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri R. Mohan Kumar, AdvocateFor Respondent: Sri Karthik Manickam, Sr. AR
Section 133(6)Section 148Section 148ASection 149(1)(b)Section 149(2)Section 69A

…r section 148 of the Act of 1961 are quashed and set aside. The respondents are free to take appropriate steps in accordance with law.” 6.6. Therefore, in view of the Judgment of the Hon’ble Supreme Court in the case of CIT vs. Vegetable Products Ltd. [1973] 88 ITR 192 (SC), we follow the Judgment of Hon’ble Madras High Court as well as Hon’ble Bombay High Court (supra) in deciding the issue in favour of the assessee. Accordingly, in the facts and circumstances of the case, when the actual transaction of cash deposit in the bank account of the assessee is only Rs.38,10,000/- then, the notice issued 21 ITA.No.22…

JILA SAHAKARI KENDRIYA BANK MYDT,SEHORE, MP vs. COMMISIONER OF INCOME TAX (APPEALS), NFAC, DELHI

Appeal is partly allowed for statistical purposes

ITA 407/IND/2024[2014-15]Status: DisposedITAT Indore10 Apr 2026AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Jila Sahakari Kendriya Cit(A), Nfac, Delhi / Bank Mydt, Acit-3(1), Bhopal बनाम/ Sehore, M.P. Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Aaalj0022F Assessee By Shri Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 26.02.2026 Date Of Pronouncement 10.04.2026

Section 143(2)Section 143(3)Section 36(1)(va)Section 36(1)(viia)Section 43B

…e ITAT, Indore accepted assessee’s claim. This earlier decision is referred in different case laws narrated by Ld. AR (re- produced above). (iii) Even if there is a divergence amongst different benches of ITAT, we have to adopt the Vegetable Products Ltd. 88 ITR 192 wherein the Hon’ble Supreme Court has held that if two reasonable constructions of a taxing provision are possible, that construction which favours the assessee must be adopted. 10. In view of above discussions, we hold that the “Provision for standard assets” made by assessee is eligible for deduction u/s 36(1)(viia). However, during hearing,…

AURORA EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT., CENTRAL CIRCLE 2(4), HYDERABAD

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

ITA 1257/HYD/2025[2018-19]Status: DisposedITAT Hyderabad27 Mar 2026AY 2018-19
Section 11Section 132Section 143(3)Section 153ASection 254Section 269Section 269SSection 271D

…uming there are two possible interpretations, one favouring the Revenue (Hon’ble Kerala High Court) and the other favouring the assessee (Hon’ble Karnataka High Court), the settled law laid down by the Hon’ble Supreme Court in CIT vs. Vegetable Products Ltd. [88 ITR 192] is that where two views are reasonably possible, the one favourable to the assessee must be adopted. Therefore, applying the ratio of the Hon’ble Karnataka High Court to the present case, we hold that the penalty proceedings are deemed to have been initiated on 18.01.2017, when the Ld. AO made a reference to the Addl. CIT. Consequently, the last…

AURORA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE 2(4), HYDERABAD

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

ITA 1256/HYD/2025[2017-18]Status: DisposedITAT Hyderabad27 Mar 2026AY 2017-18
Section 11Section 132Section 143(3)Section 153ASection 254Section 269Section 269SSection 271D

…uming there are two possible interpretations, one favouring the Revenue (Hon’ble Kerala High Court) and the other favouring the assessee (Hon’ble Karnataka High Court), the settled law laid down by the Hon’ble Supreme Court in CIT vs. Vegetable Products Ltd. [88 ITR 192] is that where two views are reasonably possible, the one favourable to the assessee must be adopted. Therefore, applying the ratio of the Hon’ble Karnataka High Court to the present case, we hold that the penalty proceedings are deemed to have been initiated on 18.01.2017, when the Ld. AO made a reference to the Addl. CIT. Consequently, the last…

AURORA EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT., CENTRAL CIRCLE 2(4), HYDERABAD

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

ITA 1255/HYD/2025[2016-17]Status: DisposedITAT Hyderabad27 Mar 2026AY 2016-17
Section 11Section 132Section 143(3)Section 153ASection 254Section 269Section 269SSection 271D

…uming there are two possible interpretations, one favouring the Revenue (Hon’ble Kerala High Court) and the other favouring the assessee (Hon’ble Karnataka High Court), the settled law laid down by the Hon’ble Supreme Court in CIT vs. Vegetable Products Ltd. [88 ITR 192] is that where two views are reasonably possible, the one favourable to the assessee must be adopted. Therefore, applying the ratio of the Hon’ble Karnataka High Court to the present case, we hold that the penalty proceedings are deemed to have been initiated on 18.01.2017, when the Ld. AO made a reference to the Addl. CIT. Consequently, the last…

OM SHIVDARSHAN CO-OP HOSING SOCIETY LTD,MUMBAI vs. INCOME TAX OFFICER, WARD 41(2)(3), , MUMBAI

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

ITA 966/MUM/2026[2021-22]Status: DisposedITAT Mumbai27 Mar 2026AY 2021-22

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Ravindra Naik, CAFor Respondent: Shri Pravin Salunkhe, SR. DR
Section 143(1)Section 250Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

…th the views of the Hon'ble High Court, adopt an objective criterion for deciding as to which decision of the Hon'ble High Court should be followed by us. We find guidance from the judgment of the Hon'ble Supreme Court in CIT v. Vegetable Products Ltd. [1973] 88 ITR 192. In the aforesaid decision, the Hon'ble Supreme Court has laid down a principle that "if two reasonable constructions of a taxing provisions are possible, that construction which favours the assessee must be adopted". 14. Therefore, in view of the above, we uphold the plea of the assessee and direct the AO to grant the deduction under section 80P(…

BANARSI LAL,FIROZABAD vs. ITO 2(2)(1), FIROZABAD, FIROZABAD

In the result, the appeal of the assessee is allowed

ITA 317/AGR/2025[2014-2015]Status: DisposedITAT Agra20 Mar 2026AY 2014-2015

Bench: Us Challenging The Validity Of Assumption Of Jurisdiction U/S 147 Of The Act. These Additional Grounds Go To The Root Of The Matter & The Facts Relevant For Its Adjudication Are Placed On Record. Hence, We Admit The Additional Grounds & Take Up The Same First For Adjudication.

Section 147Section 148Section 151Section 250

…Banarsi Lal 5. We find that the various decisions quoted by both the Ld. AR as well as the Ld. DR are non-jurisdictional high courts giving conflicting decisions. We find that the Hon’ble Supreme Court in the case of CIT vs Vegetable Products Ltd reported in 88 ITR 192 (SC) had held that when there are conflicting decisions of non- jurisdictional high courts on the same issue, then the construction that is favourable to the assessee need to be adopted. Respectfully following the same, we hold that the reopening has been made in the instant case by not taking approval u/s 151 of the Act from the competent authori…

NITYANAND NAGAR VIBHAG -IV COOPERATIVE HOUSING SOCIETY LIMITED ,MUMBAI vs. ITO WARD 24(3)(1), MUMBAI

In the result, the appeal filed by the Assessee stands allowed

ITA 494/MUM/2026[2021-22]Status: DisposedITAT Mumbai12 Mar 2026AY 2021-22

Bench: Shri Narender Kumar Choudhryshri Girish Agrawal

For Appellant: Revenue byFor Respondent: Shri Pravin Salunkhe (Sr. DR.)
Section 143(1)Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(D)Section 80P(2)(d)

…iews of the Hon’ble High Court, adopt an objective criterion for deciding as to which decision of the Hon’ble High Court should be followed by us. we find guidance from the judgment of the Hon’ble Supreme Court in Ld. CIT(A) v. Vegetable products Ltd., [1972] 88 ITR 192. In the aforesaid decision, the Hon’ble Supreme Court has laid down a principle that “if two reasonable constructions of a taxing provisions are possible, that construction which favours the Assessee must be adopted.” 6 NITYANAND NAGAR VIBHAG 5. As the facts of this case are not deviated from the facts of the aforesaid case dealt with by the Hon’…

LA ROYAL CO-OPERATIVE HSG SOC LTD,KANDIVALI vs. ASSESSING OFFICER, KAUTILIYA BHAVAN

In the result, the appeal filed by the Assessee stands allowed

ITA 443/MUM/2026[2021-22]Status: DisposedITAT Mumbai11 Mar 2026AY 2021-22

Bench: Shri Narender Kumar Choudhryshri Girish Agrawal

For Appellant: Shri Ganshyamlal Kachhara, LdFor Respondent: Shri Pravin Salunkhe (Sr. DR.)
Section 143(1)Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(D)Section 80P(2)(d)

…iews of the Hon’ble High Court, adopt an objective criterion for deciding as to which decision of the Hon’ble High Court should be followed by us. we find guidance from the judgment of the Hon’ble Supreme Court in Ld. CIT(A) v. Vegetable products Ltd., [1972] 88 ITR 192. In the aforesaid decision, the Hon’ble Supreme Court has laid down a principle that “if two reasonable constructions of a taxing provisions are possible, that construction which favours the Assessee must be adopted.” 6 LA Royal Co-Operative HSG SOC LTD 6. As the facts of this case are not deviated from the facts of the aforesaid case dealt with…

VIMAL TODI,INDORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, INDORE

Appeal is allowed

ITA 188/IND/2024[2012-13]Status: DisposedITAT Indore06 Mar 2026AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshishri Vimal Todi, Additional Commissioner बनाम/ 501, Darshan Residency, Of Income-Tax, Vs. 104-105, Anand Bazar, Indore Indore

Section 132Section 254(2)Section 271DSection 275Section 275(1)(c)

…आयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M JOSHI, JUDICIAL MEMBER Shri Vimal Todi, Additional Commissioner बनाम/ 501, Darshan Residency, of Income-tax, Vs. 104-105, Anand Bazar, Indore Indore (Assessee/Appellant) (Revenue/Respondent) PAN: AFYPT0164P Assessee by Shri Venus Rawka, CA & AR Revenue by Shri Ashish Porwal, Sr. DR Date of Hearing 09.02.2026 Date of Pronouncement 06.03.2026 आदेश/ O R D E R Per B.M. Biyani, AM: Feeling aggrieved by order of first-appeal dated 29.12.2023 passed by learned Co…

AMITH VISHNAV GUDIMELLA,HYDERABAD vs. ITO, WARD-12(1), HYDERABAD, HYDERABAD

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 1705/HYD/2025[2020-21]Status: HeardITAT Hyderabad06 Mar 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1705/Hyd/2025 Assessment Year 2020-2021 Amith Vishnav The Income Tax Officer, Gudimella, Hyderabad. Ward-12(1), Pin – 500 008. Telangana. Vs. Hyderabad. Pan Aghpv2565J Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By Sri T Chaitanya Kumar, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: MS Reema Yadav, Sr. AR
Section 143(1)Section 154Section 90Section 91

…gly, in view of the series of decisions of this Tribunal as well as to maintain the rule of consistency with the decisions of the Coordinate Benches and the decision of the Hon'ble Supreme Court in the case of Vegetable Products Ltd vs. CIT reported in (1973] 88 ITR 192 (SC) dated 29-01- 1973, in case of divergent views, the precedent in favour of the assessee shall be followed. Hence, in view of the facts and circumstances as discussed above as well as the decisions of this Tribunal, Hon'ble High Court and Hon'ble Supreme Court, we hold that the Foreign Tax Credit cannot be denied merely because there is a 18 IT…

MAHAVEER SINGH,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 840/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 139(1)Section 142(1)Section 143(3)Section 148Section 234FSection 263(1)Section 270ASection 270A(2)(b)Section 272A(1)(d)Section 44A

…st of the revenue, the Additional Commissioner had jurisdiction under section 263 to pass the order. The Madhya Pradesh High Court in the case of Indian Pharmaceuticals after referring to the decision of the Apex Court in the case of C.A. Abraham v. ITO[1961] 41 ITR 425 and CIT v. Bheekha Bhai Dada Bhai [1961] 42 ITR 123 has held that the assessment does not mean only computation of income but consideration of all facts including the liability for penalty that may attract the provisions contained in section 271(1)(a) of the Act. It has further held that if in any proceeding for assessment the Income Tax Officer f…

DCIT CC 5(1), MUMBAI , MUMBAI vs. J KUMAR INFRAPROJECTS LIMITED, MUMBAI

In the result, the CO filed by the assessee stands allowed

ITA 2885/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Feb 2026AY 2015-16

Bench: Shri Sandeep Gosain, () & Shri Bijayananda Pruseth

Section 250Section 69C

…tional High Court on the issue at hand and thus, if there are divergent views of non- jurisdictional High Courts on the subject, the view that favour the Assessee needs to be adopted as held by the Hon’ble Supreme Court in CIT v. Vegetable Products Ltd.[1973] 88 ITR 192 (SC)wherein it is held that if the language is capable of more than one meaning, the Court needs to adopt the interpretation that favours the Assessee needs to be adopted. 21. In view of the above, it is held that the sanction granted u/s.151 of the Act without signing the same is invalid and therefore the Assessing Officer did not assumed jurisd…

DCIT CC 5(1) MUMBAI , MUMBAI vs. J KUMAR INFRAPROJECTS LIMITED, MUMBAI

In the result, the CO filed by the assessee stands allowed

ITA 2884/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Feb 2026AY 2014-15

Bench: Shri Sandeep Gosain, () & Shri Bijayananda Pruseth

Section 250Section 69C

…tional High Court on the issue at hand and thus, if there are divergent views of non- jurisdictional High Courts on the subject, the view that favour the Assessee needs to be adopted as held by the Hon’ble Supreme Court in CIT v. Vegetable Products Ltd.[1973] 88 ITR 192 (SC)wherein it is held that if the language is capable of more than one meaning, the Court needs to adopt the interpretation that favours the Assessee needs to be adopted. 21. In view of the above, it is held that the sanction granted u/s.151 of the Act without signing the same is invalid and therefore the Assessing Officer did not assumed jurisd…

DCIT CC 5(1), MUMBAI , BKC vs. J KUMAR INFRAPROJECTS LIMITED, ANDHERI

In the result, the CO filed by the assessee stands allowed

ITA 2883/MUM/2025[2013-14]Status: DisposedITAT Mumbai26 Feb 2026AY 2013-14

Bench: Shri Sandeep Gosain, () & Shri Bijayananda Pruseth

Section 250Section 69C

…tional High Court on the issue at hand and thus, if there are divergent views of non- jurisdictional High Courts on the subject, the view that favour the Assessee needs to be adopted as held by the Hon’ble Supreme Court in CIT v. Vegetable Products Ltd.[1973] 88 ITR 192 (SC)wherein it is held that if the language is capable of more than one meaning, the Court needs to adopt the interpretation that favours the Assessee needs to be adopted. 21. In view of the above, it is held that the sanction granted u/s.151 of the Act without signing the same is invalid and therefore the Assessing Officer did not assumed jurisd…

FAYAZ MOHAMMED,HYDERABAD vs. DCIT, CENTRAL CIRCLE 2(4), HYDERABAD, HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 1671/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Feb 2026AY 2017-18
Section 132Section 147Section 148Section 153ASection 153CSection 250Section 69

…f the decision relied upon by the Ld. DR is applicable to the facts of the present case, but fact remains that since there are divergent views on the issue, in view of the decision of Hon'ble Supreme Court in the case of CIT Vs. Vegetable Products Ltd. (1973) 88 ITR 192 (SC), in our considered view, the view which is favourable to the assessee should be considered. Since the Hon'ble Supreme Court and majority of Hon'ble High Courts have taken a view that notice issued u/s.153C of the Act after a period of 10 months to 1 ½ year is barred by limitation and in our considered view by applying the above case laws in t…

HORIZON CO OPERATIVE HOUSING SOCIETY LIMITED ,MUMBAI vs. ITO WARD 21(2)(4), MUMBAI

In the result, both the appeals filed by the assessee stand allowed

ITA 8469/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Feb 2026AY 2018-19

Bench: Shri Amit Shukla () & Shri Girish Agrawal ()

Section 143(3)Section 2(19)Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA (JUDICIAL MEMBER) & SHRI GIRISH AGRAWAL (ACCOUNTANT MEMBER) I.T.A. No. 8468 & 8469/Mum/2025 Assessment Years: 2013-14 & 2018-19 Horizon Co-operative Housing Vs. ITO, 21(1)(4) Society Limited 1, Horizon Society S. K. Ahire Marg Door Darshan Worli Mumbai - 400018 [PAN: AAAAH1685F] (Appellant) (Respondent) Assessee by Ms. Pratiksha Jain a/w Shri Jayesh Chobisa, ARs Revenue by Shri Hemanshu Joshi, Sr.D/R Date of Hearing 24.02.2026 Date of Pronouncement 25.02.2026 ORDER PER AMIT SHUKLA (J.M.): 1. The above-captioned appeals have been fil…

HORIZON CO-OPERATIVE HOUSING SOCIETY LIMTED ,MUMBAI vs. ITO WARD 21(1)(4), MUMBAI

ITA 8468/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Feb 2026AY 2013-14

Bench: Shri Amit Shukla () & Shri Girish Agrawal () Ι.Τ.Α. Νο. 8468 & 8469/Mum/2025

Section 143(3)Section 2(19)Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA (JUDICIAL MEMBER) & SHRI GIRISH AGRAWAL (ACCOUNTANT MEMBER) Ι.Τ.Α. Νο. 8468 & 8469/Mum/2025 Assessment Years: 2013-14 & 2018-19 Horizon Co-operative Housing Society Limited Vs. ΙΤΟ, 21(1)(4) 1, Horizon Society S. K. Ahire Marg Door Darshan Worli Mumbai - 400018 [PAN: ААААH1685F] (Appellant) (Respondent) Assessee by Ms. Pratiksha Jain a/w Shri Jayesh Chobisa, ARs Revenue by | Shri Hemanshu Joshi, Sr.D/R Date of Hearing 24.02.2026 Date of Pronouncement 25.02.2026 ORDER PER AMIT SHUKLA (J.M.): 1. The above-captioned appeals have been fil…

DINESH VERMA,MANALI, HIMACHAL PRADESH vs. ITO, ITO WARD KULLU

In the result, appeal filed by the Assessee is dismissed

ITA 897/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

For Appellant: Shri Vinamar Gupta, C.A (Virtually)For Respondent: Shri Manav Bansal, CIT, DR
Section 147Section 148Section 151ASection 263Section 270A

…upon Allahabad High Court decisions rendered in the year 2005 and ignoring the jurisprudence laid before and thereafter. 4. That the Learned CIT has erred in law and facts and circumstances of the case by ignoring supreme court decision in Vegetable Products 88 ITR 192. 5. That the Learned CIT has erred in law and facts and circumstances of the case by directing to revise order which is void ab initio because assessment has been carried out in violation of Notification dated 29-03-2022 issued u/s 151A. 4. Briefly stated, the assessment was completed by the Assessing Officer, determining the income of the assess…

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 494/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh24 Feb 2026AY 2013-14

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

Section 143(3)Section 263

…ight Corridor Corporation Ltd. It was also submitted that where more than one interpretation has been pronounced by Jurisdictional High Court then Interpretation which favors the assessee have to be adopted. Reliance placed on CIT vs Vegetable Products Ltd in 88 ITR 192 (SC). v) 29.10.2020 Assessment completed u/s 143(3) r.w.s 143(3A) & 143(3B) of the Act on 29.10.2020 accepting returned income. (30-31) vi) 23.02.2021 Order passed u/s 154 of the Act rectifying interest payable u/s 244A of the Act. (33-34) vii) Proposal sent by ITO, Sirsa to initiate proceedings u/s 263 of the Act. (Page 465-466 of JPB) viii) 16.0…

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