Commissioner of Income\nTax, Chennai v. Alagendran Finance Ltd.

7 SCC 215Reported decision2007#21267 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 341,001 Indian tax judgments — from 2025 to 2025.

Sections most often in play

Section 143(2)Section 147 Section 263 Section 115JB Section 139(1)Section 143(3)Section 144 Section 144B

Issues it is cited on

regular assessment erroneous and prejudicial section 263 section 26 scrutiny assessment section 139(1)section 139 section 143(2)section 13 section 147 section 144 section 143

Judgments citing Commissioner of Income\nTax, Chennai v. Alagendran Finance Ltd.

Mahakali Developers and Resorts Private Limited, Scf vs. PCIT Patiala, Aaykar Bhawan

Appeals of the assessee are allowed

ITA 295/CHANDI/2024[2015-2016]Status: DisposedITAT Chandigarh24 Feb 2025AY 2015-2016

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Ashok Goel, CAFor Respondent: Smt. Kusum Bansal, CIT, DR

Section 139(1)Section 143(2)Section 143(3)Section 144Section 147Section 24Section 24(1)Section 263

…ithin the limitation as contemplated in sub-clause (2) of Section 263 of the Income Tax Act. In support of his contention, he relied upon judgement of Hon'ble Supreme Court in the case of Commissioner of Income Tax, Chennai Vs Alagendran Finance Ltd. (2007) 7 SCC 215. This judgement has subsequently been followed by the Hon'ble Supreme Court in the case of CIT Mumbai Vs Industrial Development Bank of India Ltd. He placed on record copy of the Hon'ble Supreme Court’s decision in the case of Industrial Development Bank of India Ltd. which is reported in 454 ITR 811. According to the ld. Counsel for the assessee…

Mahakali Developers and Resorts Private Limites, Scf, Ist Floor vs. PCIT Patiala, Aaykar Bhawan Patiala

Appeals of the assessee are allowed

ITA 294/CHANDI/2024[2013-2014]Status: DisposedITAT Chandigarh24 Feb 2025AY 2013-2014

For Appellant: Shri Ashok Goel, CAFor Respondent: Smt. Kusum Bansal, CIT, DR

Section 139(1)Section 143(2)Section 143(3)Section 144Section 147Section 24Section 24(1)Section 263

…within the limitation as contemplated in sub-clause (2) of Section 263 of the Income Tax Act. In support of his contention, he relied upon judgement of Hon'ble Supreme Court in the case of Commissioner of Income Tax, Chennai Vs Alagendran Finance Ltd. (2007) 7 SCC 215. This judgement has subsequently been followed by the Hon'ble Supreme Court in the case of CIT Mumbai Vs Industrial Development Bank of India Ltd. He placed on record copy of the Hon'ble Supreme Court's decision in the case of Industrial Development Bank of India Ltd. which is reported in 454 ITR 811. According to the ld. Counsel for the assessee,…

Hsbc Securities and Capital Markets (India) Private Limited, Mumbai vs. Principal Commissioner of Income-Tax, Mumbai-4, Mumbai

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

ITA 2586/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Feb 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: Ms. Krupa Gandhi, Ld. A.RFor Respondent: Shri Biswanath Das, Ld. D.R

Section 115JSection 143(3)Section 147Section 14ASection 154Section 263

…52 taxmann.com 591) (Refer pg. no. 47 to 49 of LPB) relying on Alagendran Finance Ltd. (supra) held that: "3.... We are fortified with our view by the decision of this Court in the case of CIT v. Alagendran Finance Ltd. [2007] 162 Taxman 465/293 ITR 1/[2007] 7 SCC 215. As observed and held by this Court in the aforesaid decision, once an Order of Assessment is reopened, the previous order of assessment will be held to be set aside and the whole proceedings would start afresh but the same would not mean that even when the subject matter of reassessment is distinct and different, the entire proceedings of assessme…

Shiv Vegpro Private Limited, Kota vs. PCIT-Udaipur, Udaipur

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

ITA 1014/JPR/2024[2017-18]Status: DisposedITAT Jaipur28 Jan 2025AY 2017-18

For Appellant: Shri Mahendra Gargieya, (Adv.) &For Respondent: Mrs. Alka Gautam, (CIT-DR)

Section 147Section 263Section 36(1)(iii)Section 36(1)(va)Section 43B

…nd, therefore, the limitation would start from the original Assessment Order and not from the Reassessment Order. We are fortified with our view by the decision of this Court in the case of Commissioner of Income Tax, Chennai v. Alagendran Finance Ltd. (2007) 7 SCC 215. As observed and held by this Court in the aforesaid decision, once an Order of Assessment is re-opened, the previous order of assessment will be held to be set aside and the whole proceedings would start afresh but the same would not mean that even when the subject matter of re-assessment is distinct and different, the entire proceedings of assess…