COMMISSIONER OF INCOME TAX & ANOTHER v. RANKA & RANKA

352 ITR 121High Court2013#7426 most cited

What is COMMISSIONER OF INCOME TAX & ANOTHER v. RANKA & RANKA authority for?

Circulars issued by the Central Board of Direct Taxes are generally applicable to pending proceedings, even if initially argued to be prospective. However, a specific instruction (Instruction 3/11) was held to be prospective in nature.

15

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2013 to 2025.

Also referred to as

COMMISSIONER OF INCOME TAX & ANOTHER v. RANKA & RANKA · 352 ITR 121 · CBDT circular · prospective · pending proceedings · Instruction 3/11

Judgments citing COMMISSIONER OF INCOME TAX & ANOTHER v. RANKA & RANKA

M/S.P.Satyanarayana and Sons vs. Income Tax Officer, Ward 1[9], Hyderabad

ITTA/209/2008HC Telangana08 Sept 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Commissioner of Income Tax vs. Sri M.R.Jayaram (HUF)

Appeal stands dismissed as not maintainable in view of aforestated

WTA/13/2015HC Karnataka29 Jan 2020

Bench: ARAVIND KUMAR,E.S.INDIRESH

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

Commissioner of Income Tax vs. M.R.Anandaram (HUF)

Appeal stands dismissed as not maintainable in view of aforestated

WTA/15/2015HC Karnataka29 Jan 2020

Bench: ARAVIND KUMAR,E.S.INDIRESH

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

Commissioner of Income Tax vs. M.R.Anandaram (HUF)

Appeal stands dismissed as not maintainable in view of aforestated

WTA/18/2015HC Karnataka29 Jan 2020

Bench: ARAVIND KUMAR,E.S.INDIRESH

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

Commissioner of Income Tax vs. Sri M.R.Janakiram (HUF)

Appeal stands dismissed as not maintainable in view of aforestated

WTA/20/2015HC Karnataka29 Jan 2020

Bench: ARAVIND KUMAR,E.S.INDIRESH

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

Commissioner of Income Tax vs. Sri M.R.Sampangiramaiah(Indl)

Appeal stands dismissed as not maintainable in view of aforestated

WTA/29/2015HC Karnataka29 Jan 2020

Bench: ARAVIND KUMAR,E.S.INDIRESH

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

M/S Cgi Information Systems and Management Consultants Private Limited, Bangalore vs. Deputy Commissioner of Income Tax (International Taxation) Circle-1(1), Bangalore

In the result, the appeals of assessee for Assessment Years 2010-11 and 2011-12 are dismissed

ITA 2832/BANG/2018[2010-11]Status: DisposedITAT Bangalore09 Aug 2019AY 2010-11

Bench: Shri A.K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri Pradeep Kumar, CIT (D.R)
Section 201Section 201(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “ C ” BENCH: BANGALORE BEFORE SHRI A.K. GARODIA, ACCOUNTANT MEMBER AND SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER ITA. Nos.2832 & 2833/Bang/2018 (Assessment Years : 2010-11 & 2011-12) M/s. CGI Information Systems & Management Consultants Private Limited, E-City Tower, No.95/1 & 95/2, Electronic City Phase 1 (West), Bangalore-560 100 ….Appellant. PAN AAACII994C Vs. Dy. Commissioner of Income Tax (I.T), Circle 1(1), Bangalore. ….Respondent. Assessee By: Smt. Tanmayee Rajkumar, Advocate. Revenue By: Shri Pradeep Kumar, CIT (D.R) Date of Hearing : 16.07.2019 Date…

The Commissioner vs. M/S Ask Brothers Ltd

Appeal stands dismissed as not maintainable in view of aforestated

ITA/9/2015HC Karnataka19 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

M/S Metal Closures Pvt Ltd vs. The Deputy Commissioner of Income-Tax

Appeal stands dismissed as not maintainable in view of aforestated

ITA/24/2015HC Karnataka12 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

Official Liquidator

Appeal stands dismissed as not maintainable in view of aforestated

OLR/12/2016HC Karnataka02 Sept 2016

Bench: L.NARAYANA SWAMY

Section 27

…and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case of DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of…

The Commissioner of Income Tax vs. M/S Dtdc Courier & Cargo Ltd

Appeal stands dismissed as not maintainable in view of aforestated

ITA/15/2015HC Karnataka18 Dec 2015

Bench: S.SUJATHA,VINEET SARAN

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

The Commissioner vs. M/S Igate Global Solutions Ltd

Appeal stands dismissed as not maintainable in view of aforestated

ITA/13/2015HC Karnataka11 Aug 2015

Bench: B.MANOHAR,VINEET SARAN

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

Emudhra Limited

Appeal stands dismissed as not maintainable in view of aforestated

COP/23/2015HC Karnataka23 Apr 2015

Bench: L.NARAYANA SWAMY

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

Magna Infotech Limited

Appeal stands dismissed as not maintainable in view of aforestated

COP/29/2015HC Karnataka22 Apr 2015

Bench: A.S.BOPANNA

Section 27

…prospective and cannot be made applicable to the pending matters, which we are not inclined to accept in the light of law laid down by Coordinate Bench of this Court in the case of COMMISSIONER OF INCOME TAX & ANOTHER V/S RANKA & RANKA reported in (2013) 352 ITR 121 (KARN), wherein it has been held that scope of Circular issued by Central Board of Direct Taxes would be applicable to the pending proceedings, which also came to be affirmed by Apex Court in the case DIRECTOR OF INCOME TAX V/S S.R.M.B DAIRY FARMING (P) LTD. reported in (2018) 400 ITR 9 (SC) vide paragraph 23. In fact, Central Board of Di…

The Commr of Income Tax vs. Sri N L Hamirwasia

The appeal is dismissed, subject to

ITA/141/2007HC Karnataka22 Apr 2013

Bench: B.MANOHAR,N.KUMAR

Section 260A

…U D G M E N T This appeal is preferred by the Revenue. 2. The net tax effect in this appeal is Rs.5,57,925-00. In view of the judgment of this Court in the case of COMMISSIONER OF INCOMET-TAX AND ANOTHER Vs. RANKA & RANKA reported in (2013) 352 ITR 121 (Kar), 3 wherein this Court held that the benefit granted under Instruction 3/11 is prospective in nature, this appeal is not maintainable. Accordingly the appeal is dismissed, subject to the condition that in the event, the Apex Court reversing the aforesaid judgment, the appellant is at liberty either to revive this app…

COMMISSIONER OF INCOME TAX & ANOTHER v. RANKA & RANKA (352 ITR 121) — Cited in 15 Judgments | BharatTax