Commissioner of Income Tax v. Excel Industries

13 SCC 459Supreme Court of India2014#2779 most cited

What is Commissioner of Income Tax v. Excel Industries authority for?

An issue or fundamental aspect settled in one assessment year cannot be disturbed or reconsidered by the Revenue in subsequent assessment years if there is no change in the underlying facts or circumstances.

43

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2025.

Also referred to as

CIT v. Excel Industries · rule of consistency · issue settled · subsequent assessment year · no change in circumstances · Section 147 · Section 148 · Section 143(3) · Section 2(15) · Revenue taking different view · fundamental aspect · assessment procedure

Also reported as

262 CTR 261

Sections most often in play

Section 11Section 12Section 143(3)Section 2(15)Section 144C(13)Section 144C(5)Section 147Section 148

Issues it is cited on

section 2(19aa)section 293section 10(2)(xv)section 10(2)section 2(47)(v)legal expensessection 49section 39transferee companysection 53asection 2(47)section 53

Judgments citing Commissioner of Income Tax v. Excel Industries

ACIT CIRCLE-1(1) (E)NEW DELHI, DELHI vs. DELHI BUREAU OF TEXT BOOKS, DELHI

In the result, both the appeals of the Revenue are dismissed

ITA 1115/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalacit, Delhi Bureau Of Text Books Circle-1(1), 25/2 Institutional Area, New Delhi. Vs. Pankha Road, D Block, Janak Puri, Delhi-110058 Pan-Aaatd4122G (Appellant) (Respondent) Assessee By None Department By Ms. Suman Malik, Cit-Dr Date Of Hearing 02/06/2025 Date Of Pronouncement 02/06/2025 O R D E R Per Manish Agarwal, Am: Both The Appeals Are Filed By The Revenue Against The Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Appeal No. Cit(A), Delhi-40/10313/2018-19 & Appeal No. Nfac/2016- 17/10028873 For Assessment Year 2016-17 & 2017-18 Respectively.

Section 11Section 12

…ined in Parashuram Pottery Works Ltd. vs. Income Tax Officer (1977) 106 ITR 1 (SC), Radhasoami Satsang Saomi Bagh vs. Commissioner of Income Tax (1992) 193 ITR 321 (SC), Hoystead vs. Commissioner of Taxation (1926) AC 155 (PC), CIT vs. Excel Industries (2013) 262 CTR 261 (SC) the Hon'ble High Court held that the Revenue in the absence of any change of circumstances cannot take a different view from that taken in the earlier years. Now turning to the case on hand it is not the case of Revenue that any change in the circumstances had taken place. We, therefore, while respectfully following the decision of the Hon'b…

ACIT CIRCLE-1(1) (E) NEW DELHI, DELHI vs. DELHI BUREAU OF TEXT BOOKS, DELHI

In the result, both the appeals of the Revenue are dismissed

ITA 1114/DEL/2024[2016-17]Status: DisposedITAT Delhi18 Jun 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalacit, Delhi Bureau Of Text Books Circle-1(1), 25/2 Institutional Area, New Delhi. Vs. Pankha Road, D Block, Janak Puri, Delhi-110058 Pan-Aaatd4122G (Appellant) (Respondent) Assessee By None Department By Ms. Suman Malik, Cit-Dr Date Of Hearing 02/06/2025 Date Of Pronouncement 02/06/2025 O R D E R Per Manish Agarwal, Am: Both The Appeals Are Filed By The Revenue Against The Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Appeal No. Cit(A), Delhi-40/10313/2018-19 & Appeal No. Nfac/2016- 17/10028873 For Assessment Year 2016-17 & 2017-18 Respectively.

Section 11Section 12

…ined in Parashuram Pottery Works Ltd. vs. Income Tax Officer (1977) 106 ITR 1 (SC), Radhasoami Satsang Saomi Bagh vs. Commissioner of Income Tax (1992) 193 ITR 321 (SC), Hoystead vs. Commissioner of Taxation (1926) AC 155 (PC), CIT vs. Excel Industries (2013) 262 CTR 261 (SC) the Hon'ble High Court held that the Revenue in the absence of any change of circumstances cannot take a different view from that taken in the earlier years. Now turning to the case on hand it is not the case of Revenue that any change in the circumstances had taken place. We, therefore, while respectfully following the decision of the Hon'b…

INCOME TAX OFFICER, PARWANOO, H.P vs. DEYEM INDUSTRY, NALAGARH SOLAN

In the result, appeal of the Revenue is dismissed

ITA 708/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh09 Jun 2025AY 2012-13

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 708/Chd/2023 निर्धारण वर्ष / Assessment Year : 2012-13 The ITO Parwanoo, Himachal Pradesh बनाम DEYEM INDUSTRY Nalagarh, Ropar Road Near Hazat Khana, Nalagarh, H.P.- 174101 स्थायी लेखा सं./ PAN NO: AAGFD0437L अपीलार्थी/ Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Ankit Awal, Ms. Khushbu Sood, Advocates राजस्व की ओर से/ Revenue by : Shri Rohit Sharma, CIT DR (Virtual) सुनवाई की ता

For Appellant: Shri Ankit Awal & Ms. Khushbu Sood, AdvocatesFor Respondent: Shri Rohit Sharma, CIT DR (Virtual)
Section 143(3)Section 147Section 2(47)Section 271(1)(c)Section 53A

…आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ “ए” , च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: HYBRID MODE "ी लिलत कुमार, "ाियक सद" एवं "ी कृणव" सहाय, लेखा सद" BEFORE: SHRI. LALIET KUMAR, JM & SHRI. KRINWANT SAHAY, AM आयकर अपील सं./ ITA No. 708/Chd/ 2023 िनधा"रण वष" / Assessment Year : 2012-13 The ITO बनाम DEYEM INDUSTRY Parwanoo, Himachal Pradesh Nalagarh, Ropar Road Near Hazat Khana, Nalagarh, H.P.- 174101 "ायी लेखा सं./PAN NO: AAGFD0437L अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Shri Ankit Awal & Ms. Khushbu Sood, Advocates राज" की ओर से/ Revenue b…

ACIT, CIRCLE-12(2), NEW DELHI vs. INNOVATIONS INDIA ADVERTISING AND EVENT PVT. LTD., NEW DELHI

In the result, appeal of Revenue in ITA No

ITA 534/DEL/2020[2015-16]Status: DisposedITAT Delhi09 Apr 2025AY 2015-16

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Alok Bhachawat, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 37(1)

…for the proposition that notes on accounts forms part of balance sheet: 1. Bihar Vs. Ziqitza health Care Ltd 246 Comp Cas 180 2. CIT Vs. Shoorji Vallabhdas and Co. [1962] 46 ITR144 3. Godhra Electricity Co. Vs. CIT 4 SCC 530 4. CIT Vs. Excel Industries Ltd 13 SCC 459 10. We have heard the rival submissions and have perused the relevant material on record. We find that there is an entry by way of notes to the Account in the balance sheet with regard to receipt of Rs. 4.37 crore and expenses of Rs. 4.22 crore on account of conducting an event at Norway. The relevant extract from the Notes to Accounts under Re…

DCIT (LTU), NEW DELHI vs. M/S. MAWANA SUGAR LTD., NEW DELHI

In the result, all the appeals filed by the Revenue for AYs 2006-07, 2012-

ITA 6081/DEL/2016[2012-13]Status: DisposedITAT Delhi26 Mar 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: Shri Taran Deep Singh, AdvocateFor Respondent: Ms. Baljeet Kaur, CIT DR
Section 2Section 2(47)Section 391

…the years under consideration. Support in this regard was ITA No.457& 5830/DEL/2016 ITA No.5489 to 5490/DEL/2018 ITA No.516 & 6081/DEL/2016 ITA No.5835 & 5836/DEL/2018 drawn from the decision of Apex Court in case of CIT vs Excel Industries reported in (2014) 13 SCC 459 and PCIT vs Power Links Transmission reported in 287 Taxman 327(DEL). In Excel Industries it was held by Hon’ble Apex Court as under: “25. In Radhasoami Satsang v. CIT this Court did not think it appropriate to allow the reconsideration of an issue for a subsequent assessment year if the same “fundamental aspect” permeates in different assessment…

SIEL LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the appeals filed by the Revenue for AYs 2006-07, 2012-

ITA 6301/DEL/2015[2011-12]Status: DisposedITAT Delhi26 Mar 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: Shri Taran Deep Singh, AdvocateFor Respondent: Ms. Baljeet Kaur, CIT DR
Section 2Section 2(47)Section 391

…the years under consideration. Support in this regard was ITA No.457& 5830/DEL/2016 ITA No.5489 to 5490/DEL/2018 ITA No.516 & 6081/DEL/2016 ITA No.5835 & 5836/DEL/2018 drawn from the decision of Apex Court in case of CIT vs Excel Industries reported in (2014) 13 SCC 459 and PCIT vs Power Links Transmission reported in 287 Taxman 327(DEL). In Excel Industries it was held by Hon’ble Apex Court as under: “25. In Radhasoami Satsang v. CIT this Court did not think it appropriate to allow the reconsideration of an issue for a subsequent assessment year if the same “fundamental aspect” permeates in different assessment…

SIEL LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the appeals filed by the Revenue for AYs 2006-07, 2012-

ITA 6300/DEL/2015[2003-04]Status: DisposedITAT Delhi26 Mar 2025AY 2003-04

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: Shri Taran Deep Singh, AdvocateFor Respondent: Ms. Baljeet Kaur, CIT DR
Section 2Section 2(47)Section 391

…the years under consideration. Support in this regard was ITA No.457& 5830/DEL/2016 ITA No.5489 to 5490/DEL/2018 ITA No.516 & 6081/DEL/2016 ITA No.5835 & 5836/DEL/2018 drawn from the decision of Apex Court in case of CIT vs Excel Industries reported in (2014) 13 SCC 459 and PCIT vs Power Links Transmission reported in 287 Taxman 327(DEL). In Excel Industries it was held by Hon’ble Apex Court as under: “25. In Radhasoami Satsang v. CIT this Court did not think it appropriate to allow the reconsideration of an issue for a subsequent assessment year if the same “fundamental aspect” permeates in different assessment…

THE COMMISSIONER OF INCOME TAX III, vs. M/S. SAVIJANA SEA FOODS PVT. LTD.,

Appeals of the Revenue are dismissed

ITTA/55/2010HC Telangana20 Dec 2024

Bench: J SREENIVAS RAO,ALOK ARADHE

Section 260

…plained by the Supreme Court in Parashuram Pottery Works Ltd. v. Income Tax Officer, [1977] 106 ITR 1 (SC) and Radhasoami Satsang Saomi Bagh v. Commissioner of Income Tax, [1992] 193 ITR 321 (SC) was reiterated by it in CIT v. Excel Industries Ltd. (2014) 13 SCC 459 in the following manner: 31. It appears from the record that in several assessment years, the Revenue accepted the order of the Tribunal in favour of the assessee and did not pursue the matter any further but in respect of some assessment years the matter was taken up in appeal before the Bombay High Court but without any success. That bein…

VENKAT RAJASEKHAR KONERU,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(1), HYDERABAD

In the result, all the appeals of the assessees are dismissed

ITA 627/HYD/2022[2016-17]Status: DisposedITAT Hyderabad22 Oct 2024AY 2016-17

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Shri M. Chandramouleswara RaoFor Respondent: Shri Srinath Sadanala, Sr.AR
Section 132Section 139(4)Section 142(1)Section 143(2)Section 153C

…less and until there is created in favour of the assessee a debt due by somebody it cannot be said that he has acquired a right to receive the income or that income has accrued to him.” 26. This Court, in Commissioner of Income Tax v. Excel Industries, (2014) 13 SCC 459 at 463-464 referred to various judgments on the expression “accrues”, and then held: “14. First of all, it is now well settled that income tax cannot be levied on hypothetical income. In CIT v. Shoorji Vallabhdas and Co. [CIT v. Shoorji Vallabhdas and Co., (1962) 46 ITR 144 (SC)] it was held as follows: (ITR p. 148) “… Income tax is a levy on inco…

PRAMOD REDDY TEKULA,HYDERABAD vs. ACIT,CENTRAL CIRCLE-1(1), HYDERABAD

In the result, all the appeals of the assessees are dismissed

ITA 611/HYD/2022[2016-17]Status: DisposedITAT Hyderabad22 Oct 2024AY 2016-17

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Shri M. Chandramouleswara RaoFor Respondent: Shri Srinath Sadanala, Sr.AR
Section 132Section 139(4)Section 142(1)Section 143(2)Section 153C

…less and until there is created in favour of the assessee a debt due by somebody it cannot be said that he has acquired a right to receive the income or that income has accrued to him.” 26. This Court, in Commissioner of Income Tax v. Excel Industries, (2014) 13 SCC 459 at 463-464 referred to various judgments on the expression “accrues”, and then held: “14. First of all, it is now well settled that income tax cannot be levied on hypothetical income. In CIT v. Shoorji Vallabhdas and Co. [CIT v. Shoorji Vallabhdas and Co., (1962) 46 ITR 144 (SC)] it was held as follows: (ITR p. 148) “… Income tax is a levy on inco…

BANDI SUDHEER REDDY ,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(4), HYDERABAD

In the result, all the appeals of the assessees are dismissed

ITA 610/HYD/2022[2016-17]Status: DisposedITAT Hyderabad22 Oct 2024AY 2016-17

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Shri M. Chandramouleswara RaoFor Respondent: Shri Srinath Sadanala, Sr.AR
Section 132Section 139(4)Section 142(1)Section 143(2)Section 153C

…less and until there is created in favour of the assessee a debt due by somebody it cannot be said that he has acquired a right to receive the income or that income has accrued to him.” 26. This Court, in Commissioner of Income Tax v. Excel Industries, (2014) 13 SCC 459 at 463-464 referred to various judgments on the expression “accrues”, and then held: “14. First of all, it is now well settled that income tax cannot be levied on hypothetical income. In CIT v. Shoorji Vallabhdas and Co. [CIT v. Shoorji Vallabhdas and Co., (1962) 46 ITR 144 (SC)] it was held as follows: (ITR p. 148) “… Income tax is a levy on inco…

GE SUBSIDIARY INC,63 (SUCCESSOR IN INTEREST OF MONOGRAM LICESING INTERNATIONAL INC.),MUMBAI vs. ACIT (IT) RG. 3 (2)(2), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 5906/MUM/2018[2014-15]Status: DisposedITAT Mumbai26 Jun 2024AY 2014-15

Bench: Shri Amit Shukla & Shri Gagan Goyalge Subsidiary Inc, 63 (Successor In Interest Of Monogram Licensing International Inc.) C/O. Pwc House, Plot No. 18 A, Guru Nanak Station Road, Bandra, Mumbai- 400050 Pan: Aadcm6233F Appellant Vs. Acit (Intl Taxation) - 3(2) (2), Mumbai, Room No. 1615, Air India Building, Nariman Point, Mumbai- 400 021 Respondent

For Appellant: Shri Dhanesh Bafna, Shri PratikFor Respondent: Shri Abhishek Tharwal, Ld. DR
Section 143(3)Section 144C(13)Section 234BSection 92C(3)

…loss actually caused to the exchequer on account of such differences so as to warrant any income addition to the total income of the assessee. We derive support from the decision of the Hon’ble Supreme Court in the case of CIT v. Excel Industries Ltd. [2013] 262 CTR 261 (SC), extract of which is reproduced hereunder: “32. Thirdly, the real question concerning us is the year in which the assessee is required to pay tax. There is no dispute that in the subsequent accounting year, the assessee did make imports and did derive benefits under the advance license and the duty entitlement pass book and paid tax thereo…

JUBHLIEE HILLS INTERNATIONAL CENTRE vs. INCOME TAX OFFICER, HYDERABAD

Appeal is allowed

ITTA/205/2005HC Telangana04 Jan 2023

Bench: N.TUKARAMJI,UJJAL BHUYAN

For Appellant: Mr. Challa GunaranjanFor Respondent: Mr. J.V.Prasad, Standing Counsel
Section 13Section 260A

…ad … Respondent ! Counsel for the Appellant : Mr. Challa Gunaranjan ^ Counsel for Respondent : Mr. J.V.Prasad, Standing Counsel, IT Department < GIST:  HEAD NOTE: ? CASES REFERRED: (2014) 13 SCC 459 (2008) 302 ITR 279 (1997) 5 SCC 394 ::2:: THE HON’BLE THE CHIEF JUSTICE UJJAL BHUYAN AND THE HON’BLE SRI JUSTICE N.TUKARAMJI I.T.T.A.No.205 of 2005 JUDGMENT: (Per the Hon’ble the Chief Justice Ujjal Bhuyan) Heard Mr. Challa Gunaranjan, learned counsel for the appellant and Mr. J.V.Prasad, learned Standing Counsel, Inc…

PCIT, DELHI-7 vs. RATNAGIRI GAS AND POWER PVT. LTD.

ITA/264/2022HC Delhi29 Aug 2022

Bench: HON'BLE MR. JUSTICE RAJIV SHAKDHER,HON'BLE MS. JUSTICE TARA VITASTA GANJU

…Indian Molasses Co. (P) Ltd. vs. CIT, West Bengal (1959) 37 ITR 66; (ii) Commissioner of Income Tax vs. Excel Industries Ltd. (2014) This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003617 ITA 264/2022 Page 4 of 11 13 SCC 459. 10. On the other hand, Mr Ved Kumar Jain, who appears on behalf of the respondent/assessee, has made the following broad submissions: 11. Although the respondent/assessee was remiss in producing the CSA before the AO, it was produced before the Commissioner of Income Tax (Appeals) [in short, “CIT(A)”]. Therefore, this objection no longer…

COMMISSIONER OF INCOME TAX (EXEMPTIONS) DELHI vs. HAMDARD NATIONAL FOUNDATION (INDIA)

ITA/144/2021HC Delhi16 Feb 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MR. JUSTICE NAVIN CHAWLA

Section 11Section 13(2)(b)Section 13(3)

…rather than spend the taxpayers‟ money pursuing the litigation for the sake of it and should abide by the principle of consistency. In support, he places reliance on the following judgments: i. Commissioner of Income Tax v. Excel Industries Ltd., (2014) 13 SCC 459; ii. M/s Radhasoami Satsang, Saomi Bagh, Agra v. Commissioner of Income Tax, (1992) 1 SCC 659; and iii. Berger Paints India Ltd. v. Commissioner of Income Tax, Calcutta, (2004) 12 SCC 42. 17. We have considered the submissions made by the learned counsels for the parties. This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/…

COMMISSIONER OF INCOME TAX (EXEMPTIONS) DELHI vs. HAMDRD NATIONAL FOUNDATION (INDIA)

ITA/115/2021HC Delhi16 Feb 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MR. JUSTICE NAVIN CHAWLA

Section 11Section 13(2)(b)Section 13(3)

…rather than spend the taxpayers‟ money pursuing the litigation for the sake of it and should abide by the principle of consistency. In support, he places reliance on the following judgments: i. Commissioner of Income Tax v. Excel Industries Ltd., (2014) 13 SCC 459; ii. M/s Radhasoami Satsang, Saomi Bagh, Agra v. Commissioner of Income Tax, (1992) 1 SCC 659; and iii. Berger Paints India Ltd. v. Commissioner of Income Tax, Calcutta, (2004) 12 SCC 42. 17. We have considered the submissions made by the learned counsels for the parties. This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/…

DCIT(E), CIRCLE-1(1), NEW DELHI vs. DELHI BUREAU OF TEXT BOOKS, NEW DELHI

The appeal of the Revenue is dismissed

ITA 7075/DEL/2018[2013-14]Status: DisposedITAT Delhi27 Sept 2021AY 2013-14

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Dr. Maninder Kaur, Sr.D.RFor Respondent: Ms. Anubha Malwani, CA
Section 10(23)(c)Section 11Section 12Section 12ASection 2

…ined in Parashuram Pottery Works Ltd. vs. Income Tax Officer (1977) 106 ITR 1 (SC), Radhasoami Satsang Saomi Bagh vs. Commissioner of Income Tax (1992) 193 ITR 321 (SC), Hoystead vs. Commissioner of Taxation (1926) AC 155 (PC), CIT vs. Excel Industries (2013) 262 CTR 261 (SC) the Hon'ble High Court held that the Revenue in the absence of any change of circumstances cannot take a 6 I.T.A. No.7075/DEL/2018 different view from that taken in the earlier years. Now turning to the case on hand it is not the case of Revenue that any change in the circumstances had taken place. We, therefore, while respectfully followin…

ACIT(E), CIRCLE-1(1), NEW DELHI vs. DELHI BUREAU OF TEXT BOOKS, NEW DELHI

In the result, all the appeals of the revenue are dismissed

ITA 242/DEL/2018[2014-15]Status: DisposedITAT Delhi09 Dec 2020AY 2014-15

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 240/Del/2018 : Asstt. Year : 2011-12 Ita No. 241/Del/2018 : Asstt. Year : 2012-13 Ita No. 242/Del/2018 : Asstt. Year : 2014-15 Acit(E), Vs Delhi Bureau Of Text Books, Circle-1(1), 25/2, Institutional Area, Pankha New Delhi Road, D-Block, Janakpuri, New Delhi-110058 (Appellant) (Respondent) Pan No. Aaatd4122G Assessee By : Sh. Amit Kumar Gupta, Adv. Revenue By : Sh. Jagdish Singh, Sr. Dr Date Of Hearing: 24.11.2020 Date Of Pronouncement: 09.12.2020

For Appellant: Sh. Amit Kumar Gupta, AdvFor Respondent: Sh. Jagdish Singh, Sr. DR
Section 10Section 11Section 12ASection 2(15)

…ined in Parashuram Pottery Works Ltd. vs. Income Tax Officer (1977) 106 ITR 1 (SC), Radhasoami Satsang Saomi Bagh vs. Commissioner of Income Tax (1992) 193 ITR 321 (SC), Hoystead vs. Commissioner of Taxation (1926) AC 155 (PC), CIT vs. Excel Industries (2013) 262 CTR 261 (SC) the Hon'ble High Court held that the Revenue in the absence of any ITA Nos. 240 to 242/Del/2018 9 Delhi Bureau of Text Books change of circumstances cannot take a different view from that taken in the earlier years. Now turning to the case on hand it is not the case of Revenue that any change in the circumstances had taken place. We, theref…

ACIT(E), CIRCLE-1(1), NEW DELHI vs. DELHI BUREAU OF TEXT BOOKS, NEW DELHI

In the result, all the appeals of the revenue are dismissed

ITA 241/DEL/2018[2012-13]Status: DisposedITAT Delhi09 Dec 2020AY 2012-13

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 240/Del/2018 : Asstt. Year : 2011-12 Ita No. 241/Del/2018 : Asstt. Year : 2012-13 Ita No. 242/Del/2018 : Asstt. Year : 2014-15 Acit(E), Vs Delhi Bureau Of Text Books, Circle-1(1), 25/2, Institutional Area, Pankha New Delhi Road, D-Block, Janakpuri, New Delhi-110058 (Appellant) (Respondent) Pan No. Aaatd4122G Assessee By : Sh. Amit Kumar Gupta, Adv. Revenue By : Sh. Jagdish Singh, Sr. Dr Date Of Hearing: 24.11.2020 Date Of Pronouncement: 09.12.2020

For Appellant: Sh. Amit Kumar Gupta, AdvFor Respondent: Sh. Jagdish Singh, Sr. DR
Section 10Section 11Section 12ASection 2(15)

…ined in Parashuram Pottery Works Ltd. vs. Income Tax Officer (1977) 106 ITR 1 (SC), Radhasoami Satsang Saomi Bagh vs. Commissioner of Income Tax (1992) 193 ITR 321 (SC), Hoystead vs. Commissioner of Taxation (1926) AC 155 (PC), CIT vs. Excel Industries (2013) 262 CTR 261 (SC) the Hon'ble High Court held that the Revenue in the absence of any ITA Nos. 240 to 242/Del/2018 9 Delhi Bureau of Text Books change of circumstances cannot take a different view from that taken in the earlier years. Now turning to the case on hand it is not the case of Revenue that any change in the circumstances had taken place. We, theref…

ACIT(E), CIRCLE-1(1), NEW DELHI vs. DELHI BUREAU OF TEXT BOOKS, NEW DELHI

In the result, all the appeals of the revenue are dismissed

ITA 240/DEL/2018[2011-12]Status: DisposedITAT Delhi09 Dec 2020AY 2011-12

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 240/Del/2018 : Asstt. Year : 2011-12 Ita No. 241/Del/2018 : Asstt. Year : 2012-13 Ita No. 242/Del/2018 : Asstt. Year : 2014-15 Acit(E), Vs Delhi Bureau Of Text Books, Circle-1(1), 25/2, Institutional Area, Pankha New Delhi Road, D-Block, Janakpuri, New Delhi-110058 (Appellant) (Respondent) Pan No. Aaatd4122G Assessee By : Sh. Amit Kumar Gupta, Adv. Revenue By : Sh. Jagdish Singh, Sr. Dr Date Of Hearing: 24.11.2020 Date Of Pronouncement: 09.12.2020

For Appellant: Sh. Amit Kumar Gupta, AdvFor Respondent: Sh. Jagdish Singh, Sr. DR
Section 10Section 11Section 12ASection 2(15)

…ined in Parashuram Pottery Works Ltd. vs. Income Tax Officer (1977) 106 ITR 1 (SC), Radhasoami Satsang Saomi Bagh vs. Commissioner of Income Tax (1992) 193 ITR 321 (SC), Hoystead vs. Commissioner of Taxation (1926) AC 155 (PC), CIT vs. Excel Industries (2013) 262 CTR 261 (SC) the Hon'ble High Court held that the Revenue in the absence of any ITA Nos. 240 to 242/Del/2018 9 Delhi Bureau of Text Books change of circumstances cannot take a different view from that taken in the earlier years. Now turning to the case on hand it is not the case of Revenue that any change in the circumstances had taken place. We, theref…

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