(CWT v. Sharvan Kumar Swarup & Sons.

210 ITR 886Supreme Court of India1994#1530 most cited

What is (CWT v. Sharvan Kumar Swarup & Sons. authority for?

Procedural amendments do not create a vested right and therefore apply to pending matters, including those related to periods prior to the amendment's effective date.

74

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2023.

Also referred to as

CWT v. Sharvan Kumar Swarup & Sons · section 200A · section 234E · no vested right in procedure · retrospective application of law · procedural amendments · applicability to pending matters · TDS statement processing · late filing fees · 1994 Supreme Court

Issues it is cited on

section 234e(1)section 200a(1)(c)section 254(2)section 200a(1)section 200(3)section 200asection 234esection 254(1)section 200tax deducted at sourcesection 20section 234

Judgments citing (CWT v. Sharvan Kumar Swarup & Sons.

KERALA GRAMIN BANK, UDIYANKULANGARA BRANCH,THIRUVANANTHAPURAM vs. THE ITO WARD TDS, TRIVANDRUM, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee are allowed

ITA 835/COCH/2022[2013-2014(24Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, OMALLOOR BRANCH,PATHANAMTHITTA vs. THE ITO WARD TDS, TRIVANDRUM, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee are allowed

ITA 834/COCH/2022[2013-2014(24Q,Q1)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, OMALLOOR BRANCH,PATHANAMTHITTA vs. THE ITO WARD TDS, TRIVANDRUM, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee are allowed

ITA 833/COCH/2022[2013-2014(24Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, IRULAM BRANCH,WAYANAD vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 832/COCH/2022[2013-2014(26Q,Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, IRULAM BRANCH,WAYANAD vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 831/COCH/2022[2013-2014(24Q,Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, IRULAM BRANCH,WAYANAD vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 830/COCH/2022[2013-2014(24Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, IRULAM BRANCH,WAYANAD vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 829/COCH/2022[2013-2014(26Q, Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, ULLIYERI BRANCH,KOZHIKODE vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 828/COCH/2022[2013-2014(27Q,Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, ULLIYERI BRANCH,KOZHIKODE vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 826/COCH/2022[2013-2014 (24Q, Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, ULLIYERI BRANCH,KOZHIKODE vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 825/COCH/2022[2013-2014(26Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, ULLIYERI BRANCH,KOZHIKODE vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 824/COCH/2022[2013-2014(24Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, ULLIYERI BRANCH,KOZHIKODE vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 823/COCH/2022[2013-2014(26Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, ULLIYERI BRANCH,KOZHIKODE vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 822/COCH/2022[2013-2014(24Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, OTHUKKUNGAL BRANCH,MALAPPURAM vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 821/COCH/2022[2013-2014(26Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, OTHUKKUNGAL BRANCH,MALAPPURAM vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 820/COCH/2022[2013-2014(24Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, IRUMBUZHI BRANCH,MALAPPURAM vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 819/COCH/2022[2013-2014(26Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, IRUMBUZHI BRANCH,MALAPPURAM vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 818/COCH/2022[2013-2014(24Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, IRUMBUZHI BRANCH,MALAPPURAM vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 817/COCH/2022[2013-2014(26Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, IRUMBUZHI BRANCH,MALAPPURAM vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 816/COCH/2022[2013-2014(24Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

KERALA GRAMIN BANK, UNNIKULAM BRANCH,KOZHIKODE vs. THE ITO WARD TDS, KOZHIKODE, KOZHIKODE

In the result, the appeals filed by the assessee are allowed

ITA 815/COCH/2022[2013-2014(26Q,Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

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