DCIT v. Padinjarekkara Agencies Ltd. (

108 TTJ 152Income Tax Appellate Tribunal2007#2756 most cited

What is DCIT v. Padinjarekkara Agencies Ltd. ( authority for?

Additional grounds of appeal raised by the revenue may not be admitted if they are not germane to the assessment.

42

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2026.

Also referred to as

DCIT v. Padinjarekkara Agencies Ltd. · additional grounds of appeal · revenue appeal · admission of grounds · assessment procedure

Sections most often in play

Section 143(3)Section 133ASection 147Section 148Section 151Section 270ASection 41(1)Section 69C

Issues it is cited on

section 135asection 2(40)section 253(2)within four yearssection 135approval under section 151penalty under section 270ainfrastructure facilitysection 153(3)section 131(1a)section 41(1)section 144ba

Judgments citing DCIT v. Padinjarekkara Agencies Ltd. (

Poonam Lohia, New Delhi vs. ACIT Central Circle-2, Delhi, New Delhi

In the result, the Assessee’s appeal is allowed

ITA 3466/DEL/2025[2015-16]Status: DisposedITAT Delhi05 Feb 2026AY 2015-16

Bench: Shri Mahavir Singh & Shri Amitabh Shuklaasstt. Year : 2015-16 Poonam Lohia, Vs. Acit, Cc-3, Delhi 244/3-C, P.K. Road, Room No. 363, Ara Railway Officers Enclave, Centre, E-2 New Delhi – 110001 Jhandewalan Extn., (Pan: Aaapl0656M) New Delhi – 55

For Appellant: Sh. Ajay Wadhwa, Adv., Sh. Deepanshu KaushikFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 153CSection 153DSection 254(1)

…on the anvil of the decisions of the Hon’ble Apex Court in the case of CIT vs. Varas International, reported in 294 ITR 80 (SC), National Thermal Power Co. Ltd. vs. CIT reported in 229 ITR 383 (SC) and the Special Bench decision in DHL Operators, reported in 108 TTJ 152 (SB). i. That on the facts and circumstances of the case and in law, the CIT(A) has grossly erred in upholding the assessment framed under section 153C of the Act, without appreciating that the mandatory condition precedent of recording a valid satisfaction by the jurisdictional AO was not fulfilled. In the absence of any satisfaction demonstrat…

Deputy Commissioner of Income Tax, Central Circle-1, Rajkot vs. Classic Network Pvt. Ltd., Rajkot

In the result, appeal filed by the assessee in ITA No

ITA 287/RJT/2024[2016-17]Status: DisposedITAT Rajkot30 Jan 2026AY 2016-17

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

Deputy Commissioner of Income Tax, Central Circle-1, Rajkot vs. Classic Network Pvt. Ltd., Rjakot

In the result, appeal filed by the assessee in ITA No

ITA 286/RJT/2024[2014-15]Status: DisposedITAT Rajkot30 Jan 2026AY 2014-15

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

Classic Network Private Limited, Rajkot vs. Deputy Commissioner of Income Tax, Central -1, Rajkot

In the result, appeal filed by the assessee in ITA No

ITA 178/RJT/2024[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

Classic Network Private Limited, Rajkot vs. Deputy Commissioner of Income Tax, Central - 1, Rajkot

In the result, appeal filed by the assessee in ITA No

ITA 177/RJT/2024[2016-17]Status: DisposedITAT Rajkot30 Jan 2026AY 2016-17

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

Classic Network Private Limited, Rajkot vs. The Deputy Commissioner of Income Tax, Central -1 Rajkot, Rajkot

In the result, appeal filed by the assessee in ITA No

ITA 176/RJT/2024[2014-15]Status: DisposedITAT Rajkot30 Jan 2026AY 2014-15

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 291/RJT/2022[2019-20]Status: DisposedITAT Rajkot30 Jan 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 290/RJT/2022[2018-19]Status: DisposedITAT Rajkot30 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 289/RJT/2022[2015-16]Status: DisposedITAT Rajkot30 Jan 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 288/RJT/2022[2013-14]Status: DisposedITAT Rajkot30 Jan 2026AY 2013-14

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

The Deputy Commissioner of Income Tax, Central Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 275/RJT/2022[2019-20]Status: DisposedITAT Rajkot30 Jan 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

The Deputy Commissioner of Income Tax, Central Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 274/RJT/2022[2018-19]Status: DisposedITAT Rajkot30 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 273/RJT/2022[2015-16]Status: DisposedITAT Rajkot30 Jan 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 3/RJT/2021[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

The Assistant Commissioner of Income Tax, Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 13/RJT/2021[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

…any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas Internation reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC) and Special Bench decision in the case of DHL Operators reported in 108 TTJ 152(SB). Keeping in view the facts and circumstances of the present case, we are of the view that the issue raised Page 18of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) in 'additional ground' regarding challenging the reassessment proceedings under section 147/148 of the Act, goes to the root of the matte…

Krishan Kumar Goel, Ghaziabad vs. DCIT, Central Circle, Ghaziabsad

In the result, the Assessee’s appeal is allowed

ITA 4109/DEL/2018[2012-13]Status: DisposedITAT Delhi23 May 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri Manish Agarwalasstt. Year : 2012-13 Krishan Kumar Goel, Vs. Dcit, Central Circle 18, Rama Krishna Colony, Ghaziabad Model Town, G.T. Road, Ghaziabad- 201001 Uttar Pradesh (Pan: Aegpg4936H) (Appellant) (Respondent) Appellant By : None Respondent By : Sh. Dayainder Singh Sidhu, Cit(Dr) Date Of Hearing 19.05.2025 Date Of Pronouncement 23.05.2025 Order

For Appellant: NoneFor Respondent: Sh. Dayainder Singh Sidhu, CIT(DR)
Section 131Section 132Section 143(2)Section 153ASection 153CSection 153DSection 153d

…on the anvil of the decisions of the Hon’ble Apex Court in the case of CIT vs. Varas International, reported in 294 ITR 80 (SC), National Thermal Power Co. Ltd. vs. CIT reported in 229 ITR 383 (SC) and the Special Bench decision in DHL Operators, reported in 108 TTJ 152 (SB). i. That in view of the facts and circumstances of the case and in law, the assessment orders were passed under section 153A/143(3) without seeking mandatory approval under section 153D of the Act. ii. Without prejudice to the aforesaid, the approval under section 153D of the Act is mechanical, without any application of mind, without perusi…

Niit Technologies Ltd., New Delhi vs. DCIT, Circle-18(2), New Delhi

In the result, the Assessee’s appeal is allowed

ITA 4109/DEL/2017[2011-12]Status: DisposedITAT Delhi23 Apr 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri Manish Agarwal

For Appellant: NoneFor Respondent: Sh. Dayainder Singh Sidhu, CIT(DR)
Section 131Section 132Section 143(2)Section 153ASection 153CSection 153DSection 153d

…the anvil of the decisions of the Hon’ble Apex Court in the case of CIT vs. Varas International, reported in 294 ITR 80 (SC), National Thermal Power Co. Ltd. vs. CIT reported in 229 ITR 383 (SC) and the Special Bench decision in DHL Operators, reported in 108 TTJ 152 (SB). i. iii. That in view of the facts and circumstances of the case and in law, the assessment orders were passed under section 153A/143(3) without seeking mandatory approval under section 153D of the Act. Without prejudice to the aforesaid, the approval under section 153D of the Act is mechanical, without any application of mind, without p…

M/S. Impact Forging, Rajkot vs. The Deputy Commissioner of Income Tax, Central Circle-1, Rajkot

In the result, the appeal of the assessee is partly allowed

ITA 311/RJT/2018[2015-16]Status: DisposedITAT Rajkot08 Nov 2023AY 2015-16

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

For Appellant: Shri P.C Yadav, A.RFor Respondent: Shri Shramdeep Sinha, Sr.D.R
Section 153DSection 254Section 271(1)(c)Section 274

…appellant seeks to rely on the judgments of Apex Court in the case of CIT Vs Varas International reported in 284 ITR 80(SC) and NATIONAL THERMAL POWER CO. LTD vs. CIT reported in 229 ITR 383(SC). Special Bench decision in the case of DHL operators reported in 108 TTJ 152(SB). 7. It is further relevant to mention here that the assessee had not raise these grounds categorically at the time of filing of appeal since the assessee was of the firm belief that the Approval of Additional Commissioner as stipulated in section 153D was in consonance with the provisions of law. However the assessee came to know the fact tha…

M/S. Impact Forging, Rajkot vs. The Deputy Commissioner of Income Tax, Central Circle-1, Rajkot

In the result, the appeal of the assessee is partly allowed

ITA 310/RJT/2018[2014-15]Status: DisposedITAT Rajkot08 Nov 2023AY 2014-15

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

For Appellant: Shri P.C Yadav, A.RFor Respondent: Shri Shramdeep Sinha, Sr.D.R
Section 153DSection 254Section 271(1)(c)Section 274

…appellant seeks to rely on the judgments of Apex Court in the case of CIT Vs Varas International reported in 284 ITR 80(SC) and NATIONAL THERMAL POWER CO. LTD vs. CIT reported in 229 ITR 383(SC). Special Bench decision in the case of DHL operators reported in 108 TTJ 152(SB). 7. It is further relevant to mention here that the assessee had not raise these grounds categorically at the time of filing of appeal since the assessee was of the firm belief that the Approval of Additional Commissioner as stipulated in section 153D was in consonance with the provisions of law. However the assessee came to know the fact tha…

M/S. Impact Forging, Rajkot vs. The Deputy Commissioner of Income Tax, Central Circle-1, Rajkot

In the result, the appeal of the assessee is partly allowed

ITA 309/RJT/2018[2013-14]Status: DisposedITAT Rajkot08 Nov 2023AY 2013-14

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

For Appellant: Shri P.C Yadav, A.RFor Respondent: Shri Shramdeep Sinha, Sr.D.R
Section 153DSection 254Section 271(1)(c)Section 274

…appellant seeks to rely on the judgments of Apex Court in the case of CIT Vs Varas International reported in 284 ITR 80(SC) and NATIONAL THERMAL POWER CO. LTD vs. CIT reported in 229 ITR 383(SC). Special Bench decision in the case of DHL operators reported in 108 TTJ 152(SB). 7. It is further relevant to mention here that the assessee had not raise these grounds categorically at the time of filing of appeal since the assessee was of the firm belief that the Approval of Additional Commissioner as stipulated in section 153D was in consonance with the provisions of law. However the assessee came to know the fact tha…