Distributors (Baroda) (P.) Ltd. v. Union of India

155 ITR 120Supreme Court of India1985#386 most cited

What is Distributors (Baroda) (P.) Ltd. v. Union of India authority for?

For computing the deduction under Section 80M, only the net dividend income (gross dividend income after reducing expenses attributable to earning it, as per Section 57(iii) and the principle in Section 80AB) is eligible. The case also holds that tax authorities are not bound to perpetuate an error from a previous assessment year, as each year is a separate unit and consistency cannot override substantive justice.

229

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2007 to 2026.

Also referred to as

Distributors (Baroda) (P.) Ltd. v. Union of India · 155 ITR 120 · Section 80M deduction · net dividend income · expenses attributable to dividend · Section 80AB · Section 57(iii) · consistency principle · perpetuate error · assessment year separate unit · judicial conscience · dividend income

Also reported as

1 SCC 4347 CTR 349

Sections most often in play

Section 143(3)Section 14ASection 153ASection 153DSection 1961Section 271(1)(c)Section 36(1)(vii)Section 40(a)(ia)

Issues it is cited on

section 274(2)section 50(1)section 80absection 80msection 243section 54esection 10(33)section 10(15)section 245hacasus omissussection 14a(1)section 54ec

Judgments citing Distributors (Baroda) (P.) Ltd. v. Union of India

State Bank of India, Mumbai vs. DCIT Cir 2(2), Mumbai

ITA 4105/MUM/2014[2007-08]Status: DisposedITAT Mumbai11 Oct 2024AY 2007-08

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm

Section 14Section 143Section 36Section 41

…in Deputy Commissioner of income tax versus SG investment and industries Ltd [(2004) 89 ITD 44 (KOL)], honourable Supreme Court in case of CIT versus United Gen trust private limited [(200 ITR 488)], Distributors(Baroda) private limited versus Union of India [155 ITR 120] and the decision of the honourable Bombay High Court in case of CIT versus Magan Lal Chhaganlal private limited (236 ITR 456). 26) Assessee aggrieved with the order of the learned assessing officer challenged the same before the learned CIT – A who decided the above ground of appeal as per Page | 16 paragraph number 5 of his appellate order. It…

DCIT 2(2), Mumbai vs. State Bank of India, Mumbai

In the result appeal filed by the assessee for assessment year 2006 – 07 and 2007 – 08 is partly allowed

ITA 4952/MUM/2013[2006-07]Status: DisposedITAT Mumbai11 Oct 2024AY 2006-07

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm A.Y.2006-07 [ By Assessee] &

Section 14Section 143Section 36Section 41

…in Deputy Commissioner of income tax versus SG investment and industries Ltd [(2004) 89 ITD 44 (KOL)], honourable Supreme Court in case of CIT versus United Gen trust private limited [(200 ITR 488)], Distributors(Baroda) private limited versus Union of India [155 ITR 120] and the decision of the honourable Bombay High Court in case of CIT versus Magan Lal Chhaganlal private limited (236 ITR 456). 26) Assessee aggrieved with the order of the learned assessing officer challenged the same before the learned CIT – A who decided the above ground of appeal as per ` paragraph number 5 of his appellate order. It was sub…

State Bank of India, Mumbai vs. Addl CIT Cir 2(2), Mumbai

In the result appeal filed by the assessee for assessment

ITA 3868/MUM/2013[2006-07]Status: DisposedITAT Mumbai11 Oct 2024AY 2006-07

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm

Section 14Section 143Section 36Section 41

…puty Commissioner of income tax versus SG investment and industries Ltd [(2004) 89 ITD 44 (KOL)], honourable Supreme Court in case of CIT versus United Gen trust private limited [(200 ITR 488)], Distributors(Baroda) private limited versus Union of India [155 ITR 120] and the decision of the honourable Bombay High Court in case of CIT versus Magan Lal Chhaganlal private limited (236 ITR 456). 26) Assessee aggrieved with the order of the learned assessing officer challenged the same before the learned CIT – A who decided the above ground of appeal as per Page | 16 paragraph number 5 of his appellate orde…

Deputy Commissioner of Income Tax, Circle-7.1.1, Bangalore vs. Tally Solutions Private Limited, Bangalore

In the result, the appeal filed by the revenue is partly allowed for statistical purposes

ITA 177/BANG/2024[2017]Status: DisposedITAT Bangalore30 Aug 2024

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadavassessment Years: 2017-18

For Appellant: Ms. Tanmayee Rajkumar, AdvocateFor Respondent: Shri Subramanian S, JCIT
Section 14ASection 35

…ssessee. We also observed that the Revenue has not tinkered with these expenses in the previous years. However, it is the settled position of law that to perpetuate an error is not heroism as held by Hon'ble Apex Court in the case of Baroda Distributor's case 155 ITR 120 therefore, we remit this issue to the file of the AO for examination afresh. Hence the ground of appeal of the revenue is allowed for statistical purposes. 17. The next issue raised by the revenue is that the learned CIT(A) erred in deleting disallowance made by the AO under section 14A r.w.r. 8D of the IT rules for Rs. 26,05,150/- only. 18. Th…

Shri Nirmal Parmanand Anand, Mumbai vs. CIT(A), NFAC, Delhi

In the result, the appeal of the assessee is 8

ITA 654/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 Aug 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Shri Nirmal Parmanand Anand, Cit(A), Nfac Acit Circle 25/26, Kailash Darshan Kennedy 16(1), Bridge, Gant Road, Vs. Aayakar Bhavan, Mumbai-400 007. Mumbai-400020. Pan No. Aenpa 2374 Q Appellant Respondent

For Appellant: Mr. Mukesh AdvaniFor Respondent: 24/06/2024
Section 143(3)Section 147

…Court, in the case of hands of the assessee. The Hon’ble Supreme Court, in the case o hands of the assessee. The Hon’ble Supreme Court, in the case o Distributors (Baroda) Pvt. Ltd. vs. Union of India Distributors (Baroda) Pvt. Ltd. vs. Union of India [(1985) 155 ITR 120 [(1985) 155 ITR 120 (SC)], held that there is no merit in perpetuating an error and that it (SC)], held that there is no merit in perpetuating an error and that it (SC)], held that there is no merit in perpetuating an error and that it Shri Nirmal Parmanand Anan Shri Nirmal Parmanand Anan 17 should be rectified at the earliest opportunity. Theref…

Dinesh Somatmal Dhokar, Mumbai vs. Income Tax Officer - 19(1)(1), Mumbai

In the result, both the appeals are partly allowed

ITA 3556/MUM/2023[2009-10]Status: DisposedITAT Mumbai21 May 2024AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm

For Appellant: Ms. Ridhisha Jain, AR
Section 143(3)Section 147Section 148Section 271Section 271(1)(c)

…ay not be applicable as discussed in paragraph 11 of the said decision. In the context of prejudice, the Court, referring to the decision in Jankinath Sarangi v. State of Orissa [1969] 3 SCC 392, and in the case of K. L. Tripathi v. State Bank of India [1984] 1 SCC 43, as also in the case of Managing Director, ECIL v. B Karunkar [1994] 4 SCC 727, held that principles of natural justice cannot be reduced to any hard and fast formulae. The relevant observations in that regard are required to be noted which read thus:- "28. The decisions cited above make one thing clear, viz., principles of natural justice cannot be…

Dinesh Somatmal Dhokar, Mumbai vs. Income Tax Officer - 19(1)(1), Mumbai

In the result, both the appeals are partly allowed

ITA 3555/MUM/2023[2010-11]Status: DisposedITAT Mumbai21 May 2024AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm

For Appellant: Ms. Ridhisha Jain, AR
Section 143(3)Section 147Section 148Section 271Section 271(1)(c)

…ay not be applicable as discussed in paragraph 11 of the said decision. In the context of prejudice, the Court, referring to the decision in Jankinath Sarangi v. State of Orissa [1969] 3 SCC 392, and in the case of K. L. Tripathi v. State Bank of India [1984] 1 SCC 43, as also in the case of Managing Director, ECIL v. B Karunkar [1994] 4 SCC 727, held that principles of natural justice cannot be reduced to any hard and fast formulae. The relevant observations in that regard are required to be noted which read thus:- "28. The decisions cited above make one thing clear, viz., principles of natural justice cannot be…

ACIT, Circle CC 15, New Delhi vs. Alka Mendiratta, Delhi

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1864/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 153ASection 69

…llant during the above assessment year jointly with his spouse. Here it is pertinent to refer to the observations of Hon'ble Justice P.N. Bhagwati while rendering the judgment in the case of Distributors (Baroda) P Ltd. Vs. Union of India & Otrs., reported in 155 ITR 120 (SC) - larger bench decision as under: ITA Nos. 1863 & 1864/Del/2021 22 CO Nos. 25 & 28/Del/2022 Yash Pal & Alka Mendiratta “To perpetuate an error is no heroism. To rectify it is the compulsion of the judicial conscience. In this, we derive comfort and strength from the wise and inspiring words of justice Bronson in Pierce v. Dela meter (A.M.Y…

ACIT, CC-15, New Delhi vs. Yash Pal Mendiratta, Delhi

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1863/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 153ASection 69

…llant during the above assessment year jointly with his spouse. Here it is pertinent to refer to the observations of Hon'ble Justice P.N. Bhagwati while rendering the judgment in the case of Distributors (Baroda) P Ltd. Vs. Union of India & Otrs., reported in 155 ITR 120 (SC) - larger bench decision as under: ITA Nos. 1863 & 1864/Del/2021 22 CO Nos. 25 & 28/Del/2022 Yash Pal & Alka Mendiratta “To perpetuate an error is no heroism. To rectify it is the compulsion of the judicial conscience. In this, we derive comfort and strength from the wise and inspiring words of justice Bronson in Pierce v. Dela meter (A.M.Y…

Tata Elxsi Limited, Bangalore vs. Deputy Commisioner Incomer Tax, Circle-7(1)(1), Bangalore

Accordingly, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1152/BANG/2023[2018-19]Status: DisposedITAT Bangalore28 Feb 2024AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

For Appellant: Shri Padam Chand Khincha, CAFor Respondent: Shri Subramanian .S, JCIT DR
Section 10ASection 10A(9)Section 250

…ied on by the Supreme Court in the context of section 80HH. The Supreme Court after discussing all the earlier judgements of the Supreme Court i.e. Cambay Electric Supply [1978] 113 ITR 84 (SC), Cloth Traders [1979] 118 ITR 243 (SC), Distributor Baroda [1085] 155 ITR 120 (SC), HH Sir Ram Verma [1994] 205 ITR 433 (SC), Kotagiri Industrial Co-operative Tea Factory Ltd [1997] 224 ITR 604 (SC) concluded as under: "19) Reading of Section 80HH along with Section 80A would clearly signify' that such a deduction has to be of gross profits and gains, i.e., before computing the income as specified in Sections 30 to 43D of…

M/S. Tata Elxsi Limited, Bangalore vs. Deputy Commissioner Income Tax, Circle-7(1)(1), Bangalore

ITA 975/BANG/2023[2020-2021]Status: DisposedITAT Bangalore08 Jan 2024AY 2020-2021

Bench: Shri George George K. & Shri Chandra Poojari

Section 10ASection 30Section 80ASection 80HSection 80I

…pon by the Supreme Court in the context of section 80HH. 5. The Supreme Court after discussing all the earlier judgements of the Supreme Court i.e. Bombay Electric Supply [1978] 113 ITR 59 (SC), Cloth Traders [1979] 118 ITR 845 (SC), Distributor Baroda [1985] 155 ITR 120 (SC), H.H. Sir Rama Varma [1994] 205 ITR 433 (SC), Kotagiri Industrial Co-Operative Tea Factory Ltd. [1997] 224 ITR 604 (SC) concluded as under:- "19) Reading of Section 80HH along with Section 80A would clearly signify that such a deduction has to be of gross profits and gains, i.e., before computing the income as specified in Sections 30 to 43D…

M/S. Tata Elxsi Limited., Bangalore vs. Deputy Commissioner Income Tax, Circle-7(1)(1), Bangalore

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 927/BANG/2023[2016-17]Status: DisposedITAT Bangalore08 Jan 2024AY 2016-17

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri Padam Chand Kincha, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 10ASection 30Section 80ASection 80H

…ied on by the Supreme Court in the context of section 80HH. The Supreme Court after discussing all the earlier judgements of the Supreme Court i.e. Cambay Electric Supply [1978] 113 ITR 84 (SC), Cloth Traders [1979] 118 ITR 243 (SC), Distributor Baroda [1085] 155 ITR 120 (SC), HH Sir Ram Verma [1994] 205 ITR 433 (SC), Kotagiri Industrial Co-operative Tea Factory Ltd [1997] 224 ITR 604 (SC) concluded as under: "19) Reading of Section 80HH along with Section 80A would clearly signify' that such a deduction has to be of gross profits and gains, i.e., before computing the income as specified in Sections 30 to 43D of…

Nuclear Power Corporation of India Ltd, Mumbai vs. Addl CIT RG 3(2), Mumbai

ITA 3553/MUM/2011[2006-07]Status: DisposedITAT Mumbai29 Nov 2023AY 2006-07

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

…er the provisions of the Act. For reversal of his finding ct. For reversal of his finding, the Ld. AO relied on the decision of the relied on the decision of the Hon’ble Supreme Court in Hon’ble Supreme Court in the case of Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120, wherein it is held that held that to perpetuate an error is no heroism heroism. M/s Nuclear Power Corporation of India Ltd.. M/s Nuclear Power Corporatio ITA Nos. 202, 114, 4413/M/2004, 3867/M/2008, 4743 to 4745/M/2007, 3867/M/2008, 4743 to 4745/M/2…

Nuclear Power Corporation of India Ltd, Mumbai vs. Addl CIT RG 3(2), Mumbai

ITA 2452/MUM/2011[2005-06]Status: DisposedITAT Mumbai29 Nov 2023AY 2005-06

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

…er the provisions of the Act. For reversal of his finding ct. For reversal of his finding, the Ld. AO relied on the decision of the relied on the decision of the Hon’ble Supreme Court in Hon’ble Supreme Court in the case of Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120, wherein it is held that held that to perpetuate an error is no heroism heroism. M/s Nuclear Power Corporation of India Ltd.. M/s Nuclear Power Corporatio ITA Nos. 202, 114, 4413/M/2004, 3867/M/2008, 4743 to 4745/M/2007, 3867/M/2008, 4743 to 4745/M/2…

Nuclear Power Corporation of India Ltd, Mumbai vs. Addl. C.I.T, Range 3(2), Mumbai

ITA 3867/MUM/2008[2001-2002]Status: DisposedITAT Mumbai29 Nov 2023AY 2001-2002

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

…er the provisions of the Act. For reversal of his finding ct. For reversal of his finding, the Ld. AO relied on the decision of the relied on the decision of the Hon’ble Supreme Court in Hon’ble Supreme Court in the case of Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120, wherein it is held that held that to perpetuate an error is no heroism heroism. M/s Nuclear Power Corporation of India Ltd.. M/s Nuclear Power Corporatio ITA Nos. 202, 114, 4413/M/2004, 3867/M/2008, 4743 to 4745/M/2007, 3867/M/2008, 4743 to 4745/M/2…

Nuclear Power Corporation of India Ltd, Mumbai vs. Addl. C.I.T, Range 3(2), Mumbai

ITA 4745/MUM/2007[2004-2005]Status: DisposedITAT Mumbai29 Nov 2023AY 2004-2005

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

…er the provisions of the Act. For reversal of his finding ct. For reversal of his finding, the Ld. AO relied on the decision of the relied on the decision of the Hon’ble Supreme Court in Hon’ble Supreme Court in the case of Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120, wherein it is held that held that to perpetuate an error is no heroism heroism. M/s Nuclear Power Corporation of India Ltd.. M/s Nuclear Power Corporatio ITA Nos. 202, 114, 4413/M/2004, 3867/M/2008, 4743 to 4745/M/2007, 3867/M/2008, 4743 to 4745/M/2…

Nuclear Power Corporation of India Ltd, Mumbai vs. Addl. C.I.T, Range 3(2), Mumbai

ITA 4744/MUM/2007[2003-2004]Status: DisposedITAT Mumbai29 Nov 2023AY 2003-2004

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

…er the provisions of the Act. For reversal of his finding ct. For reversal of his finding, the Ld. AO relied on the decision of the relied on the decision of the Hon’ble Supreme Court in Hon’ble Supreme Court in the case of Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120, wherein it is held that held that to perpetuate an error is no heroism heroism. M/s Nuclear Power Corporation of India Ltd.. M/s Nuclear Power Corporatio ITA Nos. 202, 114, 4413/M/2004, 3867/M/2008, 4743 to 4745/M/2007, 3867/M/2008, 4743 to 4745/M/2…

Nuclear Power Corporation of India Ltd, Mumbai vs. Addl. C.I.T, Range 3(2), Mumbai

ITA 4743/MUM/2007[2002-2003]Status: DisposedITAT Mumbai29 Nov 2023AY 2002-2003

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

…er the provisions of the Act. For reversal of his finding ct. For reversal of his finding, the Ld. AO relied on the decision of the relied on the decision of the Hon’ble Supreme Court in Hon’ble Supreme Court in the case of Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120, wherein it is held that held that to perpetuate an error is no heroism heroism. M/s Nuclear Power Corporation of India Ltd.. M/s Nuclear Power Corporatio ITA Nos. 202, 114, 4413/M/2004, 3867/M/2008, 4743 to 4745/M/2007, 3867/M/2008, 4743 to 4745/M/2…

The Dy CIT 3(2), Mumbai vs. M/S. Nuclear Power Corporation of India Ltd, Mumbai

ITA 4603/MUM/2007[2004-2005]Status: DisposedITAT Mumbai29 Nov 2023AY 2004-2005

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

…er the provisions of the Act. For reversal of his finding ct. For reversal of his finding, the Ld. AO relied on the decision of the relied on the decision of the Hon’ble Supreme Court in Hon’ble Supreme Court in the case of Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120, wherein it is held that held that to perpetuate an error is no heroism heroism. M/s Nuclear Power Corporation of India Ltd.. M/s Nuclear Power Corporatio ITA Nos. 202, 114, 4413/M/2004, 3867/M/2008, 4743 to 4745/M/2007, 3867/M/2008, 4743 to 4745/M/2…

Nuclear Power Corporation of India Ltd., Mumbai vs. ACIT Range 3(2), Mumbai

ITA 4413/MUM/2004[2000-01]Status: DisposedITAT Mumbai29 Nov 2023AY 2000-01

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 1998-99 & Assessment Year: 1999-2000 & Assessment Year: 2000-01 & Assessment Year: 2001-02 & Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 Nuclear Power Corporation Of Acit, Range-3(2), India Ltd., Aayakar Bhavan, M.K. Road, Vikram Sarabhai Bhavan, Vs. Mumbai-400021. Central Avenue, Anushakti Nagar, Mumbai-400094. Pan No. Aaacn 3154 F Appellant Respondent

…er the provisions of the Act. For reversal of his finding ct. For reversal of his finding, the Ld. AO relied on the decision of the relied on the decision of the Hon’ble Supreme Court in Hon’ble Supreme Court in the case of Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120 Distributors Baroda ltd reported in 155 ITR 120, wherein it is held that held that to perpetuate an error is no heroism heroism. M/s Nuclear Power Corporation of India Ltd.. M/s Nuclear Power Corporatio ITA Nos. 202, 114, 4413/M/2004, 3867/M/2008, 4743 to 4745/M/2007, 3867/M/2008, 4743 to 4745/M/2…