DIT v. Pariwar Sewa Sansthan

254 ITR 268High Court2002#5480 most cited

What is DIT v. Pariwar Sewa Sansthan authority for?

The Assessing Officer's action in disallowing salary paid to specified persons as excessive cannot be sustained without demonstrating such excessiveness with material evidence. The salary paid should be comparable to earlier years with reasonable yearly increases.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2010 to 2023.

Also referred to as

DIT v. Pariwar Sewa Sansthan · excessive salary to specified persons · section 13(1)(c) · section 13(3) · charitable trust · Assessing Officer burden of proof · salary comparison

Issues it is cited on

section 13(2)(c)section 144(b)advancement of general public utilitysection 12a(a)section 13(2)section 11(4a)section 13(3)section 13(1)(c)section 11(1)(a)section 13(1)section 40a(2)section 11(1)

Judgments citing DIT v. Pariwar Sewa Sansthan

Deputy Commissioner of Income Tax, Jalandhar vs. M/S. Sadhu Singh Hamdard Trust, Jalandhar

ITA 344/ASR/2010[2007-08]Status: DisposedITAT Amritsar07 Dec 2023AY 2007-08

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

The Assistant Commissioner of Income Tax, Jalandhar vs. M/S. Sadhu Singh Hamdard Trust, Jalandhar

ITA 421/ASR/2009[2006-07]Status: DisposedITAT Amritsar07 Dec 2023AY 2006-07

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

The DCIT, Jalandhar vs. M/S. Sadhu Singh Hamdard Trust, Jalandhar

ITA 39/ASR/2007[2003-04]Status: DisposedITAT Amritsar07 Dec 2023AY 2003-04

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

DCIT, Jalandhar vs. M/S. Sadhu Singh Hamdard Trust, Jalandhar

ITA 328/ASR/2007[2004-05]Status: DisposedITAT Amritsar07 Dec 2023AY 2004-05

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

The Assistant Commissioner of Income Tax, Jalandhar vs. M/S. Sadhu Singh Hamdard Trust, Jalandhar

ITA 177/ASR/2006[2001-02]Status: DisposedITAT Amritsar07 Dec 2023AY 2001-02

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

The Assistant Commissioner of Income Tax, Jalandhar vs. M/S. Sadhu Singh Hamdard Trust, Jalandhar

ITA 272/ASR/2004[1997-98]Status: DisposedITAT Amritsar07 Dec 2023AY 1997-98

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

The Assistant Commissioner of Income Tax, Jalandhar vs. M/S. Sadhu Singh Hamdard Trust, Jalandhar

ITA 261/ASR/2004[1999-2000]Status: DisposedITAT Amritsar07 Dec 2023AY 1999-2000

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

M/S Sadhu Singh Hamdard Trust, Jalandhar vs. The Addl. Commissioner of Income Tax, Jalandhar

ITA 129/ASR/2002[1998-99]Status: DisposedITAT Amritsar07 Dec 2023AY 1998-99

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

M/S. Sadhu Singh Hamdard Trust, Jalandhar vs. The Assistant Commissioner of Income Tax, Jalandhar

ITA 186/ASR/2001[1994-95]Status: DisposedITAT Amritsar07 Dec 2023AY 1994-95

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

M/S. Sadhu Singh Hamdard Trust, Jalandhar vs. The Assistant Commissioner of Income Tax, Jalandhar

ITA 185/ASR/2001[1994-95]Status: DisposedITAT Amritsar07 Dec 2023AY 1994-95

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

M/S. Sadhu Singh Hamdard Trust, Jalandhar vs. The Assistant Commissioner of Income Tax, Jalandhar

ITA 184/ASR/2001[1993-94]Status: DisposedITAT Amritsar07 Dec 2023AY 1993-94

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. D. R
Section 11Section 11(1)(a)Section 13Section 13(1)Section 13(3)Section 13(3)(c)Section 2(15)

…ions of law framed in ITA No.1 of 2011 as depicted in para-No.12 of this judgment in this light are answered against the revenue. ” 4. Emphatic reliance in this regard is placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268.In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(l)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court held as un…

ITO (E), New Delhi vs. M/S. Iilm Foundation, New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 1131/DEL/2016[2011-12]Status: DisposedITAT Delhi24 Dec 2020AY 2011-12

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…sons mentioned in section 13(3) of the Act in respect of services rendered by such persons, the same should not be unreasonable. 20. Emphatic reliance in this regard was placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268 (Del). In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(1)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court hel…

ADIT(E), New Delhi vs. M/S. Iilm Foundation, New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2872/DEL/2014[2010-11]Status: DisposedITAT Delhi24 Dec 2020AY 2010-11

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…sons mentioned in section 13(3) of the Act in respect of services rendered by such persons, the same should not be unreasonable. 20. Emphatic reliance in this regard was placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268 (Del). In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(1)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court hel…

ADIT(E), New Delhi vs. M/S. Iilm Foundation, New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2871/DEL/2014[2009-10]Status: DisposedITAT Delhi24 Dec 2020AY 2009-10

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…sons mentioned in section 13(3) of the Act in respect of services rendered by such persons, the same should not be unreasonable. 20. Emphatic reliance in this regard was placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268 (Del). In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(1)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court hel…

ADIT (E), New Delhi vs. Iilm Foundation, New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2675/DEL/2013[2008-09]Status: DisposedITAT Delhi24 Dec 2020AY 2008-09

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…sons mentioned in section 13(3) of the Act in respect of services rendered by such persons, the same should not be unreasonable. 20. Emphatic reliance in this regard was placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268 (Del). In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(1)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court hel…

Iilm Foundaion, New Delhi vs. ADIT (Exemption), New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 1142/DEL/2011[2007-08]Status: DisposedITAT Delhi24 Dec 2020AY 2007-08

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…sons mentioned in section 13(3) of the Act in respect of services rendered by such persons, the same should not be unreasonable. 20. Emphatic reliance in this regard was placed on the decision of Hon’ble Delhi High Court in the case of Pariwar Seva Sansthan: 254 ITR 268 (Del). In that case, the Revenue filed appeal against the decision of the Tribunal holding that since payments made to parties specified under section 13(3) was reasonable and not excessive, there was no violation of section 13(1)(c) of the Act. Affirming the decision of the Tribunal as not given rise to any question of law, the Hon’ble Court hel…

ITO(E), Jaipur vs. Yazur Shiksha Samiti, Jaipur

In the result, Appeals of the Revenue in ITA Nos

ITA 1093/JPR/2016[2012-13]Status: DisposedITAT Jaipur07 Jun 2017AY 2012-13

Bench: The Hon’Ble Tribunal In The Interest Of Justice.”

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri R.A.Verma (ACIT) fu/kZkfjrh dh vksj ls@
Section 11Section 13(3)Section 143(3)

…rated the salary paid to specified persons are excessive. In the absence of such material the action of the AO cannot be sustained. Ld. Counsel has placed reliance on the judgment of the Hon’ble Delhi High Court in the case of DIT Vs. Pariwar Sewa Sansthan 254 ITR 268 (Del.) (HC), further reliance is placed on the decision of the Co-ordinate Bench rendered in the case of DIT(E) Vs. N.H. Kapadia Education Trust (2012) 136 ITD 111 (Ahmd). 6. We have heard the rival contentions, perused the material available on record and gone through the orders of the authorities below. The Ld. CIT(A), after considering the…

Anand Education Society, New Delhi vs. ADIT (E), New Delhi

In the result, appeal of the assessee is allowed and that of the department is dismissed

ITA 761/DEL/2013[2009-10]Status: DisposedITAT Delhi15 Jul 2016AY 2009-10

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 761/Del/2013 : Asstt. Year : 2009-10 Anand Education Society, Vs Asstt. Director Of Income Tax(E) 30, Community Centre, Ashok Trust Circle-Ii, Vihar, Phase-I, New Delhi New Delhi-110052 (Appellant) (Respondent)

For Appellant: Sh. Ved Jain, Adv. & Ashish Chadha, CAFor Respondent: Sh. K. K. Jaiswal, DR
Section 11Section 12ASection 13(3)Section 147

…nd support from ADIT vs. MANAV BHARTI CHILD AND PSYCHOLOGY 20 SOT 517 (Del.), wherein it has been held that, in the context of section 11 and 13(l)(c) of the Act are attracted. The decision of the Honorable Delhi High Court in the case of Privar Seva Sansthan 254 ITR 268 (Del) is also to the same effect. The following are the decision on section 13(3) of the IT Act, 1961 giving below for your kindly consideration. A) Asstt. Commissioner of IT, Faridabad Vs M/s Idicula Trust Society ITA No.4514/Del/2011 B) Income tax Officer vs. M/s Resource Development & Management Trust (ASBM Trust) ITA No. 14/CTK/20I1 C) Career…

ADIT (E), New Delhi vs. Anand Education Society, New Delhi

In the result, appeal of the assessee is allowed and that of the department is dismissed

ITA 1005/DEL/2013[2009-10]Status: DisposedITAT Delhi15 Jul 2016AY 2009-10

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 761/Del/2013 : Asstt. Year : 2009-10 Anand Education Society, Vs Asstt. Director Of Income Tax(E) 30, Community Centre, Ashok Trust Circle-Ii, Vihar, Phase-I, New Delhi New Delhi-110052 (Appellant) (Respondent)

For Appellant: Sh. Ved Jain, Adv. & Ashish Chadha, CAFor Respondent: Sh. K. K. Jaiswal, DR
Section 11Section 12ASection 13(3)Section 147

…nd support from ADIT vs. MANAV BHARTI CHILD AND PSYCHOLOGY 20 SOT 517 (Del.), wherein it has been held that, in the context of section 11 and 13(l)(c) of the Act are attracted. The decision of the Honorable Delhi High Court in the case of Privar Seva Sansthan 254 ITR 268 (Del) is also to the same effect. The following are the decision on section 13(3) of the IT Act, 1961 giving below for your kindly consideration. A) Asstt. Commissioner of IT, Faridabad Vs M/s Idicula Trust Society ITA No.4514/Del/2011 B) Income tax Officer vs. M/s Resource Development & Management Trust (ASBM Trust) ITA No. 14/CTK/20I1 C) Career…

The Corbett Educational Society, Uttrakhand vs. CIT, Haldwani

In the result, the appeal of the assessee is dismissed

ITA 5581/DEL/2014[]Status: DisposedITAT Delhi30 Mar 2016

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: Nil The Corbett Educational Society, Vs. Commissioner Of Income Tax, Hariyawala Chowk, Kashipur, Khurana Complex, Nainital Road, Distt.- Udham Singh Nagar, Haldwani. Uttarakhand. (Pan: Aabtt2988H ) (Appellant) (Respondent)

Section 10Section 12ASection 13(3)Section 133ASection 2(15)

…n the following cases: 7 ITA No. 5581/Del.2014, The Corbett Education Society 1. Fifth General Education Society versus CIT (1990) 185 ITR 634 2. DCIT versus Cosmopolitan Educational Society (2000) 244 ITR 494 (Raj) 3. DIT versus Parivar Sewa Sansthan (2002) 254 ITR 268 (Del) 4. Orpat charitable trust versus CIT (2002) 256 ITR 690 (Guj) 5. Guru Govind Singh Education Society versus CIT (2009) 118 ITD 207 (ASR) 6. CIT versus Spring Dale education society (2011) 204 Taxmann 11 (P & H) 7. DIT versus JITO Channai chapterr (2012) 204 Taxmann 157 (Madras) 8. CIT versus Bharat Sewa Sansthan (2013) 217 Taxmann 337 (All)…

DIT v. Pariwar Sewa Sansthan (254 ITR 268) — Cited in 21 Judgments | BharatTax