Ganpatrai & Son Ltd. v. Commissioner of Excess Profits Tax

24 ITR 362High Court1953#5008 most cited

What is Ganpatrai & Son Ltd. v. Commissioner of Excess Profits Tax authority for?

An appellate tribunal has the jurisdiction to consider and decide appeals on any ground, even if not raised by the assessee, including points of law raised suo motu by the tribunal. Additionally, additional grounds of appeal can be admitted if the omission was not wilful or unreasonable.

23

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2017 to 2025.

Also referred to as

Ganpatrai & Son Ltd. v. Commissioner of Excess Profits Tax · 24 ITR 362 · appellate tribunal jurisdiction · suo motu grounds · additional grounds of appeal · admission of grounds · section 250(5) · excess profits tax

Sections most often in play

Section 119Section 132(1)Section 143(3)Section 144ASection 153ASection 153CSection 153DSection 158BG

Issues it is cited on

section 153(a)violation of natural justicesection 132(4a)section 40a(3)section 132(1)section 153a(1)section 145(3)section 40asearch assessmentsection 153drule 46asection 145

Judgments citing Ganpatrai & Son Ltd. v. Commissioner of Excess Profits Tax

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 38/ALLD/2023[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 37/ALLD/2023[2006-07]Status: DisposedITAT Allahabad31 Oct 2025AY 2006-07

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 36/ALLD/2023[2005-06]Status: DisposedITAT Allahabad31 Oct 2025AY 2005-06

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 127/ALLD/2023[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 126/ALLD/2023[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 125/ALLD/2023[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Ramji Vaish, Allahabad vs. DCIT(C.C.), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 101/ALLD/2023[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Asstt. Commissioner of Income Tax, Central Circle, Allahabad vs. Vijay Stone Product, Sonebhadra

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 65/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Asstt. Commissioner of Income Tax Central Circle, Allahabad vs. Vijay Stone Products, Sonebhadra

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 64/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 33/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 32/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 31/ALLD/2019[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 30/ALLD/2019[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 25/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 24/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

M/S Subhash Stone Product Private Limited, Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 108/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Subhash Stone Product (P) Ltd., Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 107/ALLD/2019[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…T(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Call), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 13. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” In the case of M/s Vijay Stone Products, the assessee filed the following grounds of appeal in the Cross Objection No. 05/ALLD/2019 arising out of ITA No.…

Deputy Commissioner of Income Tax, CC-I, Kanpur vs. Shri Yogendra Kumar Jaiswal, Mumbai

In the result, the appeal of the Revenue is partly allowed for statistical purposes

ITA 442/LKW/2019[2015-16]Status: DisposedITAT Lucknow13 May 2024AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriaassessment Year: 2015-16 Dy. Cit V. Shri Yogendra Kumar Jaiswal Central Circle-I 2601, Glenridege Kanpur Hiranandani Gardens Powai, Mumbai Pan:Aaopj1739K (Appellant) (Respondent) Appellant By: Smt. Namita S Pandey, Cit(Dr) Respondent By: None Date Of Hearing: 13 05 2024 Date Of Pronouncement: 13 05 2024 O R D E R

For Appellant: Smt. Namita S Pandey, CIT(DR)For Respondent: None
Section 250(4)

…IT(A) erred in admitting the additional evidence at appellate stage without appreciating that the purpose of rule 46A is to ensure that evidence is primarily led before the Income-tax Officer as held in Rajkumar Srimal 102 ITR 525 (Cal), Ganpatrai & Sons Ltd. 24 ITR 362 (Bom). 5. On facts & circumstances of the case and in law, the CIT(A) erred in admitting the additional evidence and asking the AO to submit enquiry report u/s 250(4) without mentioning as to on what issues the enquiries were directed by him. The Ld. CIT(A) should have specifically mentioned the issues on which enquiry was required from AO u/s 250…

Ych Logistics (India) Private Limited, Kancheepuram vs. DCIT, Chennai

In the result, the appeal of the assessee is allowed

ITA 322/CHNY/2016[2011-12]Status: DisposedITAT Chennai20 Jul 2022AY 2011-12

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Dr. S.Palani Kumar, CIT
Section 10ASection 143(3)Section 144CSection 144C(5)Section 92C

…cluded from adjusting the tax liabilities of the assessee in the light of its findings merely because the findings were inconsistent with the pleaded by the assessee. 24. Coming to our High Court in the case of Ramgopal Ganpatrai and Sons Ltd. v. CEPT [1953] 24 ITR 362, the court considered the provisions relating to appeals in respect of the Excess Profit Tax. The court observed that an Appellate Tribunal has jurisdiction to deal with an order which is in appeal before it on any ground even though such a ground was not taken earlier. It said, inter alia, that the appellate court may even reverse or modify the o…

DCIT, Central Circle- II, Noida vs. Tirupati Udyog Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 7158/DEL/2018[2009-10]Status: DisposedITAT Delhi26 May 2022AY 2009-10

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri Amit Goel, AdvFor Respondent: Shri H.K. Chaudhary, CIT-DR
Section 132Section 143(3)Section 153Section 153ASection 46A(2)Section 68

…correctness of such documents, which were never furnished before the A.O. and hence violated the principles of admission of additional evidence, as laid down in CIT Vs Ranjit Kumar 288 ITR 179 (Guj), Raj Kumar Srimal 102 ITR 515 (call), Ganpat Rai & Sons Ltd. 24 ITR 362 (Bom). 3. Whether on facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting addition based on claim made by assessee for the first time claiming that such receipts were actually received in earlier years, wheneven before CIT(A), the assessee did not furnish any details/evidences as to which F.Y. these were actually recei…

Ganpatrai & Son Ltd. v. Commissioner of Excess Profits Tax (24 ITR 362) — Cited in 23 Judgments | BharatTax