What is Gee Vee Enterprises v. Addl. CIT authority for?

An assessment order is erroneous and prejudicial to the interest of revenue if the Assessing Officer fails to make proper inquiries before accepting the assessee's statements or claims. The Commissioner can revise such an order under Section 263 without conducting further inquiries himself.

How many judgments cite Gee Vee Enterprises v. Addl. CIT?

543 judgments on BharatTax cite Gee Vee Enterprises v. Addl. CIT (99 ITR 375), spanning 2009 to 2026.

Which sections of the Income Tax Act does Gee Vee Enterprises v. Addl. CIT come up under?

It is most often cited in judgments turning on Section 263, Section 143(3), Section 147, Section 142(1), Section 144B, Section 148.

Gee Vee Enterprises v. Addl. CIT (99 ITR 375)

V.L Jewellers, Delhi vs. Circle-49(1), Delhi

In the result, appeal of the assessee is allowed

ITA 836/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Mar 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.836/Del/2022 िनधा"रणवष"/Assessment Year:2017-18 बनाम V.L. Jewellers, Pr. Commissioner Of 2775, 1St Floor, Gali No. 20-21, Vs. Income Tax, Beadon Pura, Karol Bagh, Circle 49(1), New Delhi. Room No. 1202, 12, Civic Centre, Minto Road, New Delhi. Pan No. Aadfv7989A अपीलाथ" Appellant ""यथ"/Respondent

Section 142(1)Section 143(1)Section 143(3)Section 263

…y. In such cases, the order becomes erroneous because enquiry or verification has not been made and not because a wrong order has been passed on merits. 13. Delhi High Court in Gee Vee Enterprises vs. Additional Commission of Income-Tax, Delhi-I & Ors.,(1975) 99 ITR 375, has observed as under:- "The reason is obvious. The position and function of the Income-tax Officer is very different from that of a civil court. The statements made in a pleading proved by the minimum amount of evidence may be accepted by a civil court in the absence of any rebuttal. The civil court is neutral. It simply gives decision on the ba…

Hotel Royal Garden, Daman and Diu (Ut) vs. The PCIT, Valsad

In the result, appeal filed by assessee is dismissed

ITA 103/SRT/2022[2017-18]Status: DisposedITAT Surat21 Mar 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.103/Srt/2022 Assessment Year: (2017-18) (Physical Court Hearing) Hotel Royal Garden, Vs. The Pcit, Valsad. Main Road, Dabhel, Nani Daman – 396210, Daman & Diu (Ut). "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefh2587H (Appellant) (Respondent) Appellant By Shri Darshit J. Naik, Ca With Jayraj M. Naik, Ca Respondent By Shri Ashok B. Koli, Cit(Dr) Date Of Hearing 05/01/2023 Date Of Pronouncement 21/03/2023

Section 143(3)Section 263

…order which is erroneous as well as prejudicial to the interest of the revenue. In this interpretation of the provisions of the section 263, we rely on the decision of the Hon'ble Delhi High Court delivered in the case of Gee Vee Enterprises vs Add.CIT(1975) 99 ITR 375 (Delhi). The same view has also been held by the Hon'ble Supreme Court in the case of Malabar Industrial Company Ltd vs. CIT 243 ITR 83 (SC). The relevant portion of this judgment, is reproduced as under: "An incorrect assumption of facts or an incorrect application of law will satisfy the requirement of the order being erroneous. In the same cate…

V Guard Industries Limited, Vennala vs. The Principal Commissioner of Income Tax-1, Kochi

In the result, the assessee’s appeal is partly allowed

ITA 63/COCH/2022[2016-2017]Status: DisposedITAT Cochin20 Mar 2023AY 2016-2017

Bench: Shri Sanjay Arora & Shri Sandeep Gosainv-Guard Industries Ltd. Principal Cit-1, 42/962, Vennala High School C R Building, I S Press Road, Vs. Road, Vennala, Kochi 682018 Ernakulam 682028 [Pan: Aaacv5492Q] (Appellant) (Respondent) Appellant By: Shri Anil D. Nair, Advocate Respondent By: Shri Prashant V.K., Cit-Dr Date Of Hearing: 01.02.2023 Date Of Pronouncement: 20.03.2023 O R D E R Per: Bench This Is An Appeal By The Assessee Challenging The Revision Of It’S Assessment Under Section 143(3) Of The Income Tax Act, 1961 (‘The Act’ Hereinafter) Dated 28/12/2018 For Assessment Year (Ay) 2016-17 By The Principal Commissioner Of Income Tax-1, Kochi (‘Pr. Cit’ For Short) Vide Order U/S. 263 Dated 22/03/2021. 2. The Appeal, Filed On 08/03/2022, Though Delayed By 256 Days, Was Admitted In View Of The Blanket Condonation By The Apex Court In Suo Motu Wp(C) No.3/2020, Dated 10/01/2022, Excluding The Period From 15/3/2020 To 28/02/2022 In Reckoning The Delay In Computing Limitation Under Law & The Hearing Accordingly Proceeded With. The Assessee Is A Company Manufacturing Electrical Cables, Pumps, Solar Water Heaters, Etc. & Trading In Electrical & Electronic Goods. Revision Of It’S Impugned Assessment Is On Several Issues On Which The Revisionary Authority Found An Absence Or Lack Of Enquiry By The Assessing Officer

For Appellant: Shri Anil D. Nair, AdvocateFor Respondent: Shri Prashant V.K., CIT-DR

Section 143(3)Section 263

…g the same would be subject to sec. 263. The decision by the Hon’ble jurisdictional High Court, reported at [1992] 198 ITR 611 (Ker), holding the assessment as without application of mind, was, accordingly, affirmed. In Gee Vee Enterprises v. Addl. CIT [1975] 99 ITR 375 (Del), again with reference to judicial precedents, it stands explained that the order of the AO becomes erroneous on a failure to make enquiry where the circumstances call for it. This is not because there is anything wrong in the order if all the facts stated therein are assumed to be correct. However, the AO is not only an adjudicator but also…

Credit Suisse (Singapore ) Limited, Singapore vs. Commissioner of Income Tax (International Tax), Mumbai-2

In the result, appeals by the assessee for 2016-17 and 2017-18 are allowed

ITA 1008/MUM/2022[2017-18]Status: DisposedITAT Mumbai09 Mar 2023AY 2017-18

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं. 1007/मुं/2022 ("न.व.2016-17) आअसं. 1008/मुं/2022 ("न.व.2017-18) Credit Suisse (Singapore) Limited, C/O. Delloite Haskins & Sells Chartered Accountants Llp, 30Th Floor, Tower 3, One International Centre, Senapati Bapat Marg, Elphinstone Road (West), Mumbai 400 013 Pan: Aaccc-7328-N ...... अपीलाथ"/Appellant बनाम Vs. Commissioner Of Income Tax (International Taxation) Mumbai-2, 1706, 17Th Floor, Air India Building, ...... ""तवाद"/Respondent Nariman Point, Mumbai 400 038

For Appellant: Shri P.J.Pardiwala Sr. Advocate with Shri. Paras SavlaFor Respondent: Ms. Surabhi Sharma, CIT DR and Ms. Samruddhi Dhananjay Hande, Sr. AR

Section 263

…tacharjee , 341 ITR 434(Gawahati); (ii) CIT vs. Emery Stone Manufacturing Company , 213 ITR 843(Raj); (iii) Rampyari Devi Saraogi vs. CIT, 67 ITR 84 (SC); (iv) ITO vs. DG Housing Projects Limited, 343 ITR 329 (Del); (v) Gee Vee Enterprises vs. Additional CIT, 99 ITR 375 (Del); & (vi) CIT vs. Ballarpur Industries Ltd. I.T. Reference No.27 of 2002 decided on 31/07/2017 by the Hon’ble Bombay High Court. The ld. Departmental Representative prayed for dismissing appeal of the assessee. 4. We have heard the submissions made by rival sides and have examined the orders of authorities below. The ld. Counsel for the assess…

Credit Suisse (Singapore ) Limited, Singapore vs. Commissioner of Income Tax (International Tax), Mumbai-2

In the result, appeals by the assessee for 2016-17 and 2017-18 are allowed

ITA 1007/MUM/2022[2016-17]Status: DisposedITAT Mumbai09 Mar 2023AY 2016-17

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं. 1007/मुं/2022 ("न.व.2016-17) आअसं. 1008/मुं/2022 ("न.व.2017-18) Credit Suisse (Singapore) Limited, C/O. Delloite Haskins & Sells Chartered Accountants Llp, 30Th Floor, Tower 3, One International Centre, Senapati Bapat Marg, Elphinstone Road (West), Mumbai 400 013 Pan: Aaccc-7328-N ...... अपीलाथ"/Appellant बनाम Vs. Commissioner Of Income Tax (International Taxation) Mumbai-2, 1706, 17Th Floor, Air India Building, ...... ""तवाद"/Respondent Nariman Point, Mumbai 400 038

For Appellant: Shri P.J.Pardiwala Sr. Advocate with Shri. Paras SavlaFor Respondent: Ms. Surabhi Sharma, CIT DR and Ms. Samruddhi Dhananjay Hande, Sr. AR

Section 263

…tacharjee , 341 ITR 434(Gawahati); (ii) CIT vs. Emery Stone Manufacturing Company , 213 ITR 843(Raj); (iii) Rampyari Devi Saraogi vs. CIT, 67 ITR 84 (SC); (iv) ITO vs. DG Housing Projects Limited, 343 ITR 329 (Del); (v) Gee Vee Enterprises vs. Additional CIT, 99 ITR 375 (Del); & (vi) CIT vs. Ballarpur Industries Ltd. I.T. Reference No.27 of 2002 decided on 31/07/2017 by the Hon’ble Bombay High Court. The ld. Departmental Representative prayed for dismissing appeal of the assessee. 4. We have heard the submissions made by rival sides and have examined the orders of authorities below. The ld. Counsel for the assess…

Devika Rajesh Jaggi, Mumbai vs. Principle CIT Range-19, Mumbai

In the result, the present appeal is allowed

ITA 861/MUM/2022[2017-18]Status: DisposedITAT Mumbai24 Feb 2023AY 2017-18

For Appellant: Shri Yogesh TharFor Respondent: Smt. Riddhi Mishra

Section 143(3)Section 263

…ot only an adjudicator but also an investigator and he cannot remain passive in the face of a return which is apparently in order but calls for further inquiry but, as observed by Hon'ble Delhi High Court in the case of Gee Vee Enterprises v. Addl. CIT [1975] 99 ITR 375 "it is his duty to ascertain the truth of the facts stated in the return when the circumstances of the case are such as to provoke an inquiry. (Emphasis, by underlining, supplied by us). It is, therefore, obvious that when the circumstances are not such as to provoke an inquiry, he need not put every proposition to the test and probe everything st…

Dineshchandra Narharishankar Upadhyay, Surat vs. Principal Commissioner of Income Tax-1, Surat

In the result, appeal of the assessee is allowed

ITA 120/SRT/2022[2017-18]Status: DisposedITAT Surat22 Feb 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.120/Srt/2022 ("नधा"रणवष" / Assessment Year: (2017-18) (Physical Court Hearing) Dineshchandra Narharishankar Principal Commissioner Of Upadhyay, 5/1203, Main Income-Tax-1, Room No. 123, Vs. Road, Haripura, Surat-395003 Aaykar Bhavan, Majura Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacpu 1094 J (Appellant) (Respondent) िनधा"रती की ओर से /Assessee By : Shri Hiren M. Diwan, C.A राज"व क" ओर से /Respondent By: Shri Ravinder Sindhu, Cit-D.R

For Appellant: Shri Hiren M. Diwan, C.AFor Respondent: Shri Ravinder Sindhu, CIT-D.R

Section 143(3)Section 263Section 54F

…order if all the facts stated therein are assumed to be correct. We derive support for the ITA No.120/SRT/2022 A.Y.17-18 Dineshchandra N Upadhyay proposition as stated above from the decision of the Hon’ble Delhi High Court in the case of Gee Vee Enterprises 99 ITR 375 (Del). 18. Since in the present case the PCIT has exercised jurisdiction u/s.263 of the Act on the ground that the Assessing Officer while completing the assessment proceeding did not make enquiries which he ought to have made. Therefore, it is necessary to look into what enquiries the Assessing Officer made on the issues raised in the order u/s.…

Gujarat Narmada Valley Fertilizers & Chemicals Ltd, Surat vs. Pr. CIT-3, Vadodara

In the result, appeal filed by the assessee is allowed

ITA 178/SRT/2020[2014-15]Status: DisposedITAT Surat22 Feb 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.178/Srt/2020 Assessment Year: (2014-15) (Virtual Court Hearing) Gujarat Narmada Valley Fertilizers Vs. The Pcit-3 & Chemicals Ltd., Surat. Narmada House, Narmadanagar, Bharuch – 392015. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacg8372Q (Appellant) (Respondent) Assessee By Shri Yogesh Shah, Ar Respondent By Shri Ashok B. Koli, Cit-Dr Date Of Hearing 03/01/2023 Date Of Pronouncement 22/02/2023

Section 115JSection 143(3)Section 14ASection 263Section 801Section 80I

…es of the case are such as to provoke enquiry. If there is failure to make such enquiry, the order is erroneous and prejudicial to the interest of revenue. In this regard useful references may be made to the following cases: Gee Vee Enterprises vs. Addl. CIT, 99 ITR 375(DEL) Rampyari Devi Saraogi vs. Commissioner of Income-tax, 67 ITR 84(SC) Malabar Industrial Co. Ltd. vs. CIT, (2000) 243 ITR 83 (SC) RajalakshmiMills Ltd., vs. ITO 2009, ITOL-317-ITAT-MAD-SB It may further be stated that Explanation 2 has been inserted below sub-section (1). of Section 263 wherein it has been declared that an order passed by the A…

Martin and Harris Laboratories Limited, Mumbai vs. Principal Commissioner of Income Tax (PCIT), Aaykar Bhawan, Mumbai-400020

In the result, the present appeal by the Assessee is allowed

ITA 627/MUM/2022[2017-18]Status: DisposedITAT Mumbai17 Feb 2023AY 2017-18

For Appellant: Sh. Salil Kapoor, &For Respondent: Ms. Sailja Rai

Section 143(3)Section 14ASection 263Section 263(1)Section 801CSection 80GSection 80I

…ot only an adjudicator but also an investigator and he cannot remain passive in the face of a return which is apparently in order but calls for further inquiry but, as observed by Hon'ble Delhi High Court in the case of Gee Vee Enterprises v. Addl. CIT [1975] 99 ITR 375 "it is his duty to ascertain the truth of the facts stated in the return when the circumstances of the case are such as to provoke an inquiry. (Emphasis, by underlining, supplied by us). It is, therefore, obvious that when the circumstances are not such as to provoke an inquiry, he need not put every proposition to the test and probe everything st…

Shri Rajkot District Cooperative Bank Ltd., Rajkot-Gujarat vs. The Pr. Commr. of Income Tax-1, Rajkot-Gujarat

In the result, appeal of the assessee is dismissed

ITA 123/RJT/2016[2011-12]Status: DisposedITAT Rajkot15 Feb 2023AY 2011-12

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2011-12 Shri Rajkot District Cooperative Vs. Pr.Cit, Rajkot-1 Bank Ltd. Rajkot. ‘Jilla Bank Bhavan’, Kasturba Road Opp: Chaudhari High School Rajkot. Pan : Aaaar 0564 K 0 अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assesseeby : Shri S.N. Soparkar, Ld.Ar Revenue By : Shri Shramdeep Sinha, Ld.Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 17/11/2022 घोषणा क" तार"ख /Date Of Pronouncement: 15/02/2023

For Appellant: Shri S.N. Soparkar, ld.ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR

Section 143(3)Section 263Section 36

…to be assessed in his or her end in order to assist someone else who would have been assessed to a larger amount, the assessment so made can certainly be erroneous and prejudicial to the interest of the revenue. 13. In GEE VEE Enterprises v. Addl. CIT [1975] 99 ITR 375 (Delhi) following the aforesafd two judgments of the Apex Court it has been held that the position and function of the Income Tax Officer is very different from that of a Civil Court. The statements made in a pleading proved by minimum amount of evidence may be accepted by a Civil Court in absence of any rebuttal. The Civil Court is neutral. It si…

Shivam Residential Construction (India) Pvt. Ltd., Valsad vs. Principal Commissioner of Income Tax, Valsad

In the result, appeal of the assessee is dismissed

ITA 396/SRT/2018[2013-14]Status: DisposedITAT Surat10 Feb 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.396/Srt/2018 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Shivam Residential Construction Principal Commissioner Of (India) Pvt. Ltd., New Civil Income-Tax-Valsad, Palak Vs. Hospital Road, Nanakwada, Valsad Arcade, Pali Hill, Santinagar, Tithal Road, Valsad-396001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aapcs 3137 G (Appellant) (Respondent) िनधा"रती की ओर से /Assessee By : Shri Milin Mehta, C.A राज"व क" ओर से /Respondent By: Shri Ashish Pophare, Cit-D.R

For Appellant: Shri Milin Mehta, C.AFor Respondent: Shri Ashish Pophare, CIT-D.R

Section 143(3)Section 263Section 68

…falls within the category of being an order which is erroneous as well as prejudicial to the interest of the revenue. For that reliance can be placed on the decision of the Hon'ble Delhi High Court delivered in the case of Gee Vee Enterprises vs Add.CIT(1975) 99 ITR 375 (Delhi). The same view has also been held by the Hon'ble Supreme Court in the case of Malabar ITA No.396/SRT/2018 A.Y.13-14 Shivam Residential Construction (India) Pvt. Ltd. Industrial Company Ltd vs. CIT 243 ITR 83 (SC). The relevant portion of this judgment is reproduced as under: "An incorrect assumption of facts or an incorrect application of…

S Krishna Murthy, Tirupati vs. Income Tax Officers, Ward-1(2), Tirupati

In the result, appeal filed by the assessee is allowed

ITA 424/HYD/2021[2015-16]Status: DisposedITAT Hyderabad06 Feb 2023AY 2015-16

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2015-16 Shri Krishna Murthy Vs. Income Tax Officer Tirupati Ward 1(2) Pan: Aozps5794Q Tirupati (Appellant) (Respondent) Assessee By: Shri Shashank Dundu,Advocate Revenue By: Shri K.E. Sunil Babu, Dr Date Of Hearing: 02/02/2023 Date Of Pronouncement: 06/02/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.12.2017 Of The Learned Pr.Cit Tirupati, Relating To A.Y.2015-16. 2. Facts Of The Case, In Brief , Are That The Assessee Is An Individual & Filed His Return Of Income On 14.02.2017 Admitting Taxable Income Of Rs.9,10,510/- & Agricultural Income At Rs.2,40,000/-. The Case Was Selected For Scrutiny To Examine “(I) Whether The Cash Deposit Has Been Made From Disclosed Sources & (Ii) Whether Investment & Income Relating To Properties Are Duly Disclosed”. Accordingly Notice U/S 143(2) Of The Act Was Issued To The Assessee In Response To Which The A.R Of The Page 1 Of 9

For Appellant: Shri Shashank Dundu,AdvocateFor Respondent: Shri K.E. Sunil Babu, DR

Section 143(2)Section 143(3)Section 263

…verification of the reasons for which the case was selected for scrutiny. The gist of some of the judicial pronouncements discussed as under whose issues and facts are that of similar to the case of the assessee. In the case of Gee Vee Enterprises Vs Addl.CIT 99 ITR 375 (Delhi), it is held that the AO being not only an adjudicator but also an ' Investigator', he cannot remain passive in the fact of a return which is apparently in order but calls for further enquiry in the facts and circumstances of the case and the word erroneous in section 263 of the I.T. Act includes the failure to make such an enquiry. The CIT…

Shri Praful Gautambhai Kothari, Rajkot vs. The Pr. CIT-1, Rajkot

In the result, the appeal filed by the assessee is allowed

ITA 163/RJT/2021[2011-12]Status: DisposedITAT Rajkot31 Jan 2023AY 2011-12

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 163/Rjt/2021 िनधा"रण वष"/Asstt. Years: 2011-2012

For Appellant: Shri Gaurang Khakhar, A.RFor Respondent: Shri Shramdeep Sinha, CIT. D.R

Section 142(1)Section 143(3)Section 147Section 263

…. There are various judicial decisions in 1. Rampyari Devi SaroglTO. CIT (SC) 67 ITR 84 2. Malabar Industrial Co. Ltd. Vs. CIT(SC) 243 ITR 83 3. Swarup Vegetable Products Industries Ltd. Vs. CIT (ALL) 187 ITR 412 4. Gee Vee Enterprises Vs. Addl.CIT&Ors (Del.) 99 ITR 375 5. Rajalakshmi Mills Ltd. Vs. ITO (ITAT, SB-Chennai) 121 ITD 343, 313 ITR(AT) 182 6. SRM Systems & Software Pvt. Ltd. Vs. ACIT 2010-TIOL-646-HC- MAD-IT. 7. Shakti Credits Ltd Vs. CIT 2015 Tax Pub (DT) 3058 (Luck.'A' Trib) 8. Shoreline Hotel Pvt Ltd. Vs. CIT 2015 Tax Pub (DT) 2982 (Mum.'E" Trib.) 9. Kapil Ratan Associates Vs CIT 2015 Tax Pub (DT) 2…

United Rail Road Consultants Private Limited (Unique Rail Road Consultants Pvt Ltd Now Merged With United Rail Road Consultants Pvt Ltd, Hyderabad vs. DCIT-1 Central Circle-1(3), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 745/HYD/2020[2015-16]Status: DisposedITAT Hyderabad30 Jan 2023AY 2015-16

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2015-16 M/S. United Rail Road Vs. Dy. C.I.T Consultants (P) Ltd., Central Circle 1(3) Secunderabad Hyderabad Pan:Aaacu8136E (Appellant) (Respondent) Assessee By: Shri M.V. Joshi, C.A Appeared For Shri P. Murali Mohan Rao, Ca Revenue By: Shri Jeeval Lal Lavidiya, Dr Date Of Hearing: 12/01/2023 Date Of Pronouncement: 30/01/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.3.2020 Passed U/S 263 Of The I.T. Act, 1961 By The Learned Pr.Cit (Central)- Hyderabad, Relating To A.Y.2015-16. 2. Facts Of The Case, In Brief, Are That The Assessee Company Was Engaged In The Business Of Providing Consultancy Services. It Filed Its Return Of Income For The A.Y 2015-16 On 29.9.2015 Declaring Total Income Of Rs.2,29,74,860/-. The Case Was Selected For Scrutiny Through Cass In The Limited Scrutiny To Verify “Large Other Expenses Claimed In The Profit & Loss A/C & Mismatch In Sales Turnover Reported In Audit Report &

For Appellant: Shri M.V. Joshi, C.A appeared for Shri P. Murali Mohan Rao, CAFor Respondent: Shri Jeeval Lal Lavidiya, DR

Section 143(2)Section 143(3)Section 199Section 236Section 263

…wing decisions: i) Hon'ble Supreme Court in the case of Smt. Taradevi Aggarwal (88 ITR 323 (S.C) ii) Hon'ble Supreme Court decision in the case of Smt. Rampyari Devi Sarogi (67 ITR 84 (S.C) iii) Hon'ble Delhi High Court in the case of Gee Vee Enterprises Ltd (99 ITR 375 (Del.) iv) ITAT Mumbai decision in the case of Radiant Life Care Mumbai (P) Ltd (ITA 895 & 896/Mum/2021 dated 31.5.2022 11. We have heard the rival arguments made by both the sides, perused the orders of the AO and the learned Pr.CIT/CIT and the paper book filed on behalf of the assessee. We have also Page 8 of 15 ITA No 745 of 2020 United Rail…