Gopal Saran Narain Singh v. CIT

3 ITR 237Reported decision1935#11449 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 341,001 Indian tax judgments — from 2019 to 2024.

Sections most often in play

Section 14ASection 36(1)(vii)Section 36(1)(viii)Section 40A(9)Section 41(4)

Issues it is cited on

period of holdingsection 41section 260section 260asection 45mercantile system of accountingsection 2(24)section 54profits and gains of business or professionsection 115jsection 145revenue expenditure

Judgments citing Gopal Saran Narain Singh v. CIT

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

…non- rural advances. Therefore, there cannot be double deduction one on the provision basis and again on actual write-of basis separately and independently. He further relied upon the judicial precedent of Privy Council Maharajkumar Gopal Saran Narain Singh [3 ITR 237]. Accordingly, since the ground of appeal does not arise out of the issue in assessment proceedings, he held it to be not maintainable and dismissed. 133) The learned authorized representative submitted that this issue is covered squarely in favour of the assessee by the decision of the coordinate bench Bangalore tribunal in case of state bank of M…

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

…n rural advances. Therefore, there cannot be double deduction one on the provision basis and again on actual write-of basis separately and independently. He further relied upon the judicial precedent of Privy Council Maharajkumar Gopal Saran Narain Singh [3 ITR 237]. Accordingly, since the ground of appeal does not arise out of the issue in assessment proceedings, he held it to be not maintainable and dismissed. 133) The learned authorized representative submitted that this issue is covered squarely in favour of the assessee by the decision of the coordinate bench Bangalore tribunal in case of state ba…

Economic Explosives Limited, Nagpur vs. National E Assessment Centre, New Delhi

In the result, appeal for the assessment year 2018–19 filed by the assessee is partly allowed

ITA 242/NAG/2023[2018-19]Status: DisposedITAT Nagpur09 Sept 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mani JainFor Respondent: Shri Kailash C. Kanojiya
Section 139Section 142(1)Section 143(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY, ACCOUNTANT, MEMBER ITA no.177/Nag./2022 (Assessment Year : 2017–18) Economic Explosives Ltd. 11, Zade Layout, Bharat Nagar ……………. Appellant Nagpur 440 033 PAN – AAACE3871C v/s Asstt. Commissioner of Income Tax ……………. Respondent Central Circle–1(2), Nagpur ITA no.242/Nag./2023 (Assessment Year : 2018–19) Economic Explosives Ltd. 11, Zade Layout, Bharat Nagar ……………. Appellant Nagpur 440 033 PAN – AAACE3871C v/s Asstt. Commissioner of Income Tax ……………. Respondent Central Circle–1, Nagpur Assessee…

Economic Explosives Limited, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 1 (2), Nagpur

In the result, appeal for the assessment year 2018–19 filed by the assessee is partly allowed

ITA 177/NAG/2022[2017-18]Status: DisposedITAT Nagpur09 Sept 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mani JainFor Respondent: Shri Kailash C. Kanojiya
Section 139Section 142(1)Section 143(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY, ACCOUNTANT, MEMBER ITA no.177/Nag./2022 (Assessment Year : 2017–18) Economic Explosives Ltd. 11, Zade Layout, Bharat Nagar ……………. Appellant Nagpur 440 033 PAN – AAACE3871C v/s Asstt. Commissioner of Income Tax ……………. Respondent Central Circle–1(2), Nagpur ITA no.242/Nag./2023 (Assessment Year : 2018–19) Economic Explosives Ltd. 11, Zade Layout, Bharat Nagar ……………. Appellant Nagpur 440 033 PAN – AAACE3871C v/s Asstt. Commissioner of Income Tax ……………. Respondent Central Circle–1, Nagpur Assessee…

DCIT, New Delhi vs. M/S. Ambreen Projects & Infrastrcture (P) Ltd., New Delhi

In the result, the appeal of the Revenue is allowed

ITA 4037/DEL/2013[2009-10]Status: DisposedITAT Delhi24 Nov 2021AY 2009-10

Bench: Shri O.P. Kant & Shri Kuldip Singh[Through Video Conferencing] Assessment Year: 2009-10

Section 132Section 132(4)Section 139(1)Section 143(3)Section 153CSection 69B

…id by Lord Wright in Kamakshya Narayan Singh v. CIT [(1943) 11 ITR 513 (PC)] “income ... is a word difficult and perhaps impossible to define in any precise general formula. It is a word of the broadest connotation”. In Gopal Saran Narain Singh v. CIT [(1935) 3 ITR 237 (PC)] the Privy Council pointed out that “anything that can properly be described as income is taxable under the Act unless expressly exempted”. This Court had to deal with the ambit of the tax expression ‘income’ in Navinchandra Mafatlal v. CIT [AIR 1955 SC 58]. The Indian Income Tax and Excess Profits Tax (Amendment) Act, 1947 had inserted Sectio…

Shiv Kumar Jatia, New Delhi vs. ITO, Ward- 10(2), New Delhi

The appeals of the assessee are allowed

ITA 7256/DEL/2019[2011-12]Status: DisposedITAT Delhi26 Apr 2021AY 2011-12

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumar(Through Video Conferencing) Ita No. 7256/Del/2019 : Asstt. Year : 2011-12 Ita No. 241/Del/2019 : Asstt. Year : 2013-14 Sh. Shiv Kumar Jatia, Vs Income Tax Officer, B-50, Gulmohar Park, Ward-10(2), New Delhi-110049 New Delhi-110002 (Appellant) (Respondent) Pan No. Aabpj7582K Assessee By : Sh. C. S. Aggarwal, Sr. Adv. Revenue By : Sh. Prakash Dubey, Sr. Dr Date Of Hearing: 10.03.2021 Date Of Pronouncement: 26.04.2021

For Appellant: Sh. C. S. Aggarwal, Sr. AdvFor Respondent: Sh. Prakash Dubey, Sr. DR
Section 10Section 10(38)Section 2(24)Section 71Section 74

…ined u/s 2(47) of the I.T. Act. 1961. 3. The receipt then has to be considered from the view of specific provision of exemption under Chapter III of the Income Tax Act, 1961. The Privy Council in its landmark judgment in Gopal Saran Narain Singh vs CIT (1935) 3 ITR 237 PC] laid down that “anything that can be properly described as income is taxable under the Act unless expressly exempted”. Chapter III explicitly provides for the income which does not form part of total income. If the receipt is covered by the provisions of Chapter III, particularly Section 10, then even if the receipt is in nature of the income i…

Shiv Kumar Jatia, New Delhi vs. ITO, Ward- 10(2), New Delhi

The appeals of the assessee are allowed

ITA 241/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Apr 2021AY 2013-14

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumar(Through Video Conferencing) Ita No. 7256/Del/2019 : Asstt. Year : 2011-12 Ita No. 241/Del/2019 : Asstt. Year : 2013-14 Sh. Shiv Kumar Jatia, Vs Income Tax Officer, B-50, Gulmohar Park, Ward-10(2), New Delhi-110049 New Delhi-110002 (Appellant) (Respondent) Pan No. Aabpj7582K Assessee By : Sh. C. S. Aggarwal, Sr. Adv. Revenue By : Sh. Prakash Dubey, Sr. Dr Date Of Hearing: 10.03.2021 Date Of Pronouncement: 26.04.2021

For Appellant: Sh. C. S. Aggarwal, Sr. AdvFor Respondent: Sh. Prakash Dubey, Sr. DR
Section 10Section 10(38)Section 2(24)Section 71Section 74

…ined u/s 2(47) of the I.T. Act. 1961. 3. The receipt then has to be considered from the view of specific provision of exemption under Chapter III of the Income Tax Act, 1961. The Privy Council in its landmark judgment in Gopal Saran Narain Singh vs CIT (1935) 3 ITR 237 PC] laid down that “anything that can be properly described as income is taxable under the Act unless expressly exempted”. Chapter III explicitly provides for the income which does not form part of total income. If the receipt is covered by the provisions of Chapter III, particularly Section 10, then even if the receipt is in nature of the income i…

National Textile Corporation Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, appeal of Assessee dismissed

ITA 2471/DEL/2017[2007-08]Status: DisposedITAT Delhi01 Oct 2019AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: Shri Manoj Kumar Anand, C.AFor Respondent: Shri K. Hauthang, Sr. D.R
Section 14Section 2(24)Section 5Section 56(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “E”: DELHI BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER ITA.No.2471/Del./2017 Assessment Year 2007-2008 M/s. National Textile The Addl. CIT, Corporation Ltd., Core-4, Special Range-6, Room vs., Scope Complex-7, Lodhi No.352, C.R. Building, Road, New Delhi- 110 003. New Delhi. PAN AAACN2847D (Appellant) (Respondent) For Assessee : Shri Manoj Kumar Anand, C.A. For Revenue : Shri K. Hauthang, Sr. D.R. Date of Hearing : 25.09.2019 Date of Pronouncement : 01.10.2019 ORDER PER BHAVNESH SAINI, J.M. This appeal by Assessee has been d…

Cable Corporation of India Ltd, Mumbai vs. DCIT Circle 2(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6558/MUM/2017[2010-11]Status: DisposedITAT Mumbai31 May 2019AY 2010-11

Bench: Shri Rajesh Kumar & Shri Amarjeet Singhassessment Year: 2010-11

For Appellant: Shri Perey Pareliwala, A.RFor Respondent: Shri Awangshi Gimson, D.R
Section 143(1)Section 2(24)Section 56

…the hands of the Appellant. The word "income" is not limited by the words "profits" and "gains" and anything which can properly be described as income is taxable under this Act, unless expressly exempted. Maharaj Kumar Gopal Saran Narain Singh vs. CIT, (1935) 3 ITR 237, 242 (PC); Raja Bahadur Kamakshya Narain Singh vs. CIT, (1943) 11 ITR 513, 522 (PC); Kedar Narain Singh vs. CIT (1938) 6 ITR 157, 161(AIl). Thus, in the light of above factual references and judicial propositions, it is held that there is no genuine Gift of Equity Shares and the worth of share taken by the Appellant is evidently a taxable income h…

Gopal Saran Narain Singh v. CIT (3 ITR 237) — Cited in 9 Judgments | BharatTax