Govind Das v. ITO

103 ITR 123Supreme Court of India1976#1380 most cited

What is Govind Das v. ITO authority for?

Taxing provisions imposing new liabilities or affecting substantive rights are presumed to operate prospectively unless the statute expressly or necessarily implies retrospective application. Retrospective operation is generally not given if it impairs existing rights, creates new obligations, or imposes new liabilities, except for procedural matters.

83

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2025.

Also referred to as

Govind Das v. ITO · 103 ITR 123 · prospective operation · retrospective application · statutory interpretation · taxing provisions · new liability · fiscal amendments · Section 171(6) · Income Tax Act

Sections most often in play

Section 1894Section 1961Section 10(37)Section 142(1)Section 143(2)Section 45(5)Section 56(2)(viii)Section 14

Issues it is cited on

section 2(viii)section 56(viii)section 45(5)(c)section 155(16)section 23(1a)section 104section 45(5)(b)section 145b(1)section 194lakeyman insurancesection 160section 23(2)

Judgments citing Govind Das v. ITO

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

ITA 992/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh11 Nov 2025AY 2023-24

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…is principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan Electro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon’ble Court held that a subsequent amendment cannot impose a tax burden for a period when such liability did not e…

BALBIR SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, SIRSA, HARYANA

ITA 483/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

BISHAN CHAND,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5 (5), CHANDIGARH, CHANDIGARH

ITA 458/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

SAT PAL,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5(5), , CHANDIGARH

ITA 243/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

GURDEEP SINGH HUF,CHANDIGARH vs. ITO, WARD 5(5), CHANDIGARH

ITA 1153/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

BALJEET KAUR,NADI MOHALLA AMBALA CITY vs. ITO WARD 1, AMBALA, AMBALA

ITA 92/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

ITA 876/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…is principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan Electro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon’ble Court held that a subsequent amendment cannot impose a tax burden for a period when such liability did not e…

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

ITA 663/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21
For Respondent: \nShri Suraj Bhan Nain, Advocate

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

ANJU,MOHALI vs. INCOME TAX OFFICER WARD 6 (1) , MOHALI

ITA 563/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

ITA 531/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…is principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan Electro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon’ble Court held that a subsequent amendment cannot impose a tax burden for a period when such liability did not e…

SAMAY SINGH,YAMUNANAGAR vs. ITO-WARD (5), YAMUNANAGAR

ITA 435/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

INCOME TAX OFFICER, INCOME TAX OFFICE BARNALA vs. LAKHVIR SINGH, GRAIN MARKET, BARNALA

ITA 245/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh11 Nov 2025AY 2021-22
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

BALJIT SINGH,AMBALA CITY vs. INCOME TAX OFFICER, WARD-1, AMBALA, AMBALA

ITA 176/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

BALBIR KUMAR HUF,CHANDIGARH vs. ITO , CHANDIGARH

ITA 172/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…is principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan Electro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon’ble Court held that a subsequent amendment cannot impose a tax burden for a period when such liability did not e…

PREETO THROUGH L/H GURMUKH SINGH,PANCHKULA vs. ITO, WARD NO. 3, PANCHKULA

ITA 1176/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

PAWAN KUMAR,FATEHABAD vs. INCOME TAX OFFICER WARD-1, FATEHABAD

ITA 1112/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…is principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan Electro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon’ble Court held that a subsequent amendment cannot impose a tax burden for a period when such liability did not e…

SH. TEJ RAM,CHANDIGARH vs. ITO, WARD -5, PANCHKULA

ITA 697/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

RAGHBIR SINGH HUF,CHANDIGARH vs. ITO-WARD-1(3), CHANDIGARH

ITA 617/CHANDI/2023[2017-2018]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-2018
For Respondent: \nShri Suraj Bhan Nain, Advocate

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

INCOME TAX OFFICER, WARD-5(5), CHANDIGARH, CHANDIGARH vs. AVTAR SINGH, VILLAGE- KAIMBWALA

ITA 615/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan\nElectro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon'ble Court held that a\nsubsequent amendment cannot impose a tax burden for a period when such\nliability did…

SH. AMARDEEP SINGH ATHWAL,YAMUNANAGAR vs. ITO, WARD-1, YAMUNANAGAR

ITA 566/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…is principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hindustan Electro Graphites Ltd. (2000) 243 ITR 48 (SC), the Hon’ble Court held that a subsequent amendment cannot impose a tax burden for a period when such liability did not e…

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Govind Das v. ITO (103 ITR 123) — Cited in 83 Judgments | BharatTax