(ii) Govt. of India v. Citedal Fine Pharmaceuticals

3 SCC 483Reported decision1989#910 most cited

What is (ii) Govt. of India v. Citedal Fine Pharmaceuticals authority for?

The absence of a specific limitation period for recovery of duty or tax does not, by itself, render a rule arbitrary or unconstitutional under Article 14, provided authorities act with expedition and adhere to principles of natural justice.

116

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2026.

Also referred to as

Govt. of India v. Citedal Fine Pharmaceuticals · 3 SCC 483 · Section 144C · Section 153 · absence of limitation for recovery · Article 14 · arbitrary recovery · natural justice · expedition · reasonable haste

Sections most often in play

Section 144C(13)Section 153(4)Section 153(1)Section 143(3)Section 153Section 144BSection 144CSection 153(2A)

Issues it is cited on

section 144cofsection 158absection 261section 11(3)impermissible avoidance arrangementsection 153(4)section 144c(4)section 22(1)reference to tpostay of demandsection 141section 21

Judgments citing (ii) Govt. of India v. Citedal Fine Pharmaceuticals

Renew Wind Energy (Rajkot) Private Limited, Delhi vs. Deputy Commissioner of Income-Tax, Circle 19(1), Delhi

In the result, appeals of the Assessees are allowed

ITA 4421/DEL/2024[2020-2021]Status: DisposedITAT Delhi29 Jan 2026AY 2020-2021

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrenew Wind Energy (Shivpur) Vs The Deputy Commissioner Of Private Limited, 138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikaji Cama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4810H New Delhi Appellant Respondent Renew Wind Energy (Rajkot) Vs The Deputy Commissioner Of Private Limited,138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikajicama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4553H New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Rohde and Schwarz India Private Limited, New Delhi vs. Assessment Unit, the Deputy Commissioner of Income Tax, Circle 19(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 4414/DEL/2024[2020-21]Status: DisposedITAT Delhi29 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrohde & Schwarz India Private Vs Assessment Unit, The Limited Deputy Commissioner Of A-27, First Floor Mohan Cooperative Income Tax, Circle 19(1), Industrial Estate, Mathura Road, New Delhi New Delhi-110044 Pan: Aaacr3267P Appellant Respondent Assessee By Ms. Snigdha Gautam, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Zimmer India Private Limited, Gurgaon, Haryana vs. The Deputy Commissioner of Income Tax, Gurgaon, Haryana

In the result, appeal of the Assessee is allowed

ITA 4314/DEL/2024[2020-21]Status: DisposedITAT Delhi29 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayzimmer India Private Limited V The Deputy Commissioner Vanijya Nikunj, Enkay Towers, Unit S Of Income Tax, Circle 3(1) No. 6Th Floor, Udyog Vihar, Phase-V, Hsiidc Building, Udyog Gurgaon, 122016, Haryana Vihar V, Gurugram Haryana Pan: Aaecs7432H Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Renew Wind Energy (Shivpur) Private Limited, Delhi vs. Deputy Commissioner of Income-Tax, Circle 19(1), Delhi

In the result, appeals of the Assessees are allowed

ITA 4238/DEL/2024[2020-2021]Status: DisposedITAT Delhi29 Jan 2026AY 2020-2021

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrenew Wind Energy (Shivpur) Vs The Deputy Commissioner Of Private Limited, 138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikaji Cama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4810H New Delhi Appellant Respondent Renew Wind Energy (Rajkot) Vs The Deputy Commissioner Of Private Limited,138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikajicama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4553H New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Fev India Private Limited, Delhi vs. Assessment Unit, National Faceless Assessment Centre

In the result, appeal of the Assessee is allowed

ITA 4148/DEL/2024[2020-21]Status: DisposedITAT Delhi29 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayfev India Private Limited V Assessment Unit B-260, Greater Kailash-1, New S National Faceless Delhi, South East, Delhi,110048 Assessment Centre, Income Pan: Aaacf9589Q Tax Department, New Delhi Appellant Respondent Assessee By Sh. Nikhil Tiwari, Ca (Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)Section 5

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Johnson Matthey India Pvt. Ltd., New Delhi vs. ACIT Circle 13(1), New Delhi

In the result, appeals of the Assessees are allowed

ITA 3953/DEL/2024[2020-21]Status: DisposedITAT Delhi29 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaljohnson Matthey India P. Ltd. Vs The Deputy Commissioner Of C/O. Luthra & Luthra Law Income Tax, Circle 13(2) Office India, 103, Ashoka Estate, Spm Civic Centre, New Delhi Barakhamba Road, New Delhi Pan: Aaacj2919A Appellant Respondent Johnson Matthey India P. Ltd. Vs National Faceless Appeal 5Th Floor, C/O Regus Business Centre, Income Tax Center, Gurgaon, Road, South Department West Delhi Pan: Aaacj2919A Appellant Respondent Assessee By Sh. Sumit Mangal, Adv, Ms. Radhika Sharma, Adv& Ms. Soumya Pandey, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Google India Digital Services Private Limited, Delhi vs. Au, NFAC, ACIT(OSD), Range 42, Delhi

In the result, appeal of the Assessee is allowed

ITA 3311/DEL/2024[2020-21]Status: DisposedITAT Delhi29 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaygoogle India Digital Servicdes V Assessment Unit, Private Limited. 5Th Floor, Dlf S Nfac, Acit (Osd), Range Centre Block, 124, Sansad Marg, 42, C. R. Building, H. O. Central Delhi, New Delhi New Delhi Pan: Aagcg6803L Appellant Respondent Assessee By Sh. Kanchan Kaushal, Ar Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Groupe Seb India Pvt Ltd, Gurugram vs. ACIT, (OSD), New Delhi

In the result, appeal of the Assessee is allowed

ITA 2401/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaygroupe Seb India Pvt. Ltd. Vs Acit (Osd) Vipul Plaza, 215-220, Golf Course Range-10, C. R. Building, Road Suncity, Sector-54, Gurgaon, New Delhi Haryana Pan: Aagcm6857L Appellant Respondent Assessee By Ms. Shruti Khimta, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 153Section 153(1)Section 153(4)Section 202

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 12 Groupe SEB India Pvt. Ltd. Vs. ACIT (OSD) 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitr…

Ball Beverage Packaging(India) Pvt Ltd, Bangalore vs. DCIT, Circle-4 (2), Delhi

In the result, appeal of the Assessee is allowed

ITA 2382/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Jan 2026AY 2018-19

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayball Beverage Packaging (India) Pvt. V Dcit, Circle-4(2) Ltd. B-302, 3Rd Floor B Wing Brigade S New Delhi-110002 Magnum, Amruthali, Nh-7, International Airport Road, Bangaluru, Not Listed, 560092 Pan: Aabch77101B Appellant Respondent Assessee By Ms. Snigdha Gautam, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Vatika Seven Elements Pvt. Ltd., New Delhi vs. ACIT Circle 25(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 1525/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Krinwant Sahay, Accountnat Member [Assessment Year: 2018-19]

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Denso Subros Thermal Engineering Centre P.Ltd, New Delhi vs. ACIT, Circle-7(1), New Delhi

In the result, appeals of the Assessees are allowed

ITA 1486/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Krinwant Sahay, Accountnat Member

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Denso India Private Ltd., Delhi vs. ACIT Circle-7(1), Delhi

In the result, appeals of the Assessees are allowed

ITA 1485/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Krinwant Sahay, Accountnat Member

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Denso India Private Limited, Delhi vs. ACIT, Circle-7(1), Delhi

In the result, appeals of the Assessees are allowed

ITA 1484/DEL/2022[2017-18]Status: DisposedITAT Delhi29 Jan 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Krinwant Sahay, Accountnat Member

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Itron India P.Ltd, Delhi vs. DCIT, Circle-10(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 1235/DEL/2022[2017-18]Status: DisposedITAT Delhi29 Jan 2026AY 2017-18

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalitron India P. Ltd. Vs The Deputy Commissioner Of Flat No. 507, Income Tax, Circle 10(1), Bhikajicamabhawan, C. R. Building, New Delhi Bhikajicama Place, New Delhi Pan: Aabcs6575L Appellant Respondent Assessee By Sh.Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Ahresty India Pvt. Ltd., Rewari vs. ACIT, Circle, Rewari

In the result, appeal of the Assessee is allowed

ITA 7415/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Jan 2026AY 2014-15

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayahresty India Private Limited Vs Acit (Ld. A.O.) Plot No. 194, Sector-4, Phase Ii, Circle-Rewari, Haryana Hsidc, Growth Centre, Bawlal, Distrewari, Haryana, 123501 Pan: Aagca1057N Appellant Respondent Assessee By Ms. Snigdha Gautam, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 29/01/2026

Section 143(3)Section 144BSection 144CSection 144C(1)Section 144C(13)Section 144C(5)Section 153Section 153(1)Section 153(4)Section 92C

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Ls Cable India P.Ltd., Rewari vs. Addl.CIT, Special Range-5, New Delhi

In the result, appeals of the Assessee in ITA No

ITA 4665/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Jan 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

Ls Cable India Pvt. Ltd., Haryana vs. ACIT, New Delhi

In the result, appeals of the Assessee in ITA No

ITA 1961/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Jan 2026AY 2012-13

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 144CSection 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

M/S. Cosmo Films Ltd., New Delhi vs. ACIT, New Delhi

In the result, appeals of the Assessees are allowed

ITA 1580/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Jan 2026AY 2012-13

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaycosmo Films Ltd. Vs Ddit 1008, Dlf Tower-A, Circle-3(1), Jasola District Centre, New Delhi New Delhi Pan: Aaacc1152C Appellant Respondent

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

M/S Cosmo Films Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeals of the Assessees are allowed

ITA 4453/DEL/2015[2011-12]Status: DisposedITAT Delhi29 Jan 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaycosmo Films Ltd. Vs Ddit 1008, Dlf Tower-A, Circle-3(1), Jasola District Centre, New Delhi New Delhi Pan: Aaacc1152C Appellant Respondent

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…

M/S. Cosmo Films Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeals of the Assessees are allowed

ITA 1192/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Jan 2026AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaycosmo Films Ltd. Vs Ddit 1008, Dlf Tower-A, Circle-3(1), Jasola District Centre, New Delhi New Delhi Pan: Aaacc1152C Appellant Respondent

Section 143(3)Section 144BSection 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

…or the State Governments to require, by statutory rules or appropriate instructions, to ensure completion of assessments with expedition and reasonable haste but subject to rules of natural justice" (ii) Govt. of India v. Citedal Fine Pharmaceuticals, [(1989) 3 SCC 483 1989 SCC (Tax) 464 at page 487] 6. Learned counsel appearing for the respondents urged that Rule 12 is unreasonable and violative of Article of for the recovery of duty. He urged that in the absence of any prescribed period for recovery of the duty as contemplated by Rule 12. the officer may act arbitrarily in recovering the amount after lapse of l…