(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

Issues it is cited on

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

Oracle India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeals of the Assessee in ITA No

ITA 938/DEL/2016[2007-08]Status: DisposedITAT Delhi28 Jan 2026AY 2007-08

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaloracle India Private Limited Vs Addl. Cit F-01/02, 1St Floor, Salcon Range-13 Rasvilas, D-1, District Centre, New Delhi Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Oracle India Private Limited Vs Dcit F-01/02, 1St Floor, Circle-19(1) Salconrasvilas, D-1, District New Delhi Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Dcit Vs Oracle India Private Limited Circle-19(1) F-01/02, 1St Floor, Salcon New Delhi Rasvilas, D-1, District Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Assessee By Sh. Naveen Dhamija, Ca, Sh. Vishal Aggarwal, Ca& Sh. Rinku Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144CSection 153Section 154

…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…

DCIT, New Delhi vs. M/S. Oracle India Pvt. Ltd., New Delhi

In the result, appeals of the Assessee in ITA No

ITA 7015/DEL/2014[2007-08]Status: DisposedITAT Delhi28 Jan 2026AY 2007-08

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaloracle India Private Limited Vs Addl. Cit F-01/02, 1St Floor, Salcon Range-13 Rasvilas, D-1, District Centre, New Delhi Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Oracle India Private Limited Vs Dcit F-01/02, 1St Floor, Circle-19(1) Salconrasvilas, D-1, District New Delhi Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Dcit Vs Oracle India Private Limited Circle-19(1) F-01/02, 1St Floor, Salcon New Delhi Rasvilas, D-1, District Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Assessee By Sh. Naveen Dhamija, Ca, Sh. Vishal Aggarwal, Ca& Sh. Rinku Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144CSection 153Section 154

…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. Oracle India Private Limited, New Delhi vs. Addl.CIT, New Delhi

In the result, appeals of the Assessee in ITA No

ITA 6907/DEL/2014[2007-08]Status: DisposedITAT Delhi28 Jan 2026AY 2007-08

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaloracle India Private Limited Vs Addl. Cit F-01/02, 1St Floor, Salcon Range-13 Rasvilas, D-1, District Centre, New Delhi Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Oracle India Private Limited Vs Dcit F-01/02, 1St Floor, Circle-19(1) Salconrasvilas, D-1, District New Delhi Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Dcit Vs Oracle India Private Limited Circle-19(1) F-01/02, 1St Floor, Salcon New Delhi Rasvilas, D-1, District Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Assessee By Sh. Naveen Dhamija, Ca, Sh. Vishal Aggarwal, Ca& Sh. Rinku Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

Section 143(3)Section 144CSection 153Section 154

…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…