In\nSedco Forex International Drilling Inc. v. CIT

279 ITR 310Supreme Court of India2005#920 most cited

What is In\nSedco Forex International Drilling Inc. v. CIT authority for?

A tax amendment explicitly stating an effective date applies prospectively from that date. Even if an amendment is labelled 'for removal of doubts,' it cannot be presumed retrospective if it alters or changes the law as it earlier stood.

116

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2026.

Also referred to as

Sedco Forex International Drilling Inc. v. CIT · retrospective amendment · prospective application · amendment effective date · removal of doubts · statutory interpretation · tax law changes · Income Tax Act amendment

Sections most often in play

Section 14ASection 143(3)Section 143(2)Section 142(1)Section 56(2)(viii)Section 10(37)Section 143(1)Section 145B(1)

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 In\nSedco Forex International Drilling Inc. v. CIT

BHUPENDRA FLOUR MILLS PVT LTD,BATHINDA vs. ITO, WARD 1(1), BATHINDA, BATHINDA

The appeal stands partly allowed in terms of out above order

ITA 54/ASR/2025[2017-18]Status: DisposedITAT Amritsar20 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayandasgupta, Jm आयकरअपीलसं. / Ita No.54/Asr/2025 (िनधा"रणवष" / Assessment Year: 2017-18) M/S Bhupendra Flour Mills Pvt Ltd. Ito Ward - 1(1) बनाम/ Railway Road Central Revenue Building Bhatinda, Punjab – 151001 Civil Lines, Bhatinda Vs. Punjab - 151001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccb-6192-P (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Sh. Farhat Khan (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05-02-2026 घोषणाकीतारीख /Date Of Pronouncement 20.02.2026 : आदेश / O R D E R

For Appellant: Sh. Sudhir Sehgal (Advocate) - Ld. ARFor Respondent: Sh. Farhat Khan (CIT) – Ld. DR (Virtual)
Section 10(37)Section 14Section 143(3)Section 145B(1)Section 194LSection 2Section 2(24)Section 36Section 4Section 45(5)

…various provisions of law, as mentioned herein above. 61. Equally, the principle is well-settled that a judicial interpretation continues to apply only until the Legislature steps in and amends the law. In Sedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the Hon’ble Supreme Court held that judicial interpretation stands superseded when the statutory provision is subsequently amended prospectively. It was held asunder:- XXXXX 62. Applying these settled principles, it is clear that the ratio of Ghanshyam (HUF) (supra) represents the legal position under the unamended law, whereas with the i…

ACIT, MUMBAI vs. K RAHEJA CORP PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 6083/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Jan 2026AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2020-21

For Respondent: Mr. Paresh Sondagar, CA
Section 11SSection 14A

…the assessee has relied on the following decision of the Hon'ble Supreme Court: decision of the Hon'ble Supreme Court: a) MM Aqua Technologies Vs CIT (436 ITR 582) a) MM Aqua Technologies Vs CIT (436 ITR 582) b) Sedco Forex International Drilling Inc Vs CIT (279 ITR 310) b) Sedco Forex International Drilling Inc Vs CIT (279 ITR 310) b) Sedco Forex International Drilling Inc Vs CIT (279 ITR 310) Also, appellant has relied on various other Also, appellant has relied on various other decisions of High court and decisions of High court and tribunal. 7.3 I have considered the facts of the case, statement of facts, gr…

GURMEET SINGH,PANCHKULA vs. INCOME TAX OFFICER, PANCHKULA

The appeal of the assessee is dismissed

ITA 1287/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh14 Jan 2026AY 2015-16

Bench: Tribunal.

For Appellant: NoneFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 10(37)Section 14Section 143(3)Section 145B(1)Section 194LSection 2Section 2(24)Section 28Section 4Section 45(5)

…various provisions of law, as mentioned herein above. 61. Equally, the principle is well-settled that a judicial interpretation continues to apply only until the Legislature steps in and amends the law. In Sedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the Hon’ble Supreme Court held that judicial interpretation stands superseded when the statutory provision is subsequently amended prospectively. It was held as under:- XXXXX 62. Applying these settled principles, it is clear that the ratio of Ghanshyam (HUF) (supra) represents the legal position under the unamended law, whereas with the i…

ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

ITA 1616/CHNY/2025[2017]Status: DisposedITAT Chennai14 Nov 2025

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

For Appellant: Shri. K. Prasanna, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115QSection 250Section 263Section 391Section 77A

…rbook). As the Finance Billy Memorandum specifically clarifies that the amendment made shall take effect from 01 June 2016, it cannot be said to have a retrospective application. • The Hon'ble Supreme Court in the case of Sedco Forex International Drill Inc. (279 ITR 310) has held that when a provision/ amendment is specifically clarified to take effect from a particular date, the same shall come into force from such date and cannot said to have a retrospective application (refer para 12, 18 and 20 of the judgement, pg no. 70 & 71 of the case laws paperbook). • A similar position was taken in the below mentioned…

M/S. UPDATER SERVICES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

ITA 1339/CHNY/2025[2017-18]Status: DisposedITAT Chennai14 Nov 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

For Appellant: Shri. K. Prasanna, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115QSection 250Section 263Section 391Section 77A

…rbook). As the Finance Billy Memorandum specifically clarifies that the amendment made shall take effect from 01 June 2016, it cannot be said to have a retrospective application. • The Hon'ble Supreme Court in the case of Sedco Forex International Drill Inc. (279 ITR 310) has held that when a provision/ amendment is specifically clarified to take effect from a particular date, the same shall come into force from such date and cannot said to have a retrospective application (refer para 12, 18 and 20 of the judgement, pg no. 70 & 71 of the case laws paperbook). • A similar position was taken in the below mentioned…

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

…various provisions of law, as mentioned herein above. 61. Equally, the principle is well-settled that a judicial interpretation continues to apply only until the Legislature steps in and amends the law. In Sedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the Hon’ble Supreme Court held that judicial interpretation stands superseded when the statutory provision is subsequently amended prospectively. It was held asunder:- 12. In our view the 1999 Explanation could not apply to assessment years for the simple reason that it had not come into effect then. Prior to introducing the 1999 Explanatio…

BHUPINDER SINGH,AMBALA vs. INCOME TAX OFFICER, W-1, AMBALA, AMBALA

ITA 528/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15
For Respondent: \nShri Suraj Bhan Nain, Advocate

…us provisions of\nlaw, as mentioned herein above.\n61.\nEqually, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

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

…ous provisions of\nlaw, as mentioned herein above.\n61. Equally, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

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

…ous provisions of\nlaw, as mentioned herein above.\n61. Equally, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

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

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

…us provisions of\nlaw, as mentioned herein above.\n61.\nEqually, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

NARENDER KAUR,KURUKSHETRA, HARYANA vs. INCOME TAX OFFICER WARD-1 , KURUKSHETRA

ITA 165/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…us provisions of\nlaw, as mentioned herein above.\n61.\nEqually, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

BALVINDER SINGH,FATEHABAD vs. ITO WARD-1, FATEHABAD

ITA 153/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

…ous provisions of\nlaw, as mentioned herein above.\n61. Equally, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

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

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

…us provisions of\nlaw, as mentioned herein above.\n61.\nEqually, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

JARNAIL SINGH,VILLAGE BHAGWANPUR, KALKA vs. ITO, WARD-2, PANCHKULA

ITA 1025/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…ous provisions of\nlaw, as mentioned herein above.\n61. Equally, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

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

…us provisions of\nlaw, as mentioned herein above.\n61.\nEqually, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

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

…various provisions of law, as mentioned herein above. 61. Equally, the principle is well-settled that a judicial interpretation continues to apply only until the Legislature steps in and amends the law. In Sedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the Hon’ble Supreme Court held that judicial interpretation stands superseded when the statutory provision is subsequently amended prospectively. It was held asunder:- 12. In our view the 1999 Explanation could not apply to assessment years for the simple reason that it had not come into effect then. Prior to introducing the 1999 Explanatio…

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

…ous provisions of\nlaw, as mentioned herein above.\n61. Equally, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

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

…us provisions of\nlaw, as mentioned herein above.\n61.\nEqually, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

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

…various provisions of law, as mentioned herein above. 61. Equally, the principle is well-settled that a judicial interpretation continues to apply only until the Legislature steps in and amends the law. In Sedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the Hon’ble Supreme Court held that judicial interpretation stands superseded when the statutory provision is subsequently amended prospectively. It was held asunder:- 12. In our view the 1999 Explanation could not apply to assessment years for the simple reason that it had not come into effect then. Prior to introducing the 1999 Explanatio…

SARVAN SINGH,AMBALA vs. INCOME TAX OFFICER-WARD 4, AMBALA

ITA 458/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…ous provisions of\nlaw, as mentioned herein above.\n61. Equally, the principle is well-settled that a judicial interpretation\ncontinues to apply only until the Legislature steps in and amends the law. In\nSedco Forex International Drilling Inc. v. CIT (2005) 279 ITR 310 (SC), the\nHon'ble Supreme Court held that judicial interpretation stands superseded\nwhen the statutory provision is subsequently amended prospectively. It was\nheld asunder:-\n12. In our view the 1999 Explanation could not apply to assessment years for\nthe simple reason that it had not come into effect then. Prior to introducing\nthe 1999 Expl…

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