Indian Farmers Fertilizers Co-operative Ltd. v. Jt. CIT

105 ITD 33Income Tax Appellate Tribunal2007#8685 most cited
12

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2022 to 2025.

Sections most often in play

Section 10(38)Section 133(6)Section 133ASection 143(2)Section 143(3)Section 144BSection 147Section 148

Issues it is cited on

revision u/s 263mere change of opinionsection 263(1)revision under section 263change of opinionborrowed satisfactionerroneous and prejudiciallevy of penaltyservice of noticeentry operatorreason to believesection 149

Judgments citing Indian Farmers Fertilizers Co-operative Ltd. v. Jt. CIT

ASHOK KUMAR JAIN,DELHI vs. PR, CIT 20, NEW DELHI

ITA 2641/DEL/2025[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2018-19 Ashok Kumar Jain, Vs. Pr. Cit-20, C/O Kapil Goel, Advocate, New Delhi. F-26/124, Sector-7, Rohini, Delhi – 110 085. Pan: Aakpj1872B

For Appellant: Dr. Kapil Goel, AdvocateFor Respondent: Ms Pooja Swaroop, CIT-DR
Section 147Section 148ASection 151Section 263Section 69C

…nce in favour of the assessee. 8.7. It is further noted that many of these judgments were discussed and followed by the Co-ordinate Bench of the Tribunal in the case of Indian Farmers Fertilizers Co-operative Ltd. vs. Jt. CIT (2007) 107 TTJ (Del) 98 : (2007) 105 ITD 33 (Del), wherein a similar issue had arisen. In this case, the issue raised before the bench was whether it is open to the assessee, not having appealed against the reassessment order, to set up or canvass its correctness in collateral proceedings taken for rectification thereof under s.154. The bench minutely analysed law in this regard and applyin…

RAHUL RASTOGI,NEW DELHI vs. PCIT, GHAZIABAD

ITA 844/DEL/2024[2013-14]Status: DisposedITAT Delhi12 Sept 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

Section 147Section 151Section 263

…e in favour of the assessee. 8. 7. It is further noted that many of these judgments were discussed and followed by the Co-ordinate Bench of the Tribunal in the case of Indian Farmers Fertilizers Co-operative Ltd. vs. Jt. CIT (2007) 107 TTJ (Del) 98 : (2007) 105 ITD 33 (Del), wherein a similar issue had arisen. In this case, the issue raised before the bench was whether it is open to the assessee, not having appealed against the reassessment order, to set up or canvass its correctness in collateral proceedings taken for rectification thereof under s.154. The bench minutely analysed law in this regard and applyin…

SARENA PRIVATE LIMITED,DELHI vs. PCIT CENTRAL, DELHI-3, DELHI

ITA 2480/DEL/2024[2014-15]Status: DisposedITAT Delhi22 Aug 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Ambareesha Agrawal, CA &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 142(1)Section 143(1)Section 143(3)Section 147Section 263Section 263(1)

…in favour of the assessee. 8. 7. It is further noted that many of these judgments were discussed and followed by the Co- ordinate Bench of the Tribunal in the case of Indian Farmers Fertilizers Co-operative Ltd. vs. Jt. CIT (2007) 107 TTJ (Del) 98 : (2007) 105 ITD 33 (Del), wherein a similar issue had arisen. In this case, the issue raised before the bench was whether it is open to the assessee, not having appealed against the reassessment order, to set up or canvass its correctness in collateral proceedings taken for rectification thereof under s.154. The bench minutely analysed law in this regard and applyin…

SARENA PRIVATE LIMITED,DELHI vs. PR,CIT CENTRE DELHI-3, DELHI

ITA 2479/DEL/2024[2013-14]Status: DisposedITAT Delhi22 Aug 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Ambareesha Agrawal, CA &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 142(1)Section 143(1)Section 143(3)Section 147Section 263Section 263(1)

…e in favour of the assessee. 8. 7. It is further noted that many of these judgments were discussed and followed by the Co- ordinate Bench of the Tribunal in the case of Indian Farmers Fertilizers Co-operative Ltd. vs. Jt. CIT (2007) 107 TTJ (Del) 98 : (2007) 105 ITD 33 (Del), wherein a similar issue had arisen. In this case, the issue raised before the bench was whether it is open to the assessee, not having appealed against the reassessment order, to set up or canvass its correctness in collateral proceedings taken for rectification thereof under s.154. The bench minutely analysed law in this regard and applyin…

NEHA GOEL,FARIDABAD vs. PCIT , FARIDABAD

In the result, appeal of the assesse is allowed

ITA 2624/DEL/2024[2014-15]Status: DisposedITAT Delhi28 May 2025AY 2014-15

Bench: Sh. Shamim Yahya & Sh. Sudhir Kumarassessment Year: 2014-15 Neha Goel, Vs. Pcit, H. No. 585 Sector 15 Faridabad. Faridabad 121007. Pan No.Ahcpg6493Q (Appellant) (Respondent)

Section 10(38)Section 144BSection 147Section 148Section 148(2)Section 151Section 263

…rence in favour of the assessee. 8.7. It is further noted that many of these judgments were discussed and followed by the Co-ordinate Bench of the Tribunal in the case of Indian Farmers Fertilizers Co-operative Ltd. vs. Jt. CIT (2007) 107 TTJ (Del) 98: (2007) 105 ITD 33 (Del), wherein a similar issue had arisen. In this case, the issue raised before the bench was whether it is open to the assessee, not having appealed against the reassessment order, to set up or canvass its correctness in collateral proceedings taken for rectification thereof under s. 154. The bench minutely analysed law in this regard and applyi…

INDO PACIFIC FINLEASE LTD,CHANDIGARH vs. PCIT- CHANDIGARH 1, CHANDIGARH

In the result, both the appeals are filed by the\nassessee are allowed

ITA 449/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh16 Apr 2025AY 2015-16
For Appellant: \nSh. Ashok Goel, C.AFor Respondent: \nSh.Rohit Sharma, CIT-D.R
Section 147Section 148Section 203(1)Section 263

…ourt finally answered the reference in favour of\nthe assessee.\n\n8. 7. It is further noted that many of these judgments were discussed\nand followed by the co-ordinate bench of the Tribunal in the case of\nIndian Farmers Fertilizers Co-operative Ltd vs KIT 105 ITD 33 (Del),\nwherein a similar issue had arisen. In this case, the issue raised before\nthe bench was whether it is open to the assessee, not having\nappealed against the reassessment order, to set up or canvass its\ncorrectness in collateral proceedings taken for rectification thereof u/s\n154. The bench minutely analysed law in this regard and applyi…

INDO PACIFIC FINLEASE LTD,CHANDIGARH vs. PCIT CHANDIGARH 1, CHANDIGARH

In the result, both the appeals are filed by the\nassessee are allowed

ITA 448/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh16 Apr 2025AY 2014-15
For Appellant: \nSh. Ashok Goel, C.AFor Respondent: \nSh.Rohit Sharma, CIT-D.R
Section 147Section 148Section 203(1)Section 263

…Court finally answered the reference in favour of\nthe assessee.\n8. 7. It is further noted that many of these judgments were discussed\nand followed by the co-ordinate bench of the Tribunal in the case of\nIndian Farmers Fertilizers Co-operative Ltd vs KIT 105 ITD 33 (Del),\nwherein a similar issue had arisen. In this case, the issue raised before\nthe bench was whether it is open to the assessee, not having\nappealed against the reassessment order, to set up or canvass its\ncorrectness in collateral proceedings taken for rectification thereof u/s\n154. The bench minutely analysed law in this regard and applyi…

S S BRAHMA EDUCATIONAL TRUST,MAYURBHANJ vs. PRINICIPAL COMMISSIONER OF INCOME TAX, PCIT, SAMBALPUR, SAMBALPUR

In the result, appeal of the assessee is allowed

ITA 107/CTK/2024[2015-16]Status: HeardITAT Cuttack05 Jun 2024AY 2015-16
For Appellant: Shri P.K.Mishra, AdvocateFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 148Section 263Section 69

…ence in favour of the assessee. 8.7. It is further noted that many of these judgments were discussed and followed by the Co-ordinate Bench of the Tribunal in the case of Indian Farmers Fertilizers Co-operative Ltd. vs. Jt. CIT (2007) 107 TTJ (Del) 98 : (2007) 105 ITD 33 (Del), wherein a similar issue had arisen. In this case, the issue raised before the bench was whether it is open to the assessee, not having appealed against the reassessment order, to set up or canvass its correctness in collateral proceedings taken for rectification thereof under s. 154. The bench minutely analysed law in this regard and applyi…

ANIL NACHRANI,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BHOPAL, BHOPAL

The appeal of the assessee is allowed, in terms of our aforesaid observations

ITA 47/RPR/2022[2012-13]Status: DisposedITAT Raipur22 Nov 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No. 47/Rpr/2022) (Assessment Year: 2012-13)

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 143(2)Section 147Section 263Section 263(1)

…High Court finally answered the reference in favour of the assessee. 8.7. It is further noted that many of these judgments were discussed and followed by the co-ordinate bench of the Tribunal in the case of Indian Farmers Fertilizers Co-operative Ltd vs JCIT 105 ITD 33 (Del), wherein a similar issue had arisen. In this case, the issue raised before the bench was whether it is open to the assessee, not having appealed against the reassessment order, to set up or canvass its correctness in collateral proceedings taken for rectification thereof u/ s 154. The bench minutely analyzed law in this regard and applying t…

MADHUBAN DEALERS PVT. LTD. PRESENTLY KNOWN AS MADHUBAN DEALERS LLP,KOLKATA vs. PCIT-13, KOLKATA

In the result, the appeal of assessee allowed

ITA 273/KOL/2022[2010-11]Status: DisposedITAT Kolkata07 Nov 2023AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 154Section 263Section 68

….10.2021 (ITAT, Kol) 5 Madhuban Dealers Pvt. Ltd., AY 2010-11 ii) Westlife Development Pvt. Ltd. Vs. Pr. CIT (88 taxmann.com 349) (ITAT Mum.) iii) Krishna Kumar Saraf Vs. CIT (83 taxmann.com 331) (ITAT Del) iv) Indian Farmers Fertilizers Coop. Ltd. Vs. JCIT (105 ITD 33) (ITAT Del.) 9. The Ld. AR stated that notice u/s. 148 of the Act was issued without obtaining prior approval from JCIT/Addl. CIT in terms of section 151 of the Act and, therefore, the order passed u/s. 147 of the Act is null and void. In defense of his argument, he relied on the following decisions: i) CIT Vs. SPL Siddhartha Ltd. 345 ITR 223 (De…

ARUNA TIWARI,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

ITA 90/RPR/2022[2015-16]Status: DisposedITAT Raipur18 Jul 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 90/Rpr/2022 "नधा"रण वष" / Assessment Year : 2015-16 Smt. Aruna Tiwari 762, Sundar Nagar, Raipur (C.G.)-492 001 Pan: Adbpt4977B .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax-1, Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Nikhilesh Begani, CAFor Respondent: Shri V.K Singh, CIT-DR
Section 142(1)Section 143(3)Section 263

…High Court finally answered the reference in favour of the assessee. 8.7. It is further noted that many of these judgments were discussed and followed by the co-ordinate bench of the Tribunal in the case of Indian Farmers Fertilizers Co-operative Ltd vs JCIT 105 ITD 33 (Del), wherein a similar issue had arisen. In this case, the issue raised before the bench was whether it is open to the assessee, not having appealed against the reassessment order, to set up or canvass its correctness in collateral proceedings taken for rectification thereof u/s 154. The bench minutely analysed law in this regard and applying th…

MARUTI CLEAN COAL AND POWER LTD.,RAIPUR vs. PR. COMMISIONER INCOME TAX-1, RAIPUR

ITA 55/RPR/2021[2011-12]Status: DisposedITAT Raipur31 Oct 2022AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 55/Rpr/2021 "नधा"रण वष" / Assessment Year : 2011-12 Maruti Clean Coal & Power Ltd. Ward No.42, Building No.14, Civil Lines, Near Income Tax Colony, Chhattisgarh-492 001. Pan : Aadcm4810C .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax-1, Raipur (C.G.) ……""यथ" / Respondent Assessee By :Shri Salil Kapoor, Ms. Ananya Kapoor & Ms. Soumya Singh, Advocates. Revenue By :Shri P. K Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 05.08.2022 घोषणा क" तार"ख / Date Of Pronouncement : 31.10.2022

For Appellant: Shri Salil Kapoor, Ms. AnanyaFor Respondent: Shri P. K Mishra, CIT-DR
Section 143(3)Section 147Section 148Section 263Section 263(2)

…High Court finally answered the reference in favour of the assessee. 8.7. It is further noted that many of these judgments were discussed and followed by the co-ordinate bench of the Tribunal in the case of Indian Farmers Fertilizers Co-operative Ltd vs JCIT 105 ITD 33 (Del), wherein a similar issue had arisen. In this case, the issue raised before the bench was whether it is open to the assessee, not having appealed against the reassessment order, to set up or canvass its correctness in collateral proceedings taken for rectification thereof u/s 154. The bench minutely analysed law in this regard and applying th…

Indian Farmers Fertilizers Co-operative Ltd. v. Jt. CIT (105 ITD 33) — Cited in 12 Judgments | BharatTax