ITO v. Bachu Lal Kapoor

60 ITR 74Supreme Court of India1966#1903 most cited

What is ITO v. Bachu Lal Kapoor authority for?

Income must be charged only once, preventing double taxation. If income is mistakenly assessed in the hands of individual members instead of the Association of Persons or Hindu Undivided Family, or vice versa, the Income Tax Officer must make appropriate adjustments for the tax already realized.

60

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2011 to 2025.

Also referred to as

ITO v. Bachu Lal Kapoor · 60 ITR 74 · double taxation · income once charged · assessment of AOP · assessment of HUF · members vs. association · appropriate adjustments · Section 34 (1922 Act) · Section 147 · Section 148 · tax realized

Sections most often in play

Section 143(3)Section 144BSection 147Section 148Section 26Section 50CSection 112Section 142(1)

Issues it is cited on

section 2(7)section 14(1)section 132(2)section 132(1)(a)section 153(a)(1)section 250(1)section 45(2)project completion methodsection 145(1)section 53asection 2(47)(v)section 53

Judgments citing ITO v. Bachu Lal Kapoor

Microsoft Regional Sales Corporation, New Delhi vs. DCIT (International Taxation), Gurgaon

In the result, the appeal in ITA No

ITA 7257/DEL/2017[2014-15]Status: DisposedITAT Delhi05 Jul 2022AY 2014-15

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 143(13)Section 144CSection 234BSection 271

…s of the case and in law, the Ld. AO has grossly erred in not transferring the TDS credit claimed by MRSC to MOL Corporation in view of the mandatory directions of Hon’ble DRP and the law laid down by the Supreme Court in the case of ITO vs. Bachu Lai Kapoor (60 ITR 74) (1966) (SC). Other Grounds 5. That on the facts and in the circumstances of the case and in law, the Ld. AO has erred in levying surcharge and education cess on interest on income-tax refund, which is taxable as per the at the rate of 15% as prescribed under the India - USA DTAA. 6. That on the facts and in the circumstances of the case and in law…

Microsoft Regional Sales Corporation, New Delhi vs. ACIT (International Taxation), New Delhi

In the result, the appeal in ITA No

ITA 1135/DEL/2017[2013-14]Status: DisposedITAT Delhi05 Jul 2022AY 2013-14

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 143(13)Section 144CSection 234BSection 271

…s of the case and in law, the Ld. AO has grossly erred in not transferring the TDS credit claimed by MRSC to MOL Corporation in view of the mandatory directions of Hon’ble DRP and the law laid down by the Supreme Court in the case of ITO vs. Bachu Lai Kapoor (60 ITR 74) (1966) (SC). Other Grounds 5. That on the facts and in the circumstances of the case and in law, the Ld. AO has erred in levying surcharge and education cess on interest on income-tax refund, which is taxable as per the at the rate of 15% as prescribed under the India - USA DTAA. 6. That on the facts and in the circumstances of the case and in law…

Mol Corporation, Usa, New Delhi vs. ACIT (International Taxation), New Delhi

In the result, the appeal in ITA No 1134/Del/2017of the assessee is partly allowed

ITA 1134/DEL/2017[2013-14]Status: DisposedITAT Delhi05 Jul 2022AY 2013-14

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 143(13)Section 144CSection 234B

…ircumstances of the case and in law, the Ld. AO has grossly erred in not transferring the TDS credit claimed by MRSC to MOLC in view of the mandatory directions of Hon’ble DRP and the law laid down by the Supreme Court in the case of ITO vs. Bachu Lai Kapoor (60 ITR 74) (1966) (SC). Other Grounds 5. That on the facts and in the circumstances of the case and in law, the Ld. AO has erred in levying interest amounting to INR 182,88,29,636 under section 234B of the Act. 6. That on the facts and in the circumstances of the case and in law, the Ld. AO has erred in initiating penalty proceedings under section 271(1 )…

Mol Corporation, New Delhi vs. DCIT (International Taxation), Gurgaon

Appeal are allowed and the impugned orders are set aside

ITA 1554/DEL/2016[2012-13]Status: DisposedITAT Delhi13 Apr 2022AY 2012-13

Bench: Sh. R.K.Panda & Sh. Anubhav Sharmam/S. Mol Corporation Vs. Dcit (International Taxation) C/O. Mr. Aakash Uppal Circle-Gurgaon, (Director) Gurgaon Srbc & Associates Llp 6Th Floor, Wing A & B, Worldmark A, Aero City, Opp. Holiday Inn, Mahipalpur, New Delhi-110037 Pan – Aafcm9676A (Appellant) (Respondent)

Section 143(3)Section 144C(13)Section 144C(5)

…1 ITA No. 1554/Del./2016 MOL Corporation IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘D’ : NEW DELHI) BEFORE SH. R.K.PANDA, ACCOUNTANT MEMBER AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER M/s. MOL Corporation Vs. DCIT (International Taxation) C/o. Mr. Aakash Uppal Circle-Gurgaon, (Director) Gurgaon SRBC & Associates LLP 6th Floor, Wing A & B, Worldmark a, Aero city, Opp. Holiday Inn, Mahipalpur, New Delhi-110037 PAN – AAFCM9676A (APPELLANT) (RESPONDENT) Assessee by Shri Nageshwqar Rao, Adv., Deepika Agarwal, Adv. Revenue by Ms. Anupama Anand, CIT-DR Date of hearing: 30.03.2022 Date of Pronouncement: 13.…

Microsoft Regional Sales Corporation, New Delhi vs. DCIT (International Taxation), Gurgaon

Appeal are allowed and the impugned orders are set aside

ITA 1553/DEL/2016[2012-13]Status: DisposedITAT Delhi13 Apr 2022AY 2012-13

Bench: Sh. R.K.Panda & Sh. Anubhav Sharmamicrosoft Regional Sales Pte. Vs. Dcit (International Taxation) Circle-Gurgaon, Ltd. (Formerly Known As M/S. Microsoft Gurgaon Regional Sales Corporation, Usa)

Section 143(3)Section 144

…That on facts and in law, the Learned AO grossly erred in not transferring the TDS credit claimed by MRSG to MOL Corporation in view of the mandatory directions of Hon’ble DRP and the law laid down by the Supreme Court in the case of ITO vs. Bachu Lai Kapoor (60 ITR 74) (1966) (SC). Penalty Proceedings 5 That on facts and in law, the Learned AO erred in initiating penalty 5 ITA No. 1553/Del./2016 Microsoft Regional Sales Corporation, USA proceedings under section 271(1)(c) of the Act against the Appellant. The above grounds of appeal are mutually exclusive and without prejudice to each other. The appellant cra…

Assistant Commissioner of Income Tax, Circle- 4(2)(1), Bangalore vs. M/S. N G Balu Reddy HUF, Bangalore

In the result, the appeal of the Revenue is allowed

ITA 651/BANG/2020[2009-10]Status: DisposedITAT Bangalore21 Dec 2021AY 2009-10

Bench: Shri Chandra Poojari & Shri George George Kassessment Year : 2009-10

For Appellant: Smt. Sheethal, AdvocateFor Respondent: Shri Chetan R, Addl. CIT (DR)
Section 139(1)Section 139(4)Section 147Section 2(47)(v)

…to which it did not belong, that does not prevent from properly assessing in the hands of a unit to which it belonged by process of reopening. For this purpose we place reliance on the judgment of Hon’ble Supreme Court in the case of ITO VS. Bachu Lal Kapoor 60 ITR 74 (SC), wherein it is held that ‘an HUF is a separate unit of assessment. It is a distinct assessable entity. It is a "person" within its definition in the Act. It is liable to be assessed to income-tax in respect of its income. A member of that HUF is not liable to pay any tax in respect of any Page 16 of 35 sum which he receives as a member of tha…

DCIT-CC-8(1), Mumbai vs. Sopariwala Export Private Limited, Mumbai

Accordingly, appeal filed by the revenue is dismissed

ITA 6327/MUM/2019[2015-16]Status: DisposedITAT Mumbai31 May 2021AY 2015-16

Bench: Shri S. Rifaur Rahman () & Shri Ravish Sood () Dcit, Cc-8(1) Sopariwala Exports Private Ltd., 21St Floor, Nirmal Room No. 656, Vs. 6Th Floor, Aayakar Bhavan, Building, Nariman Point, M.K. Road, Mumbai - 400021 Mumbai – 400 020

For Appellant: Shri Vijay Kumar Menon, D.RFor Respondent: Shri A.K. Ghosh, A.R
Section 133DSection 143(3)Section 154Section 35Section 35(1)Section 35(1)(ii)

…ITA No.6327/Mum/2019 A.Y. 2015-16 1 DCIT, CC-8(1) Vs. Sopariwala Exports Pvt. ltd. IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E” MUMBAI BEFORE SHRI S. RIFAUR RAHMAN (ACCOUNTANT MEMBER) AND SHRI RAVISH SOOD (JUDICIAL MEMBER) DCIT, CC-8(1) Sopariwala Exports Private Ltd., 21st Floor, Nirmal Room No. 656, Vs. 6th Floor, Aayakar Bhavan, Building, Nariman Point, M.K. Road, Mumbai - 400021 Mumbai – 400 020 PAN No. AACCS1620D Appellant Respondent Appellant by : Shri Vijay Kumar Menon, D.R Respondent by : Shri A.K. Ghosh, A.R Date of Hearing : 31.03.2021 Date of pronouncement : 31.05.2021 ORDER PER S. RIF…

DCIT-CC-8(1), Mumbai vs. Soex India Private Limited, Mumbai

Accordingly, appeal filed by the revenue is dismissed

ITA 6326/MUM/2019[2015-16]Status: DisposedITAT Mumbai31 May 2021AY 2015-16

Bench: Shri S. Rifaur Rahman () & Shri Ravish Sood () Dcit, Cc-8(1) Soex India Pvt. Ltd., Room No. 656, Vs. 21St Floor, Nirmal Building, 6Th Floor, Aayakar Bhavan, Nariman Point, M.K. Road, Mumbai - 400021 Mumbai – 400 020

For Appellant: Shri Vijay Kumar Menon, D.RFor Respondent: Shri A.K. Ghosh, A.R
Section 133DSection 142(1)Section 143(3)Section 35Section 35(1)Section 35(1)(ii)

…India Pvt. Ltd. taxation before the Settlement Commission for AY 15-16. Thus, if donation received by SHGPH has been taxed in the hands of SHGPH, same cannot be taxed in the hands of the Assessee. The Supreme Court in ITO v Bachu Lal Kapoor Kewal Ram [1966] 60 ITR 74 (SC) said that "the Act does not envisage taxation of the same income twice." This view was again reiterated by the Supreme Court in the case of Laxmipat Singhania v. CIT [1969) 72 ITR 291(SC), where it has said that it is fundamental rule of the law of taxation that unless otherwise expressly provided, income cannot be taxed twice. In CIT v Prabha…

M/S Mascot Lifestyle Pvt Ltd., Mumbai vs. ITO 10(2)(3), Mumbai

The appeal is allowed

ITA 4456/MUM/2019[2015-16]Status: DisposedITAT Mumbai01 Apr 2021AY 2015-16

Bench: Shri Vikas Awasthyआअसं. 4456/मुं/2019 ("न.व.2015-16.) M/S. Mascot Lifestyle Pvt. Ltd., 501, Garden View, Gulmohar Road, Juhu, Mumbai 400 049. Pan: Aagcm 4325D ...... अपीलाथ" /Appellant बनाम Vs. Income Tax Officer -10(2)(3), Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ..... ""तवाद"/Respondent

For Appellant: Shri Himanshu GandhiFor Respondent: Shri Sanjay J. Sethi
Section 143(3)

…23 of the Paper Book. The ld. Authorized Representative of the assessee asserted that the same income cannot be taxed twice, i.e. once in the hands of the directors and again in the hands of the आअसं. 4456/मुं/2019 ("न.व.2015-16.) 2. ITO vs. Bachulal Kapur , 60 ITR 74 (SC) 2.1. The ld.Authorized Representative of the assessee further submitted that in the immediate succeeding assessment year i.e. assessment year 2016-17, the professional fees paid to the directors for professional services rendered at Khar Gymkhana was allowed by the Assessing Officer in assessment order passed under section 143(3) of the Incom…

Pr. Commissioner of Income Tax-4 vs. Rajkumar C (HUF)

In the result, the order passed by the

ITA/503/2016HC Karnataka11 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(3)Section 147Section 148Section 150Section 153Section 260Section 260A

…T COMMISSIONER OF INCOME TAX', (2010) 326 ITR 123, 'KALYAN ALA BAROT VS. M.H.RATHOD', (2010) 328 ITR 521, 'R.B.BANSILAL ABIRCHAND FIRM VS. 10 COMMISSIONER OF INCOME TAX', (1968) 70 ITR 74, 'INCOME TAX OFFICER VS. BACHU LAL KAPOOR', (1966) 60 ITR 74, 'COMMISSIONER OF INCOME TAX VS. ABDUL KHADER AHMED', (2006) 285 ITR 57. 7. On the other hand, learned counsel for the assessee submitted that the condition precedent for initiating re-assessment proceedings under Section 147 of the Act is that the Assessing Officer should have the reason to believe that the income chargeable to tax had e…

Smt. Aarti Singal, Chandigarh vs. DCIT, CC-1, Chandigarh

ITA 715/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh04 Feb 2020AY 2012-13
For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri. G.C. Srivastava, Special Counsel
Section 132Section 153ASection 250(6)Section 68Section 69C

…nghal and his wife Smt. Aarti Singhal in the ratio o f 107:132 on income of Rs. 70,85,09,887/- will be given credit to the applicant company. For this direction, we are guided by the decision of Hon'ble Supreme' Court in the case of Bachu Lal Kapoor Kewal Ram 60 ITR 74 (SC) in order to avoid taxation of the same income." By following the order of the Settlement Commission the AO revised the assessment order on 01/08/2013. 6.2 In the present case the another survey was conducted on 27/12/2012 in M/s BPSL Group by DIT(Investigation), Chandigarh which resulted in voluntary disclosure of Rs. 70.36 Crores for the A.Y.…

Smt. Aarti Singal, Chandigarh vs. DCIT, CC-1, Chandigarh

ITA 713/CHANDI/2018[2010-11]Status: DisposedITAT Chandigarh04 Feb 2020AY 2010-11
For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri. G.C. Srivastava, Special Counsel
Section 132Section 153ASection 250(6)Section 68Section 69C

…nghal and his wife Smt. Aarti Singhal in the ratio o f 107:132 on income of Rs. 70,85,09,887/- will be given credit to the applicant company. For this direction, we are guided by the decision of Hon'ble Supreme' Court in the case of Bachu Lal Kapoor Kewal Ram 60 ITR 74 (SC) in order to avoid taxation of the same income." By following the order of the Settlement Commission the AO revised the assessment order on 01/08/2013. 6.2 In the present case the another survey was conducted on 27/12/2012 in M/s BPSL Group by DIT(Investigation), Chandigarh which resulted in voluntary disclosure of Rs. 70.36 Crores for the A.Y.…

Smt. Aarti Singal, Chandigarh vs. DCIT, CC-1, Chandigarh

ITA 712/CHANDI/2018[2008-09]Status: DisposedITAT Chandigarh04 Feb 2020AY 2008-09
For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri. G.C. Srivastava, Special Counsel
Section 132Section 153ASection 250(6)Section 68Section 69C

…nghal and his wife Smt. Aarti Singhal in the ratio o f 107:132 on income of Rs. 70,85,09,887/- will be given credit to the applicant company. For this direction, we are guided by the decision of Hon'ble Supreme' Court in the case of Bachu Lal Kapoor Kewal Ram 60 ITR 74 (SC) in order to avoid taxation of the same income." By following the order of the Settlement Commission the AO revised the assessment order on 01/08/2013. 6.2 In the present case the another survey was conducted on 27/12/2012 in M/s BPSL Group by DIT(Investigation), Chandigarh which resulted in voluntary disclosure of Rs. 70.36 Crores for the A.Y.…

Sh. Sanjay Singal, Chandigarh vs. DCIT, CC-1, Chandigarh

ITA 707/CHANDI/2018[2010-11]Status: DisposedITAT Chandigarh04 Feb 2020AY 2010-11
For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri. G.C. Srivastava, Special Counsel
Section 132Section 153ASection 250(6)Section 68Section 69C

…nghal and his wife Smt. Aarti Singhal in the ratio o f 107:132 on income of Rs. 70,85,09,887/- will be given credit to the applicant company. For this direction, we are guided by the decision of Hon'ble Supreme' Court in the case of Bachu Lal Kapoor Kewal Ram 60 ITR 74 (SC) in order to avoid taxation of the same income." By following the order of the Settlement Commission the AO revised the assessment order on 01/08/2013. 6.2 In the present case the another survey was conducted on 27/12/2012 in M/s BPSL Group by DIT(Investigation), Chandigarh which resulted in voluntary disclosure of Rs. 70.36 Crores for the A.Y.…

Sh. Sanjay Singal, Chandigarh vs. DCIT, CC-1, Chandigarh

ITA 706/CHANDI/2018[2008-09]Status: DisposedITAT Chandigarh04 Feb 2020AY 2008-09
For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri. G.C. Srivastava, Special Counsel
Section 132Section 153ASection 250(6)Section 68Section 69C

…nghal and his wife Smt. Aarti Singhal in the ratio o f 107:132 on income of Rs. 70,85,09,887/- will be given credit to the applicant company. For this direction, we are guided by the decision of Hon'ble Supreme' Court in the case of Bachu Lal Kapoor Kewal Ram 60 ITR 74 (SC) in order to avoid taxation of the same income." By following the order of the Settlement Commission the AO revised the assessment order on 01/08/2013. 6.2 In the present case the another survey was conducted on 27/12/2012 in M/s BPSL Group by DIT(Investigation), Chandigarh which resulted in voluntary disclosure of Rs. 70.36 Crores for the A.Y.…

Sh. Sanjay Singal, Chandigarh vs. DCIT, CC-1, Chandigarh

ITA 709/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh04 Feb 2020AY 2012-13
For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri. G.C. Srivastava, Special Counsel
Section 132Section 153ASection 250(6)Section 68Section 69C

…nghal and his wife Smt. Aarti Singhal in the ratio o f 107:132 on income of Rs. 70,85,09,887/- will be given credit to the applicant company. For this direction, we are guided by the decision of Hon'ble Supreme' Court in the case of Bachu Lal Kapoor Kewal Ram 60 ITR 74 (SC) in order to avoid taxation of the same income." By following the order of the Settlement Commission the AO revised the assessment order on 01/08/2013. 6.2 In the present case the another survey was conducted on 27/12/2012 in M/s BPSL Group by DIT(Investigation), Chandigarh which resulted in voluntary disclosure of Rs. 70.36 Crores for the A.Y.…

The ACIT Cen Cir-13, Mumbai vs. Shri Suresh V. Jain, Mumbai

Accordingly, ground raised by the revenue is dismissed

ITA 5091/MUM/2007[2005-2006]Status: DisposedITAT Mumbai10 Dec 2019AY 2005-2006

Bench: Shri S. Rifaur Rahman, Am & Shri Ram Lal Negi, Jm आयकरअपीलसं./ I.T.A. No. 5091/Mum/2007 (निर्धारणवर्ा / Assessment Year: 2005-06)

For Appellant: Shri L. K. S. DehiyaFor Respondent: ShriRajiv Khandelwal
Section 132(1)Section 153A

…e of indicating about the real owner of the income no protective assessment can be made and the only course left open to the Assessing Officer was to make a substantive assessment. He submitted that the Apex Court in the case of ITO v. Bachu Lal Kapoorfi 966] 60 ITR 74 has categorically held that when there was a doubt as to which person among two was liable to be assessed, parallel proceedings might be started against both; and also laid down an equitable procedure to he followed to make protective assessment. He further submitted that it is settled law that where there is doubt or ambiguity about the real entit…

ACIT, CC- 26, New Delhi vs. Krishan Kumar Modi, New Delhi

In the result, the assessee's appeal is allowed

ITA 3956/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Jul 2019AY 2012-13

Bench: Shri G.D. Agrawal & Shri Sudhanshu Srivastavaassessment Year: 2006-07 Assessment Year: 2006-07 Assessment Year: 2012-13 Krishan Kumar Modi, Acit, A-1, Maharani Bagh, Central Circle – 2, New Delhi. New Delhi. Vs (Pan: Aanpm0159M)

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri J.K. Mishra, C.I.T. DR
Section 132Section 132(4)Section 139(1)Section 69A

…necessary consequence, to exclude the amount offered for tax in the former assessment year; otherwise the same would result in double taxation, contrary to law. In the context, he relied upon decision of the Supreme Court in the case of Bachul Lal Kapoor: 60 ITR 74 (SC) and Laxmipat Singhania vs. CIT: 72 ITR 291 (SC) and the Delhi High Court in the case of ACIT Vs. Precision Metal Work: 156 ITR 693 (Del). ITA 2892 to 2894/D/2017 ITA 3952 to 3956/D/2017 4.0 On the other hand, the Ld. CIT-DR vehemently opposed the aforesaid contentions of the assessee. The Learned CIT-DR contended that there is no error…

ACIT, CC- 26, New Delhi vs. Krishan Kumar Modi, New Delhi

In the result, the assessee's appeal is allowed

ITA 3955/DEL/2017[2011-12]Status: DisposedITAT Delhi05 Jul 2019AY 2011-12

Bench: Shri G.D. Agrawal & Shri Sudhanshu Srivastavaassessment Year: 2006-07 Assessment Year: 2006-07 Assessment Year: 2012-13 Krishan Kumar Modi, Acit, A-1, Maharani Bagh, Central Circle – 2, New Delhi. New Delhi. Vs (Pan: Aanpm0159M)

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri J.K. Mishra, C.I.T. DR
Section 132Section 132(4)Section 139(1)Section 69A

…necessary consequence, to exclude the amount offered for tax in the former assessment year; otherwise the same would result in double taxation, contrary to law. In the context, he relied upon decision of the Supreme Court in the case of Bachul Lal Kapoor: 60 ITR 74 (SC) and Laxmipat Singhania vs. CIT: 72 ITR 291 (SC) and the Delhi High Court in the case of ACIT Vs. Precision Metal Work: 156 ITR 693 (Del). ITA 2892 to 2894/D/2017 ITA 3952 to 3956/D/2017 4.0 On the other hand, the Ld. CIT-DR vehemently opposed the aforesaid contentions of the assessee. The Learned CIT-DR contended that there is no error…

ACIT, CC- 26, New Delhi vs. Krishan Kumar Modi, New Delhi

In the result, the assessee's appeal is allowed

ITA 3954/DEL/2017[2010-11]Status: DisposedITAT Delhi05 Jul 2019AY 2010-11

Bench: Shri G.D. Agrawal & Shri Sudhanshu Srivastavaassessment Year: 2006-07 Assessment Year: 2006-07 Assessment Year: 2012-13 Krishan Kumar Modi, Acit, A-1, Maharani Bagh, Central Circle – 2, New Delhi. New Delhi. Vs (Pan: Aanpm0159M)

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri J.K. Mishra, C.I.T. DR
Section 132Section 132(4)Section 139(1)Section 69A

…necessary consequence, to exclude the amount offered for tax in the former assessment year; otherwise the same would result in double taxation, contrary to law. In the context, he relied upon decision of the Supreme Court in the case of Bachul Lal Kapoor: 60 ITR 74 (SC) and Laxmipat Singhania vs. CIT: 72 ITR 291 (SC) and the Delhi High Court in the case of ACIT Vs. Precision Metal Work: 156 ITR 693 (Del). ITA 2892 to 2894/D/2017 ITA 3952 to 3956/D/2017 4.0 On the other hand, the Ld. CIT-DR vehemently opposed the aforesaid contentions of the assessee. The Learned CIT-DR contended that there is no error…