J.P. Janni, ITO v. Induprasad D. Bhatt

7 SCR 539Reported decision1964#25513 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 348,487 Indian tax judgments — from 2018 to 2023.

Judgments citing J.P. Janni, ITO v. Induprasad D. Bhatt

M/S D. N. Singh Through Partner Dudheshwar Nath Singh vs. Commissioner of Income Tax

C.A. No.-003738-003739 - 2023Supreme Court16 May 2023

Bench: HON'BLE MR. JUSTICE K.M. JOSEPH

Section 260A

…not need any addition or subtraction and stands on its own legs. The phrase ‘valuable article’ would simply mean an item ‘worth a great deal of money’. It cannot mean, as is said in the impugned order, to include ‘any 6 Banarsi Debi vs. ITO (1964) 7 SCR 539- See paragraph 6. 7 Augustan Textile Colours Ltd. vs. Director of Industries & Anr. (Civil Appeal No. 2830/2022) per Justice Hrishikesh Roy. See paragraphs 13 & 14 Page 16 of 19 article of value’. Therefore, in the context of Section 69A, unexplained valuable article has to be high priced item which are procured to hide income, to…

The Commissioner of Income Tax vs. M/S Sudev Industries Ltd

ITA/805/2005HC Delhi31 May 2018

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 142(1)Section 144Section 147Section 148Section 230A(1)Section 260ASection 282(2)

…to service of notice within the prescribed period. Therefore, service of notice within limitation was the foundations of jurisdiction. The same view has been taken by this Court in J.P. Janni, ITO v. Induprasad D. Bhatt [AIR 1964 SC 1742 : (1964) 7 SCR 539 : 72 ITR 595] as also in CIT v. Robert J. Sas [AIR 1964 SC 1742 : (1964) 7 SCR 539 : 48 ITR 177] . The High Court in our opinion went wrong in relying upon the ratio of Banarsi Debi v. ITO [AIR 1964 SC 1742 : (1964) 7 SCR 539 : 53 ITR 100] in disposing of the case in hand. The scheme of the 1961 Act so far as notice for reassessment is conce…

The Commissioner of Income Tax-III vs. M/S Sudev Industries Limited

ITA-805/2005HC Delhi31 May 2018
Section 142(1)Section 144Section 147Section 148Section 230A(1)Section 260ASection 282(2)

…to service of notice within the prescribed period. Therefore, service of notice within limitation was the foundations of jurisdiction. The same view has been taken by this Court in J.P. Janni, ITO v. Induprasad D. Bhatt [AIR 1964 SC 1742 : (1964) 7 SCR 539 : 72 ITR 595] as also in CIT v. Robert J. Sas [AIR 1964 SC 1742 : (1964) 7 SCR 539 : 48 ITR 177] . The High Court in our opinion went wrong in relying upon the ratio of Banarsi Debi v. ITO [AIR 1964 SC 1742 : (1964) 7 SCR 539 : 53 ITR 100] in disposing of the case in hand. The scheme of the 1961 Act so far as notice for reassessment is conce…