How many judgments cite Jivatlal Purtapshi v. CIT?

19 judgments on BharatTax cite Jivatlal Purtapshi v. CIT (65 ITR 261), spanning 2016 to 2025.

Which sections of the Income Tax Act does Jivatlal Purtapshi v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 139(1), Section 144B, Section 14A, Section 2(22)(e), Section 68.

Jivatlal Purtapshi v. CIT

65 ITR 261High Court1967#6131 most cited

What is Jivatlal Purtapshi v. CIT authority for?

An appeal is not maintainable if the Assessing Officer accepts the assessee's claim after due verification of documents, especially when the decision is based on an agreement or the assessee has not provided an explanation for the nature and source of credits.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

Jivatlal Purtapshi v. CIT · 65 ITR 261 · assessment procedure · appeal maintainability · Assessing Officer acceptance · verification of documents · unexplained cash credit · Section 68

Sections most often in play

Section 143(3)Section 139(1)Section 144B Section 14A Section 2(22)(e)Section 68 Section 69C

Judgments citing Jivatlal Purtapshi v. CIT

DCIT-42(1)(1), MUMBAI vs. BHARAT RATILAL SHAH, MUMBAI

In the result, the appeal is dismissed

ITA 383/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Mar 2025AY 2018-19

Bench: Justice (Retd.) C.V. Bhadang & Shri B.R. Baskaran: A.Y. : 2018-19

For Appellant: Shri Gaurav BansalFor Respondent: Shri Alok Kumar

Section 143(3)Section 69C

…appeal is not maintainable, once the Assessing Officer in the Remand Report had accepted the claim of the assessee upon due verification of the documents produced. Reliance in this regard is placed on the following decisions :- i) Jivatlal Purtapshi vs CIT, 65 ITR 261 (Bom.) ii) ITO(IT)-2(1)(1) vs Ajay Ramchandra Chande, ITA No. 583/Mum/2020, order dated 20.02.2023 iii) ITO-32(2)(1) vs M/s. Liberal Realtors LLP, ITA Nos. 450 & 449/Mum/2021, order dated 17.01.2022 iv) PCIT-1, Kolkata vs Ambition Agencies (P.) Ltd. [2022] 134 taxmann.com 5 (Calcutta) v) Smt. B. Jayalakshmi vs ACIT, Salary Circle-II, Chennai, 407…

SUBRAMANIAM SWAMINATHAN IYER, BHILAI,DURG vs. DEPUTY COMMISSIONER OF INCOME TAX-1(1), BHILAI, DURG

In the result, appeal of the assessee is partly allowed/partly allowed for statistical purposes in terms of our aforesaid observations

ITA 71/RPR/2023[2012-13]Status: DisposedITAT Raipur10 Feb 2025AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.71/Rpr/2023 "नधा"रण वष" / Assessment Year : 2012-13 Subramaniam Swaminathan Iyer 12-A/7, Nehru Nagar, Bhilai (C.G.)-490 020 Pan: Anwps2381P

For Appellant: S/shri Milind Bhusari, AdvocateFor Respondent: Shri S.L Anuragi, CIT-DR

Section 143(2)Section 143(3)Section 14ASection 2(22)(e)Section 68

…t the order based on an agreement cannot give rise to grievances and the same cannot be agitated in appeal. The Hon’ble High Court while so concluding had relied on the order of the Hon’ble High Court of Bombay in the case of Jivatlal Purtapshi Vs. CIT (1967) 65 ITR 261 (Bom). Accordingly, in the absence of any explanation of the assessee as regards the “nature” and “source” of the subject credits, the same in our view had rightly been held by the A.O as unexplained cash credit u/s. 68 of the Act. Thus, the Ground of appeal No.2 raised by the assessee is dismissed in terms of our aforesaid observations. 52. In t…

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

ITA 1515/HYD/2019[2016-17]Status: DisposedITAT Hyderabad26 May 2023AY 2016-17

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri Vijay Mehta, CAFor Respondent: Shri Jeevan Lal

Section 133ASection 139Section 139(1)Section 80ASection 80A(5)Section 80I

…dditional ground before the Tribunal contending that the nature of the activity carried by the assessee is not that of the developer. For the above proposition, the ld.counsel for the assessee relied on the following decisions:- a) Jivatlal Purtapshi v. CIT (65 ITR 261) (Bom) b) Dr. D.Y. Patil Pratisthan v. DCIT for A.Y. 2006-07 in ITA No. 1592 and 1616/PN/11 dated 14.12.2012. c) Ramanlal Kamdar v. CIT (108 ITR 73) (Madras) d) Banta Singh Kartar Singh v. CIT (125 ITR 239) (Punjab and Haryana) 17. Referring to the decision of Hon’ble Supreme Court in the case of MCorp Global Pvt.Ltd.(supra), he reiterated that t…

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. TRACKS & TOWERS INFRATECH PRIVATE LIMITED(PART IX), HYDERABAD

In the result, both the appeals filed by the revenue are partly allowed

ITA 1514/HYD/2019[2015-16]Status: DisposedITAT Hyderabad26 May 2023AY 2015-16

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri Vijay Mehta, CAFor Respondent: Shri Jeevan Lal

Section 133ASection 139Section 139(1)Section 80ASection 80A(5)Section 80I

ITO (IT)2(1)(1), MUMBAI vs. AJAY RAMCHANDRA CHANDE, MUMBAI

In the result, appeal of the Revenue is dismissed on account of low tax effect

ITA 583/MUM/2020[2011-12]Status: DisposedITAT Mumbai20 Feb 2023AY 2011-12

Bench: Shri Vikas Awasthy & Shri Gagan Goyalvk-Vk-La- 583@Eaqcbz@2020 ¼Fu-Oa- 2011&12½ The Income Tax Officer (International Taxation)-2 (1) (1) Room No.1724, 17Th Floor, Air India Building, Nariman Point ..... Vihykfkhz/Appellant Mumbai-400 021 Cuke Vs. Shri Ajay Ramchandra Chande 603, Sagra Kanya, 7 Bunglows, Andheri West Mumbai-400 061 ..... Izfroknh/Respondent Pan No. Aofpc9895N

For Appellant: Shri Soumendu Kumar Dash izfroknh }kjk@For Respondent: Shri Gaurav Bansal

…her issues raised in ground no. 1 and 2 of the appeal are liable to be dismissed on account of low tax effect. In support of his submissions, the learned Authorised Representative (AR) placed reliance on the decision in the case of Jivatlal Purtapshi vs. CIT, 65 ITR 261 (Bom.) and the decision in the case of Smt. B Jayalakshmi vs. ACIT, 407 ITR 212 (Madras). 5. On merits, the learned AR submits that the assessee had furnished the relevant documents during assessment proceedings in “tapal”. The learned AR referred to P a g e | 4 AJAY RAMCHANDRA CHANDE submissions filed before the AO at page 19 of the paper book w…

ITO (E)- 1(1), MUMBAI vs. ANUSANDHAN TRUST, MUMBAI

In the result, assessee’s appeals are partly allowed

ITA 6424/MUM/2019[2014-15]Status: DisposedITAT Mumbai27 Oct 2021AY 2014-15

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

For Appellant: Shri Ronak DoshiFor Respondent: 11.08.2021

Section 11Section 11(1)(a)

…nd accepted by the department in earlier years deserves to be followed in the absence of any change in facts. Reliance is placed on a. Radhasaomi Satsang v. CIT ( 1 93 ITR 32 1 )(SC) b. H.A. Shah & Co. v. CIT 30 ITR 618)(Bom HC) c. Jivat Lal Purtapshi v. CIT (65 ITR 261)(Bom HC) d. CIT v. Godavari Corporation Ltd. (156 ITR 835)(MP HC) 11. In view of the foregoing facts and submissions and various judicial pronouncements of the Jurisdictional High Court, the Appellant most humbly submits 12 Anusandhan Trust that it be held that the earmarked grants be allowed to be treated as income of the trust and expenditure…

ANUSANDHAN TRUST ,MUMBAI vs. ITO (E) 1 (1), MUMBAI

In the result, assessee’s appeals are partly allowed

ITA 6221/MUM/2019[2012-13]Status: DisposedITAT Mumbai27 Oct 2021AY 2012-13

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

For Appellant: Shri Ronak DoshiFor Respondent: 11.08.2021

Section 11Section 11(1)(a)

BARING PVT. EQUITY PARTNERS (INDIA) PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of assessee on these grounds is allowed for

ITA 5862/DEL/2016[2012-13]Status: DisposedITAT Delhi29 Jan 2020AY 2012-13

Bench: Shri Bhavnesh Saini & Shri N.K. Billaiyaआ.अ.सं/.I.T.A No.5862/Del/2016 िनधा"रणवष"/Assessment Year:2012-13 बनाम Baring Pvt. Equity Partners Dcit (India) Pvt. Ltd. Vs. Circle-4(1) A-16/9, Vasant Vihar, New Delhi. New Delhi.

…ition before Ld. CIT(A), the Ld. CIT(A), however, dismissed this ground of appeal of the assessee. 4. It is well settled law that no appeal lies on agreed additions. We rely upon the judgment of Bombay High Court in the case of Jivat lal Purtapshi vs. CIT 65 ITR 261, judgment of Kerala High Court in the case of Vamadevan Bhanu vs. CIT 330 ITR 559 and judgment of Punjab & Haryana High Court in the case of Banta Singh Kartar Singh vs. CIT 125 ITR 239. Ld. Counsel for assessee submitted that the same income was offered in subsequent assessment year. However, he has not pointed out anything from the record why…

DCIT CC 7(2), MUMBAI vs. ANCHOR HEALTH & BEAUTY CARE P.LTD, MUMBAI

The appeal stands dismissed

ITA 1050/MUM/2016[2009-10]Status: DisposedITAT Mumbai16 Sept 2019AY 2009-10

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri M. Subramanian-Ld.ARFor Respondent: Shri Satish Chandra Rajore-Ld. DR

Section 143(3)Section 80Section 80I

…ppellate authority since the adjudication has been done only in accordance with findings given by learner AO in the remand report. For the said conclusion, we draw strength from the decision of Hon’ble Bombay High Court rendered in Jivatlal Purtapshi V/s CIT [65 ITR 261 15/02/1967] wherein it has been held that what is voluntarily accepted cannot give rise to a grievance which could be taken further in appeal. 5.2 In the grounds of appeal, the revenue has contended that the depreciation mainly pertained to manufacturing unit and allocating the same ITA No.1050-51/Mum/2016 M/s. Anchor Health & Beauty Care Pvt. L…

NARESH KUMAR ,NOIDA vs. ITO, WARD- 2(3), NOIDA

In the result, ITA.No.6102/Del

ITA 6103/DEL/2018[2014-15]Status: DisposedITAT Delhi11 Sept 2019AY 2014-15

Bench: Shri Bhavnesh Saini

For Appellant: Shri Sandeep Jain, C.AFor Respondent: Shri S.L. Anuragi, Sr. D.R

Section 80T

…(A). 7. The Ld. D.R. relied upon orders of the authorities below. 8. It is well settled law that no appeal lies on agreed additions. I rely upon Judgment of Hon’ble Bombay High Court in the case of Jivatlal Purtapshi vs Commissioner Of Income-Tax [1967] 65 ITR 261 (Bom.), Judgment of Hon’ble Kerala High Court in the case of CIT vs. Vamadevan Bhanu 330 ITR 559 (Kerala) and Judgment of Hon’ble Punjab and Haryana High Court in the case of Banta Singh Kartar Singh 125 ITR 239 (P&H). In this case, the Ld. CIT(A) noted in the appellate order that Counsel for Assessee at the very outset, submitted that assesse…

NARESH KUMAR ,NOIDA vs. ITO, WARD- 2(3), NOIDA

In the result, ITA.No.6102/Del

ITA 6102/DEL/2018[2014-15]Status: DisposedITAT Delhi11 Sept 2019AY 2014-15

Bench: Shri Bhavnesh Saini

For Appellant: Shri Sandeep Jain, C.AFor Respondent: Shri S.L. Anuragi, Sr. D.R

Section 80T

IBG INDIA P.LTD,NEW DELHI vs. ITO, WARD-12(1), NEW DELHI

In the result appeal of Assessee partly allowed

ITA 5651/DEL/2018[2014-15]Status: DisposedITAT Delhi06 Sept 2019AY 2014-15

Bench: Shri Bhavnesh Saini

For Appellant: Shri G.S. Kohli, C.AFor Respondent: Shri S.L. Anuragi, Sr. D.R

Section 154

…n. I do not subscribe to the view of the Learned Counsel for the Assessee. It is well settled that no appeal lies on agreed additions. I rely upon the Judgment of Hon’ble Bombay High Court in the case of Jivatlal Purtapshi vs Commissioner Of Income-Tax [1967] 65 ITR 261 (Bom.), Judgment of Hon’ble Kerala High Court in the case of CIT vs. Vamadevan Bhanu 330 ITR 559 (Kerala) and Judgment of Hon’ble Punjab and Haryana High Court in the case of Banta Singh Kartar Singh 129 ITR 239 (P&H). Learned Counsel for the Assessee admitted that assessee did not move any application under section 154 of the Income Tax Act befor…

SHIBANI S. BHOJWANI,MUMBAI vs. DCIT CEN CIR 3(4), MUMBAI

ITA 1525/MUM/2018[2013-14]Status: DisposedITAT Mumbai31 Jul 2019AY 2013-14

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2013-14 & Assessment Year: 2014-15

For Appellant: Mr. Yogesh A. Thar, ARFor Respondent: Mr. Chaudhary Arun Kumar Singh, Sr. DR

Section 143(3)

…ency does apply. We find that the Hon’ble High Court while arriving at the aforesaid view had relied on the judgment of the Hon’ble High Court of Bombay in the case of H.A. Shah and Co. Vs. CIT (1956) (30 ITR 618) (Bom) and Jivat lal Purtapshi Vs. CIT (1967) (65 ITR 261) (Bom), as well as the judgment of the Hon’ble High Court of Kerala in the case of Annamalai Reddiar Vs.CIT (1964) (53 ITR 601) (Ker). We further find that the aforesaid judgment of the Hon’ble Apex Court had also been followed by the Hon’ble High Court of Punjab and Haryana in the Shibani B. Bhojwani case of CIT, Patiala Vs. Sood Harvester (2008)…

DEVENDRA KUMAR SINGH,NEW DELHI vs. ACIT, NEW DELHI

In the result, appeal of Assessee is dismissed

ITA 5159/DEL/2015[2011-12]Status: DisposedITAT Delhi02 Jan 2019AY 2011-12

Bench: Shri Bhavnesh Saini, J.M. & Shri O.P. Kant, A.M.

For Appellant: Shri B.K. Anand, FCAFor Respondent: Smt. Naina Soin Kapil, Sr. D.R

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “D” : DELHI BEFORE SHRI BHAVNESH SAINI, J.M. AND SHRI O.P. KANT, A.M. ITA.No.5159/Del./2015 Assessment Year 2011-2012 Shri Devendra Kumar The ACIT, Circle-62(1), Singh, M/s. Kartik vs. E-2 Block, S.P. Mukherjee Construction Co. 7, DDA Shopping Complex, Plot Civic Centre, J.L. Nehru No.22, Geeta Mandir Marg, Marg, New Delhi – 002. New Delhi – 110 060. PAN ABGPK7461E (Appellant) (Respondent) For Assessee : Shri B.K. Anand, FCA For Revenue : Smt. Naina Soin Kapil, Sr. D.R. Date of Hearing : 19.12.2018 Date of Pronouncement : 02.01.2019 ORDER PER BHAVNESH SAINI, J.M.…

AQUAGRI PROCESSING PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE- 3(1), NEW DELHI

In the result, appeal of the assessee is dismissed

ITA 2702/DEL/2018[2014-15]Status: DisposedITAT Delhi10 Aug 2018AY 2014-15

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Sh. Avinash Tripathi, CAFor Respondent: Sh. Vijay Kumar Jiwani, Sr. DR

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘C/SMC’, NEW DELHI) BEFORE SHRI BHAVNESH SAINI, JUDICIAL MEMBER & SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER ITA No:- 2702/Del/2018 (Assessment Year: 2014-15) Aquagri Processing Pvt. Ltd., DCIT, 284, Sultan Sadan, L-3 Westend Vs. Circle 3(1), Marg, Saidulajaib New Delhi. PAN No.-AAGCA7616M APPELLANT RESPONDENT Assessee by : Sh. Avinash Tripathi, CA Revenue by : Sh. Vijay Kumar Jiwani, Sr. DR Date of Hearing : 07.08.2018. Date of Pronouncement : 10/08/2018. ORDER PER: BHAVNESH SAINI, JM This appeal by the Assessee has been directed against the order of L…

AJAY GOEL,MEERUT vs. ITO, WARD- 1(1), MEERUT

In the result, the appeal of the assessee is partly allowed for statistical

ITA 7269/DEL/2017[2014-15]Status: DisposedITAT Delhi20 Jun 2018AY 2014-15

Bench: Sh.Bhavnesh Saini[Assessment Year: 2014-15] Vs Ajay Goel, Ito, C/O-Vinod Kumar Goel, 282, Ward-1(1), Boundary Road, Civil Lines, Meerut. Meerut, Uttar Pradesh. Pan-Aaqpg9765L (Appellant) (Respondent) Appellant By Sh. V.K.Goel, Adv. Respondent By Sh. B.R.Mishra, Sr.Dr Date Of Hearing 13.06.2018 Date Of Pronouncement 20.06.2018

…. After considering rival submissions, I do not find any merit in this ground of the appeal of the assessee. It is well settled law that no appeal lies on agreed additions. I rely upon the decision of Hon’ble Bombay High Court in the case Jivat Lal Purtapshi 65 ITR 261, decision of Hon’ble Kerala High Court in the case Vama Davan Bhanu 330 ITR 559 and decision of Hon’ble Punjab & Haryana High Court in the case of Banta Singh Kartar Singh 125 ITR 239. The assessee made a claim of deduction of the interest before the AO. However, the assessee submitted that wrong claim is made, therefore, agreed for the addition…

ACIT, MADURAI vs. A.V.NAGARAJAN, SIVAGANGAI

In the result, the appeals of the Revenue for all the years are 15

ITA 3227/CHNY/2016[2001-02]Status: DisposedITAT Chennai05 Mar 2018AY 2001-02

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

For Appellant: Shri. B. Srinivasa Rao, IRS, CITFor Respondent: Shri. S. Sridhar, Advocate

Section 153A

…that ld. Assessing Officer could not be considered an aggrieved person once he had a given remand report which fully went in favour of the assessee. Reliance was placed on the judgment of Hon’ble Mumbai High Court in the case of Jivatlal Purtapshi vs. CIT, 65 ITR 261, that of Hon’ble Mysore High Court in the case of M.M. Annaiah vs. CIT, 76 ITR 582 and that of Hon’ble Jurisdictional High Court in the case of Ramanlal Kamdar vs. CIT, 108 ITR 73. In any case as per the ld. Authorised Representative, ld. Assessing Officer had verified the evidence produced by the assessee and had reached an opinion that such ev…

M/S. HOTZ INDUSTRIES,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of Assessee dismissed

ITA 4970/DEL/2016[2013-14]Status: DisposedITAT Delhi15 Dec 2016AY 2013-14

Bench: Shri Bhavnesh Saini

For Appellant: Shri Jashpal Singh Sethi, CAFor Respondent: Shri Pradeep Singh Gautam

Section 36(1)(iii)

…for the impugned addition of Rs.3,86,362/-. It is well settled Law that no appeal lies to the appellate authorities on agreed additions. I rely upon Judgment of Hon’ble Bombay High Court in the case of Jivatlal Purtapshi vs Commissioner Of Income- Tax [1967] 65 ITR 261 (Bom.), Judgment of Hon’ble Kerala High Court in the case of CIT vs. Vamadevan Bhanu 330 ITR 559 (Kerala) and Judgment of Hon’ble Punjab and Haryana High Court in the case of Banta Singh Kartar Singh 129 ITR 239 (P&H). In this case though the assessment order has been passed on 12.02.2016 when Counsel for Assessee agreed for addition, the assessee…

ASST CIT LTU, MUMBAI vs. ADITYA BIRLA NUVO LTD, MUMBAI

The appeal of the AO is dismissed

ITA 2141/MUM/2014[2009-10]Status: DisposedITAT Mumbai07 Apr 2016AY 2009-10

For Appellant: Shri Madhur Agarwal (AR)For Respondent: Shri Sunil K. Jha (DR)

Section 115WSection 254(1)

…a revised return 2196,2141-Aditya Birla failing which,the assessee should be precluded from raising such grounds of appeal. In support of her submissions, the ld. DR relied upon the following orders: 1. 35 Taxman 153 (Bombay)/[1987] 168 ITR 375 (Bombay) 2. 65 ITR 261 (Bombay) 7. On the contrary, the ld. AR relied upon the decision of Hon’ble ITAT, G Bench, Mumbai in ITA Nos. 4910, 4911 and 5632/Mum/2011 M/s. Grasim Industries Ltd. vs. ACI T. On the careful perusal of judgments relied upon by the Id. OR as well as the ld. AR, we are of view that the para-materia contained in the judgements relied upon by ld. DR…