How many judgments cite Jute Corporation of India Ltd. v. CIT?

1,372 judgments on BharatTax cite Jute Corporation of India Ltd. v. CIT (187 ITR 688), spanning 2008 to 2026.

Which sections of the Income Tax Act does Jute Corporation of India Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 147, Section 148, Section 153A, Section 132, Section 142(1).

Jute Corporation of India Ltd. v. CIT

187 ITR 688Supreme Court of India1991#28 most cited

What is Jute Corporation of India Ltd. v. CIT authority for?

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

1,372

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2008 to 2026.

Also referred to as

Jute Corporation of India Ltd. v. CIT · 187 ITR 688 · CIT(A) powers · Section 251 · appellate authority · new source of income · assessment confined to original items · additional legal grounds · Section 143(3) validity · Section 153C · Income Tax Act 1961

Also reported as

53 Taxmann 85

Sections most often in play

Section 143(3)Section 147 Section 148 Section 153A Section 132 Section 142(1)Section 143(2)Section 1961

Issues it is cited on

block period section 158b section 119 section 158 section 127 income escaping assessment section 149 loose papers section 132a chief commissioner section 151 section 92ca

Judgments citing Jute Corporation of India Ltd. v. CIT

ASST CIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3882/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…a bearing on the tax liability of the assessee, even though such a question was not raised before the lower authorities. 25.3. Reliance was also placed on the decision of the Hon’ble Supreme Court in the case of Jute Corporation of India Ltd. v. CIT, (1991) 187 ITR 688, wherein it was held that an appellate authority has wide powers to entertain additional grounds so long as the same are necessary to correctly assess the tax liability. In view of the these judicial precedents, it was prayed that the additional ground being purely legal in nature and going to the root of the matter may kindly be admitted and adj…

STATE BANK OF INDIA,MUMBAI vs. ASST CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3680/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

ACHAMPET SOLAR PRIVATE LTD. ,TELANGANA vs. ITO WARD-1(1), DELHI

In the result the appeal of the assessee is allowed

ITA 834/DEL/2022[2017--18]Status: DisposedITAT Delhi17 Apr 2026

Bench: Sh. Ramit Kochar & Sh. Sudhir Kumarassessment Year: 2017-18 Achampet Solar Private Ltd. Vs. Income Tax Officer, C/O Prasad & Prasad, Ward-1(1) Delhi Cas Room No. 380A, Cr Flat No. 301, Mj Towers, Building, New Delhi H.No. 8020698, Road No. 12, Banjara Hills, Hyderabad Telangana-500034 (Pan: Aanca8941N) (Appellant) (Respondent)

Section 143(3)Section 144C(13)Section 144C(5)Section 92B

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “H”, DELHI BEFORE SH. RAMIT KOCHAR, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER Assessment Year: 2017-18 Achampet Solar Private Ltd. Vs. Income Tax Officer, C/o Prasad and Prasad, Ward-1(1) Delhi CAs Room No. 380A, CR Flat No. 301, MJ Towers, Building, New Delhi H.No. 8020698, Road No. 12, Banjara Hills, Hyderabad Telangana-500034 (PAN: AANCA8941N) (APPELLANT) (RESPONDENT) Appellant by Sh. Ravi Sharma, Adv. Sh. Kshitij Bansal, CA, Ms. Supriya Mehta, CA Respondent by Shri Abhishek Deval, Sr. DR Date of hearing: 12/03/2026 Date of Pronouncement:…

GHANPUR SOLAR PRIVATE LIMITED,NEW DELHI vs. ACIT, (OSD), DELHI

In the result the appeal of the assessee is allowed

ITA 2390/DEL/2022[2017-18]Status: DisposedITAT Delhi17 Apr 2026AY 2017-18

Bench: Sh. Ramit Kochar, Accountant, Member & Sh. Sudhir Kumarassessment Year: 2017-18 Ghanpur Solar Private Vs. Acit(Osd) Delhi Limited C.R. Building, Prasad & Prasad, Ca,S I.P. Estate, New Delhi Flat No.301 M.J. Towers H- N0. 8-2-698 Road No.12 Banjara Hills Hyderabad Telangana Pan No. Aagcg1692R (Appellant) (Respondent)

Section 142(1)Section 143(3)Section 144CSection 144C(13)Section 92BSection 92C

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “H”, DELHI BEFORE SH. RAMIT KOCHAR, ACCOUNTANT, MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER Assessment Year: 2017-18 GHANPUR SOLAR PRIVATE Vs. ACIT(OSD) Delhi LIMITED C.R. BUILDING, Prasad and Prasad, CA,s I.P. ESTATE, NEW DELHI Flat no.301 M.J. Towers H- N0. 8-2-698 Road No.12 Banjara Hills Hyderabad Telangana PAN No. AAGCG1692R (APPELLANT) (RESPONDENT) Appellant by Sh. Ravi Sharma, Adv. Sh. Kshitij Bansal, CA Ms. Supriya Mehta, CA Respondent by Sh. Abhishek Deval,Sr. DR Date of hearing: 12/03/2026 Date of Pronouncement: 17/04/2026 ORDER PER SUDHIR KUMAR…

HCL TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed as indicated above

ITA 5465/DEL/2011[2007-08]Status: DisposedITAT Delhi15 Apr 2026AY 2007-08

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10ASection 143Section 144Section 144C(13)

…Honours in terms of Rule 11 of the Income- tax (Appellate Tribunal) Rules, 1963 and the decision of the Supreme Court in the case of National Thermal Power Co Ltd vs CIT: 229 ITR 383 (SC) and also the decision in the case of Jute Corporation of India vs CIT: 187 ITR 688 (SC). Reliance may also be placed on the decision of jurisdictional High Court in the case of DCM Benetton India Limited vs CIT: 173 Taxman 283 (Del), wherein, the Hon'ble High ITA Nos.- 5624/del/2010 & 5465/Del/2011 HCL Technologies Ltd. Court upheld the following finding of the decision of Hon'ble Kerala High Court in the case of CIT vs Kerala…

HCL TECHNOLOGIES LTD,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed as indicated above

ITA 5624/DEL/2010[2006-07]Status: DisposedITAT Delhi15 Apr 2026AY 2006-07

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10ASection 143Section 144Section 144C(13)

APAR INDUSTRIES LTD,MUMBAI vs. DCIT, CC6(1), MUMBAI

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

ITA 8757/MUM/2025[2015-16]Status: DisposedITAT Mumbai07 Apr 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Pawan Singh () Assessment Year: 2015-16

For Appellant: Mr. Vijay MehtaFor Respondent: Mr. Rajesh Kumar Yadav, CIT DR

Section 115JSection 143(3)Section 14ASection 32ASection 35A

…or first time. The Ld. CIT(A) relying on the decision of the Hon’ble Supreme Court in the case of National Thermal Power Company Ltd. (1998) 229 ITR 383 (SC), decision of the Hon’ble Supreme Court in the case of Jute Corporation of India Ltd. v. CIT & Another 187 ITR 688 (SC) and decision of Hon’ble Supreme Court in Goetz India Ltd. v. CIT (2006) 284 ITR 323 (SC)admitted the additional claim of the assessee for adjudication observing as under: 7.2.2.5. As per the foregoing case laws, fresh claim can be made in cases of assessment, before the appellate authority. Perhaps the basis, in the judgments of the above t…

TOMAN SINGH SAHU,RAIPUR vs. INCOME TAX OFFICER, WARD 2(1), RAIPUR, RAIPUR

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

ITA 499/RPR/2025[2016-17]Status: DisposedITAT Raipur06 Mar 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.499/Rpr/2025 "नधा"रण वष" / Assessment Year : 2016-17 Toman Singh Sahu H. No.1246, Vivekanand Ashram, Ram Kund Para, Raipur (C.G.)-492 001 Pan: Epyps2394L ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-2(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Praveen Khandelwal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 115BSection 271(1)(c)Section 69Section 69A

…legal characterization, and it is well-settled that the CIT(A) has co-terminous powers with the AO, as held by the Hon'ble Supreme Court in CIT v. Kanpur Coal Syndicate (1964) 53 ITR 225 (SC) and further upheld in Jute Corporation of India Ltd. v. CIT (1991) 187 ITR 688 (SC). These landmark decisions affirm that the CIT(A) can re-characterize the addition under the correct provision if the factual matrix so requires. These landmark decisions affirm that the CIT(A) can re-characterize the addition under the correct provision if the factual matrix so requires. Accordingly, while the AO made the addition of Rs.2,14…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, PATNA vs. PATNA IRON PVT. LTD., PATNA

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 373/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR

Section 132Section 143(2)Section 143(3)Section 153ASection 153C

…ue before any appellate authority for the first time even when the same has not been raised before the lower authorities. The case of the assessee is squarely coverd by the decisions of the Apex court in the case of i) Jute Corporation of India Ltd. Vs CIT in 187 ITR 688 , ii) National ITA Nos. 373, 332& 237/PAT/2025 Patna Iron Pvt. Ltd.& Sushil Kumar Kanodia; A.Ys. 2020-21& 2017-18 Thermal Power Co. Ltd v. CIT [1998] 229 ITR 383 and also by the decision of Hon’ble Calcutta High Court in PCIT vs. Britannia Industries Ltd. [2017] 396 ITR 677 (Cal). Therefore, we are inclined to admit the same for adjudication. 13…

SUSHIL KUMAR KANODIA,PATNA vs. ACIT, CENTRAL CIRCLE-2, PATNA

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 237/PAT/2025[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR

Section 132Section 143(2)Section 143(3)Section 153ASection 153C

CHITRAKOOT TRADELINE PRIVATE LIMITED,KOLKATA vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

ITA 193/KOL/2025[2012-13]Status: DisposedITAT Kolkata26 Feb 2026AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Chitrakoot Tradeline Private Limited National Faceless Assessment C/O Agarwal Vishwanath & Centre, Associates, 2Nd Floor, E-Ramp, Jawaharlal Vs. 133/1/1A, S.N. Banerjee Road, Nehtru Road, New Delhi-110003 Pushkal Bhawan, 3 Rd Floor, Kolkata-700103, West Bengal (Appellant) (Respondent) Pan No. Aabcc3130H Assessee By : S/Shri Deep Agarwal & Shubhankar Ghosh, Ars Revenue By : Shri Santanu Ghosh, Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 26.02.2026

For Appellant: S/Shri Deep Agarwal &For Respondent: Shri Santanu Ghosh, DR

Section 142(1)Section 143(3)Section 144BSection 68

…e before any appellate authority for the first time even when the same has not been raised before the lower authorities. The case of the assessee is squarely covered by the decisions of the Apex court in the case of i) Jute Corporation of India Ltd. Vs CIT in 187 ITR 688 , ii) National Thermal Power Co. Ltd v. CIT [1998] 229 ITR 383 and also by the decision of Hon’ble Calcutta High Court in PCIT vs. Britannia Industries Ltd. [2017] 396 ITR 677 (Cal). Therefore, we are inclined to admit the same for adjudication. 3. The facts in brief are that the assessee company is engaged in investment activities related to sh…

INCOME TAX OFFICER, KOLKATA vs. MILESTONE FINSTOCK PVT. LTD., KOLKATA

In the result, the appeal filed by the revenue is dismissed

ITA 1180/KOL/2023[2012-13]Status: DisposedITAT Kolkata24 Feb 2026AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Ito, Ward-12(1), Kolkata…..…………..………….……….……….……Appellant Vs. Milestone Finstock Pvt. Ltd..……...…………………….....……...…..…..Respondent 62A, Hazra Road, Kol-700019. [Pan: Aaccm0280B] Appearances By: Shri Mohit Mrinal, Cit-Dr, Appeared On Behalf Of The Appellant. Shri N S Saini, Ar & Priyanka Salarpuria, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 07, 2026 Date Of Pronouncing The Order : February 24, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 24.09.2020 Of The Cit(Appeals)-4, Kolkata (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2012–13. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 1075 Days & The Revenue Has Filed An Affidavit For Condonation Of The Delay. The Contents Of The Said Affidavit Are As Under: Milestone Finstock Pvt. Ltd

Section 143(2)Section 143(3)Section 250Section 73

…e taxes due are collected and Calcutta High Court in the case of Maynak Poddar HUF Vs. Wealth Tax Officer reported in 262 ITR 633 (Calcutta) and also on the decision of the Hon'ble Supreme Court in the case of Jute Corporation of India Ltd Vs. CIT reported in 187 ITR 688 (SC) where the Court held that the appellate authorities are competent enough to consider the same and take the decision for claims even raised for the first time before them. We find that the ld. CIT(A) while allowing the relief has rightly observed that in this case, there is no doubt Mcnnally Sayaji Engineering Ltd is a listed entity and this…

SHRI NARAYAN RAO HEBRI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

The appeal stands dismissed

ITA/166/2025HC Karnataka20 Feb 2026

Bench: S.G.PANDIT,K. V. ARAVIND

Section 115BSection 133ASection 143(2)Section 260Section 260A

…before the Tribunal. We fail to see why the Tribunal should be prevented from considering questions of law arising in assessment proceedings although not raised earlier. 5. In the case of Jute Corpn. of India Ltd. v. CIT [1991 Supp (2) SCC 744 : (1991) 187 ITR 688] this Court, while dealing with the powers of the Appellate Assistant Commissioner observed that an appellate authority has all the powers which the original authority may have in deciding the question before it subject to the restrictions or limitations if any prescribed by the statutory provisions. In the absence of any statutory provisio…

JIWANSAGAR NIKETAN PVT. LTD.,KOLKATA vs. ACIT, CC - 3(4),, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2726/KOL/2025[2010-2011]Status: DisposedITAT Kolkata17 Feb 2026AY 2010-2011

Bench: any appellate authority for the first time even when the same has not been raised before the lower authorities. The case of the assessee is squarely covered by the decisions of the Apex court in the case of i) Jute Corporation of India Ltd. Vs CIT in 187 ITR 688, ii) National Thermal Power Co. Ltd v. CIT [1998] 229 ITR 383 and also by the decision of Hon'ble Calcutta High Court in PCIT vs. Britannia Industries Ltd. [2017] 396 ITR 677 (Cal). Therefore, we are inclined to admit the same for a

Section 143(3)Section 147Section 148Section 151Section 250

…e before any appellate authority for the first time even when the same has not been raised before the lower authorities. The case of the assessee is squarely covered by the decisions of the Apex court in the case of i) Jute Corporation of India Ltd. Vs CIT in 187 ITR 688, ii) National Thermal Power Co. Ltd v. CIT [1998] 229 ITR 383 and also by the decision of Hon’ble Calcutta High Court in PCIT vs. Britannia Industries Ltd. [2017] 396 ITR 677 (Cal). Therefore, we are inclined to admit the same for adjudication. 4. The Ld. AR vehemently submitted before us that the reopening of assessment made by the AO u/s 147 o…

KIPPY ENGINEERING PVT. LTD.,KOLKATA vs. ACIT, CC-3(4), KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2716/KOL/2025[2010-2011]Status: DisposedITAT Kolkata17 Feb 2026AY 2010-2011

Section 143(3)Section 147Section 148Section 151Section 250

…e before any appellate authority for the first time even when the same has not been raised before the lower authorities. The case of the assessee is squarely covered by the decisions of the Apex court in the case of i) Jute Corporation of India Ltd. Vs CIT in 187 ITR 688, ii) National Thermal Power Co. Ltd v. CIT [1998] 229 ITR 383 and also by the decision of Hon’ble Calcutta High Court in PCIT vs. Britannia Industries Ltd. [2017] 396 ITR 677 (Cal). Therefore, we are inclined to admit the same for adjudication. 4. The Ld. AR vehemently submitted before us that the reopening of assessment made by the AO u/s 147 o…

GOUTAM KUMAR SARKAR,MATIGARA vs. ITO, WARD 1(3),, SILIGURI

In the result, the appeal of the assessee is allowed

ITA 1297/KOL/2025[2013-2014]Status: DisposedITAT Kolkata17 Feb 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(2)Section 144BSection 151ASection 250

…e before any appellate authority for the first time even when the same has not been raised before the lower authorities. The case of the assessee is squarely covered by the decisions of the Apex court in the case of i) Jute Corporation of India Ltd. Vs CIT in 187 ITR 688, ii) National Thermal Power Co. Ltd v. CIT [1998] 229 ITR 383 and also by the decision of Hon’ble Calcutta High Court in PCIT vs. Britannia Industries Ltd. [2017] 396 ITR 677 (Cal). Therefore, we are inclined to admit the same for adjudication. 4. The ld. AR vehemently submitted before us that the order passed by the NFAC is without jurisdiction…

GOUTAM KUMAR SARKAR,SILIGURI vs. ITO, WARD 1(3), , SILIGURI

In the result, the appeal of the assessee is allowed

ITA 1103/KOL/2025[2013-2014]Status: DisposedITAT Kolkata17 Feb 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(2)Section 144BSection 151ASection 250

…e before any appellate authority for the first time even when the same has not been raised before the lower authorities. The case of the assessee is squarely covered by the decisions of the Apex court in the case of i) Jute Corporation of India Ltd. Vs CIT in 187 ITR 688, ii) National Thermal Power Co. Ltd v. CIT [1998] 229 ITR 383 and also by the decision of Hon’ble Calcutta High Court in PCIT vs. Britannia Industries Ltd. [2017] 396 ITR 677 (Cal). Therefore, we are inclined to admit the same for adjudication. 4. The ld. AR vehemently submitted before us that the order passed by the NFAC is without jurisdiction…

JAGDEEP SINGH DHANOA,UNITED ARAB vs. INCOME TAX OFFICER IT 2(1) (1), MUMBAI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1681/MUM/2022[2017-18]Status: DisposedITAT Mumbai17 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarjagdeep Singh Dhanoa Vs. Income Tax Officer, 8202, 23 Marina, Po Pox It (2)(1), Mumbai 73392, Dubai Marina Dubai 1724, 17Th Floor, Air Ar, Foreign, India Building, United Arab Emirates- Nariman Point, 73392 Mumbai - 400021 Pan/Gir No. Aadpd4843R (Applicant) (Respondent) Assessee By None Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 03.02.2026 Date Of Pronouncement 17.02.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 26.04.2022 Passed U/S 143(3) R.W.S. 144C Of The Income Tax Act, 1961 (‘The Act’), By The Office Of The Income Tax Officer Ward 2(1) (1), Mumbai For The Assessment Year 2017-18. The Following Grounds Are Reproduced Below:

Section 143(3)Section 234ASection 234B

…he additional grounds of appeal and decide the same on merits. In respect of the above proposition, we rely on the following decisions:  National Thermal Power Co. Ltd. vs. CIT, [1998] 229 ITR 383 (Supreme Court).  Jute Corporation of India vs. CIT, [1991] 187 ITR 688 (Supreme Court).  Ahmedabad Electricity Co. Ltd. vs. CIT, [1993] 199 ITR 351 (Bombay High Court). 5 Jagdeep Singh Dhanoa 5. After carefully considering the application filed by the assessee and after hearing the Ld. DR, we are of the considered view that the additional grounds sought to be raised involve a legal issue which goes to the root of…

ASHOK KUMAR,MERRUT vs. ITO, MEEUT

In the result, the appeal of the assessee is partly allowed as indicated above

ITA 5090/DEL/2025[2011-12]Status: DisposedITAT Delhi17 Feb 2026AY 2011-12

Bench: Shri C.N. Prasadassessment Year 2011-12 Asok Kumar S/O Sher Singh Vs. Ito 24, Nagli, Azamabad Ward -1 (1) Meerut -250001 Meerut Pan No.Blapk3060J Appellant Respondent Appellant Sh. Manish Kumar, Advocate Respondent Sh. Manoj Kumar, Sr. Dr

Section 142Section 148

…151 of the Act concerning procurement of sanction has not been complied with as per mandate of section 151 before issuance of notice u/s.148 of the Act. Placing reliance on the decision of Hon’ble Supreme Court in the case of Jute Corporation of India Vs. CIT 187 ITR 688 and National Thermal Power Company Ltd. Vs. CIT 229 ITR 383 submitted that since the additional ground is purely legal ground and no investigation of new facts are required the same may be adjudication for admitted for adjudication. 6. Heard rival submissions on the additional ground as per the assessee. We find that the assessee raised the follo…

ADARSH DEVELOPERS,MUMBAI vs. ITO, WARD 22(3)(1), MUMBAI, MUMBAI

In the result, the appeal filed by the assessee stands allowed

ITA 7945/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 147Section 148Section 148ASection 151Section 151ASection 50CSection 50C(2)

…the same are purely legal in nature and do not require investigation of any fresh facts. The Hon’ble Supreme Court in the case of NTPC Ltd. v. CIT reported in (1998) 229 ITR 383 (SC) and in the case of Jute Corporation of India Ltd. v. CIT reported in (1991) 187 ITR 688 (SC) has held that an appellate authority is empowered to admit additional grounds involving question of law arising from facts already on record. Respectfully following the aforesaid decisions and considering that the additional grounds go to the root of the matter, the additional grounds raised by the assessee are admitted for adjudication. 3.…

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