Jute Corporation of India Ltd. v. CIT

187 ITR 688Supreme Court of India1991#29 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 371,900 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 147Section 148Section 153ASection 132Section 142(1)Section 143(2)Section 1961

Issues it is cited on

block periodsection 158bsection 119section 158section 127income escaping assessmentsection 149loose paperssection 132achief commissionersection 151section 92ca

Judgments citing Jute Corporation of India Ltd. v. CIT

Shri Vishal Mehta, Rajkot vs. The ITO Ward-2 (1) (2), Rajkot

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 77/RJT/2024[2015-16]Status: DisposedITAT Rajkot07 Jan 2025AY 2015-16

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &
Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

…d apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the order of Honourable Supreme Court the case of Jute Corporation of India Limited vs CIT (1991) 187 ITR 688 (SC). In this regard it is further clarified that there is no new source of income in category ‘A’ case, as defined by Honourable Supreme Court in CIT Vs Shapoorji Pallonji Mistri (1962) 44 ITR 891 (SC). To summarize, Ld. ITAT as plenary powers which Ld. CIT(A) as well as Ld. assessing officer possess and the prayer of Revenue is limited to susta…

Shri Vishal Mehta, Rajkot vs. The ITO Ward-2(1) (2) Rajkot, Rajkot

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 76/RJT/2024[2014-15]Status: DisposedITAT Rajkot07 Jan 2025AY 2014-15

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &
Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

…d apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the order of Honourable Supreme Court the case of Jute Corporation of India Limited vs CIT (1991) 187 ITR 688 (SC). In this regard it is further clarified that there is no new source of income in category ‘A’ case, as defined by Honourable Supreme Court in CIT Vs Shapoorji Pallonji Mistri (1962) 44 ITR 891 (SC). To summarize, Ld. ITAT as plenary powers which Ld. CIT(A) as well as Ld. assessing officer possess and the prayer of Revenue is limited to susta…

Shri Vishal Mehta, Rajkot vs. The ITO Ward-2(1) (2), Rajkot

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 75/RJT/2024[2013-14]Status: DisposedITAT Rajkot07 Jan 2025AY 2013-14

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &
Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

…d apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the order of Honourable Supreme Court the case of Jute Corporation of India Limited vs CIT (1991) 187 ITR 688 (SC). In this regard it is further clarified that there is no new source of income in category ‘A’ case, as defined by Honourable Supreme Court in CIT Vs Shapoorji Pallonji Mistri (1962) 44 ITR 891 (SC). To summarize, Ld. ITAT as plenary powers which Ld. CIT(A) as well as Ld. assessing officer possess and the prayer of Revenue is limited to susta…

Shri Vishal Mehta, Rajkot vs. The ITO Ward-2 (1) (2), Rajkot

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 74/RJT/2024[2012-13]Status: DisposedITAT Rajkot07 Jan 2025AY 2012-13

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &
Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

…d apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the order of Honourable Supreme Court the case of Jute Corporation of India Limited vs CIT (1991) 187 ITR 688 (SC). In this regard it is further clarified that there is no new source of income in category ‘A’ case, as defined by Honourable Supreme Court in CIT Vs Shapoorji Pallonji Mistri (1962) 44 ITR 891 (SC). To summarize, Ld. ITAT as plenary powers which Ld. CIT(A) as well as Ld. assessing officer possess and the prayer of Revenue is limited to susta…

DCIT CC 1(1), Mumbai vs. Edelweiss Tokio Life Insurance Company Ltd, Kurla, Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 3802/MUM/2024[2018-19]Status: DisposedITAT Mumbai23 Dec 2024AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Ajay Singh and Shri A. Pawar ARsFor Respondent: Shri Hemanshu Joshi (Sr. DR)
Section 143(3)

…he option to assess one or other of the entities in the alternative, the AAC can direct him to do what the ITO should have done in the circumstances of a case. In cases of KapoorchandSrimal vs CIT(1981) 131 ITR 451,460(SC)/Jute Corporation of India Ltd vs CIT 187 ITR 688(SC) likewise held that the 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 absence of any such restriction, the appellate authority is vested with all the powers of the assessing authority.…

Asia Investments P.Ltd, Mumbai vs. Addl CIT RG 2(1), Mumbai

In the result, the appeal filed by the assessee is partly allowed

ITA 916/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Dec 2024AY 2011-12

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: ShriH.P. Mahajani, ARFor Respondent: Dr. K.R. Subhash, CIT-DR
Section 14A

…ctfully following the decisions of Hon’ble Supreme Court in case of National Thermal Power Company Ltd. Vs. CIT reported in (1998) 223 ITR 383 and sy ITA No.916/MUM/2016 Asia Investments Pvt. Ltd.; A. Y.2011-12 Jute Corporation of India Vs. CIT reported in 187 ITR 688, we admit the additional grounds raised by the assessee. Accordingly the application filed by the assessee seeming admission of additional grounds stands allowed. Accordingly the application for admission if additional grounds stands allowed. Brief facts of the case are as under: 3. The assessee is stated to be investing company carrying on b…

Amit Khatri, Sonipat vs. ITO, Ward 1, Sonipat

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

ITA 2430/DEL/2023[2012-13]Status: DisposedITAT Delhi18 Dec 2024AY 2012-13

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.2430/Del/2023 िनधा"रणवष"/Assessment Year: 2012-13 बनाम Amit Khatri Income Tax Officer Ward No.30, Garhi Bhraman, Vs. Ward-1, Sonipat, Haryana. Sonipat, Haryana. Pan No. Bdspk3438G अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 151

…facts, the same may be admitted and disposed off. Reliance was placed on the decision of I.T.A. No. 2430/Del/2023 the Hon’ble Supreme Court in the case of National Thermal Power Company Ltd. Vs. CIT (229 ITR 383) and Jute Corporation of India Ltd. Vs. CIT (187 ITR 688). 3. Ld. Counsel for the assessee referring to page 38 of the Paper Book which is the Form for recording the reasons for initiating proceedings u/s 148 and for obtaining approval of the Pr. CIT for reopening of assessment, submits that in column 7 of the said Form the AO has stated that the provisions applicable for reopening of assessment is…

Sunny Trexim Private Ltd., Kolkata vs. DCIT, Circle - 5(1), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 644/KOL/2024[2013-14]Status: DisposedITAT Kolkata09 Dec 2024AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 147Section 148Section 148(2)Section 92C

…and no further verification of facts are required to be done whatsoever from any quarter. Accordingly, we are inclined to admit the same for adjudication by relying on the decision of Hon’ble Apex Court in the case of Jute Corporation of India Ltd. Vs CIT in 187 ITR 688 and National Thermal Power Co. Ltd v. CIT [1998] 229 ITR 383 wherein the Hon’ble Apex Court has held that the assessee is free to raise the legal issue at any appellate stage. We note that it is further held by the Hon’ble Bombay High Court that where the assesse raised a legal issue for the first time before the appellate authority ,then the aut…

Sunny Trexim Privat Ltd., Kolkata vs. DCIT, Circle - 5(1), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 643/KOL/2024[2010-11]Status: DisposedITAT Kolkata09 Dec 2024AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 147Section 148Section 148(2)Section 92C

…and no further verification of facts are required to be done whatsoever from any quarter. Accordingly, we are inclined to admit the same for adjudication by relying on the decision of Hon’ble Apex Court in the case of Jute Corporation of India Ltd. Vs CIT in 187 ITR 688 and National Thermal Power Co. Ltd v. CIT [1998] 229 ITR 383 wherein the Hon’ble Apex Court has held that the assessee is free to raise the legal issue at any appellate stage. We note that it is further held by the Hon’ble Bombay High Court that where the assesse raised a legal issue for the first time before the appellate authority ,then the aut…

Amol Pramod Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1098/PUN/2024[2019-20]Status: DisposedITAT Pune26 Nov 2024AY 2019-20

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Amol Pramod Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1097/PUN/2024[2018-19]Status: DisposedITAT Pune26 Nov 2024AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Amol Pramod Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1096/PUN/2024[2017-18]Status: DisposedITAT Pune26 Nov 2024AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Amol Pramod Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1095/PUN/2024[2016-17]Status: DisposedITAT Pune26 Nov 2024AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Amol Pramod Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1094/PUN/2024[2015-16]Status: DisposedITAT Pune26 Nov 2024AY 2015-16

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Amol Pramod Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1093/PUN/2024[2014-15]Status: DisposedITAT Pune26 Nov 2024AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Amol Pramod Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1092/PUN/2024[2013-14]Status: DisposedITAT Pune26 Nov 2024AY 2013-14

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Amol Pramod Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1091/PUN/2024[2012-13]Status: DisposedITAT Pune26 Nov 2024AY 2012-13

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Amol Pramod Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1090/PUN/2024[2011-12]Status: DisposedITAT Pune26 Nov 2024AY 2011-12

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Priyanvada Amol Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1065/PUN/2024[2015-16]Status: DisposedITAT Pune26 Nov 2024AY 2015-16

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…

Priyanvada Amol Mahajan, Jalgaon vs. DCIT, Central Circle-1, Nashik

In the result, all the appeals filed by the respective assessees are allowed

ITA 1064/PUN/2024[2014-15]Status: DisposedITAT Pune26 Nov 2024AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Nikhil PathakFor Respondent: Shri Ramnath P Murkunde
Section 132Section 139Section 143(2)Section 153A

…required to be investigated. Referring to the decision of the Hon'ble Supreme Court in the case of the National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) and in the case of Jute Corporation Of India Ltd vs Commissioner Of Income Tax And Anr (1991) 187 ITR 688, he submitted that the additional grounds raised by the assessee should be admitted. 10. The Ld. DR on the other hand strongly opposed the admission of the additional grounds. He submitted that these grounds are never raised before the ITA Nos.1063 to 1065/PUN/2024 Ld. CIT(A) and the assessee is raising this issue for the first time before the…