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 371,886 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

M/S. Bodal Chemicals Limited, Ahmedabad vs. The Dy.CIT., Central Circle-1(1), Ahmedabad

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

ITA 104/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Alpesh Parmar, CIT (DR)
Section 250Section 35(1)(ii)Section 80Section 801ASection 80A(5)Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. No. 104/Ahd/2024 (Assessment Year: 2016-17) M/s. Bodal Chemicals Limited, Deputy Commissioner of Vs. Plot No. 123, 124, Phase-I, GIDC, Income-tax, Vatva, Ahmedabad, Central Circle-1(1), Gujarat-382445 Ahmedabad [PAN : AAACD 5352 M] (Appellant) .. (Respondent) Appellant by : Shri S.S. Nagar, AR Respondent by: Shri Alpesh Parmar, CIT (DR) Date of Hearing 17.11.2025 Date of Pronouncement 13.02.2026 O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- This appeal has been f…

Deputy Commissioner of Income Tax, Hisar Circle, Hisar vs. Tayal Sons Private Limited, Hisar

Appeal is dismissed

ITA 5576/DEL/2025[2015]Status: DisposedITAT Delhi12 Feb 2026

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2015-16 Dcit, Vs. Tayal Sons Pvt. Ltd., Hisar 653A, Kath Mandi Road, Hisar Pan: Aabct6693E (Appellant) (Respondent) Assessee By Sh. Salil Kapoor, Adv. Sh. Shivam Yadav, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 12.02.2026 Date Of Pronouncement 12.02.2026 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal For Assessment Year 2015-16, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1078489517(1), Dated 15.07.2025 Involving Proceedings Under Section 147 R.W.S. 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case File Perused. 2. It Emerges At The Outset During The Course Of Hearing With The Able Assistance Coming From Both The Parties That There Arises The First & Foremost Issue Of Validity Of The Impugned Reopening Itself

Section 147Section 148Section 149Section 3

…rose from the fact as found by the Income-tax authorities and having a bearing on the tax liability of the assessee. While deciding in the case of NTPC (supra), the Hon’ble SC relied upon its own decision in the case of Jute Corpn. of India Ltd. v. CIT [1991] 187 ITR 688, wherein the Hon’ble Court, while dealing with the powers of the AAC 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 provision, the appellate a…

Laltanpuia Chawghlut, Aizawl vs. Income Tax Officer, Ward-1, Silchar

In the result, both appeals filed by the assessee in ITA No

ITA 191/GTY/2025[2014-15]Status: DisposedITAT Guwahati11 Feb 2026AY 2014-15

Bench: The Itat Dated 15.09.2025 As Under:

For Respondent: Santosh Kumar Karnani, Addl. CIT
Section 10(26)Section 139Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69A

…issue before any appellate authority for the first time even when the same has not been raised before the lower stages. 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. 5. We admit the additional ground and taking up for adjudication. Since, assessee did not file his ret…

Laltanpuia Chawghlut, Aizawl vs. Income Tax Officer Ward-1, Silchar

In the result, both appeals filed by the assessee in ITA No

ITA 190/GTY/2025[2013-14]Status: DisposedITAT Guwahati11 Feb 2026AY 2013-14

Bench: The Itat Dated 15.09.2025 As Under:

For Respondent: Santosh Kumar Karnani, Addl. CIT
Section 10(26)Section 139Section 142(1)Section 143(2)Section 147Section 148Section 250Section 69A

…issue before any appellate authority for the first time even when the same has not been raised before the lower stages. 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. 5. We admit the additional ground and taking up for adjudication. Since, assessee did not file his ret…

Late Chanchal Hiralal Shah (Represented by Legal Heir Rohit Hiralal Shah), Mumbai vs. ITO, Ward-20(1)(1), Mumbai

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

ITA 6349/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 148Section 148ASection 149Section 151Section 151ASection 56(2)(vii)

…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.…

The Royal Bank of Scotland N.V. - India Branch (Amalgamated With Natwest Markets Plc - India Branch), Kolkata vs. D.C.I.T., International Taxation - 2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1325/KOL/2024[2016-2017]Status: DisposedITAT Kolkata30 Jan 2026AY 2016-2017

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.1325/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2016-2017) The Royal Bank Of Scotland Vs Dcit, International Taxation- N.V.-India Branch(Amalgamated 2(1), Kolkata With Natwest Markets Plc-India Branch) 907, Regus, 9Th Floor, Ps Arcadia, 4A, Abanindra Nath Thakur Sarani, Kolkata-16 Pan No. :Aacca 6818 K

For Appellant: Shri Percy Pardiwala, Sr. CounselFor Respondent: Shri Praveen Kishore, CIT-DR
Section 147Section 148Section 148ASection 151

…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 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 facts in brief are that the AO issued original notice u.sa 148 of the Act on 30.06.2021 .The as…

Vivek Mann, Karnal vs. Income Tax Officer, Ward-1, Karnal

In the result, the appeal of the assessee is allowed

ITA 8326/DEL/2025[2015-16]Status: DisposedITAT Delhi30 Jan 2026AY 2015-16

Bench: Shri C.N. Prasad[Assessment Year: 2015-16] Vivek Mann Vs. Ito Ward-1 Village Goghirpur, Karnal Karnal Pan No.Ahcpv3556H Appellant Respondent

Section 120Section 127Section 127(1)Section 142(1)Section 143(2)

…3(2) by the authority passing the assessment order. 3. The Ld. Counsel for the assessee placing reliance on the decision of Hon’ble Supreme Court in the case of National Thermal Power Co. Ltd. Vs. CIT (229 ITR 383) and Jute Corporation of India Ltd. vs. CIT (187 ITR 688), is submitted that the additional ground raised by the assessee purely legal ground going to the root of the matter and its adjudication does not require any fresh investigation into facts apart from looking into material already on record. 4. The assessee has raised following additional ground : - “1. On the facts and circumstances of the case…

Ls Cable India P.Ltd., Rewari vs. Addl.CIT, Special Range-5, New Delhi

In the result, appeals of the Assessee in ITA No

ITA 4665/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Jan 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 144CSection 153Section 153(1)Section 153(4)

…nd goes to the root of the matter and requires no investigation or verification thus, the same be admitted for adjudication. He placed reliance on the following judgements: (i) NTPC Ltd. vs. CIT, (1998) 229 ITR 0383 (SC) (ii) Jute Corporation of India Vs. CIT 187 ITR 688 (SC) 4. On the other hand, Ld. Sr. DR for the Revenue submits that additional grounds of appeal require verification on the part of the AO therefore, the same should not be admitted at this stage. 5. After considering the submissions and perused the additional ground of appeal taken, we find that the assessee has challenged the validity of the a…

Ls Cable India Pvt. Ltd., Haryana vs. ACIT, New Delhi

In the result, appeals of the Assessee in ITA No

ITA 1961/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Jan 2026AY 2012-13

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 144CSection 153Section 153(1)Section 153(4)

…nd goes to the root of the matter and requires no investigation or verification thus, the same be admitted for adjudication. He placed reliance on the following judgements: (i) NTPC Ltd. vs. CIT, (1998) 229 ITR 0383 (SC) (ii) Jute Corporation of India Vs. CIT 187 ITR 688 (SC) 4. On the other hand, Ld. Sr. DR for the Revenue submits that additional grounds of appeal require verification on the part of the AO therefore, the same should not be admitted at this stage. 5. After considering the submissions and perused the additional ground of appeal taken, we find that the assessee has challenged the validity of the a…

Phi Seeds Pvt. Ltd., Hyderabad vs. DCIT, Circle- 19(2), New Delhi

In the result, the appeal of the Assessee is allowed

ITA 7655/DEL/2017[2012-13]Status: DisposedITAT Delhi28 Jan 2026AY 2012-13

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Ajay Vohra, Sr. Adv., Sh. Aditya VohraFor Respondent: Ms. Monika Singh, CIT(DR)
Section 10(1)Section 143Section 143(3)Section 144CSection 144C(15)Section 92C

…your honours under 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 of in the case of Jute Corporation of India vs. CIT 187 ITR 688 (SC).” 3. We have carefully considered the prayer for admission of additional ground and heard both the counsels on the issue. In our considered opinion in the light of the Hon’ble Apex Court decision in the case of NTPC Ltd. vs. CIT (1998) 229 ITR 0383 (SC), we admit the aforesaid additional ground raised by the assessee as the same is a purely…

National Oil Well Varco Pte. Ltd (Formerly Known As Varco International Pte. Ltd), Maharashtra vs. The Deputy Director of Income Tax Circle-1( International Taxation ), Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 5/DDN/2021[2017-18]Status: DisposedITAT Dehradun27 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

…nd goes to the root of the matter and requires no investigation or verification thus, the same be admitted for adjudication. He placed reliance on the following judgements: (i) NTPC Ltd. vs. CIT, (1998) 229 ITR 0383 (SC) (ii) Jute Corporation of India Vs. CIT 187 ITR 688 (SC) National Oilwell Varco Pte. Ltd. vs. DCIT 4. On the other hand, Ld. Sr. DR for the Revenue submits that additional grounds of appeal require verification on the part of the AO therefore, the same should not be admitted at this stage. 5. After considering the submissions and perused the additional ground of appeal taken, we find that the a…

National Oilwell Varco Pte. Ltd. (Formerly Known As Varco International Pte Ltd.), Mumbai vs. DCIT (International Taxation), Circle-2, Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 419/DEL/2019[2015-16]Status: DisposedITAT Dehradun27 Jan 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

…nd goes to the root of the matter and requires no investigation or verification thus, the same be admitted for adjudication. He placed reliance on the following judgements: (i) NTPC Ltd. vs. CIT, (1998) 229 ITR 0383 (SC) (ii) Jute Corporation of India Vs. CIT 187 ITR 688 (SC) National Oilwell Varco Pte. Ltd. vs. DCIT 4. On the other hand, Ld. Sr. DR for the Revenue submits that additional grounds of appeal require verification on the part of the AO therefore, the same should not be admitted at this stage. 5. After considering the submissions and perused the additional ground of appeal taken, we find that the a…

National Oilwell Varco Pte. Ltd., Mumbai vs. DCIT (International Taxation), Ci9Rcle-2, Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 5898/DEL/2017[2014-15]Status: DisposedITAT Dehradun27 Jan 2026AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

…nd goes to the root of the matter and requires no investigation or verification thus, the same be admitted for adjudication. He placed reliance on the following judgements: (i) NTPC Ltd. vs. CIT, (1998) 229 ITR 0383 (SC) (ii) Jute Corporation of India Vs. CIT 187 ITR 688 (SC) National Oilwell Varco Pte. Ltd. vs. DCIT 4. On the other hand, Ld. Sr. DR for the Revenue submits that additional grounds of appeal require verification on the part of the AO therefore, the same should not be admitted at this stage. 5. After considering the submissions and perused the additional ground of appeal taken, we find that the a…

National Oilwell Varco Pte. Ltd., Mumbai vs. DCIT (International Taxation), Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 1557/DEL/2017[2013-14]Status: DisposedITAT Dehradun27 Jan 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

…nd goes to the root of the matter and requires no investigation or verification thus, the same be admitted for adjudication. He placed reliance on the following judgements: (i) NTPC Ltd. vs. CIT, (1998) 229 ITR 0383 (SC) (ii) Jute Corporation of India Vs. CIT 187 ITR 688 (SC) National Oilwell Varco Pte. Ltd. vs. DCIT 4. On the other hand, Ld. Sr. DR for the Revenue submits that additional grounds of appeal require verification on the part of the AO therefore, the same should not be admitted at this stage. 5. After considering the submissions and perused the additional ground of appeal taken, we find that the a…

National Oilwell Varco Pte Ltd., Mumbai vs. DCIT (International Taxation), Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 1675/DEL/2016[2012-13]Status: DisposedITAT Dehradun27 Jan 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

…nd goes to the root of the matter and requires no investigation or verification thus, the same be admitted for adjudication. He placed reliance on the following judgements: (i) NTPC Ltd. vs. CIT, (1998) 229 ITR 0383 (SC) (ii) Jute Corporation of India Vs. CIT 187 ITR 688 (SC) National Oilwell Varco Pte. Ltd. vs. DCIT 4. On the other hand, Ld. Sr. DR for the Revenue submits that additional grounds of appeal require verification on the part of the AO therefore, the same should not be admitted at this stage. 5. After considering the submissions and perused the additional ground of appeal taken, we find that the a…

Mr Popatrao Dashrathrao Suryawanshi, Pune vs. Income Tax Officer, Ward-7(4), Pune

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

ITA 234/PUN/2024[2017-18]Status: DisposedITAT Pune21 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Mr. Popatrao Dashrathrao Suryawanshi Ito, Ward 7(4), Pune S.No.38, Tingre Nagar, Havaldar Mala, Vs. Vishrantwadi, Pune – 411015 Pan: Adhps2643F (Appellant) (Respondent) Assessee By : Shri Suhas Bora Department By : Shri Manish Mehta, Addl.Cit Date Of Hearing : 19-01-2026 Date Of Pronouncement : 21-01-2026 O R D E R

For Appellant: Shri Suhas BoraFor Respondent: Shri Manish Mehta, Addl.CIT
Section 142(1)Section 143(2)Section 45(2)Section 54BSection 54F

…itted that the appellate authorities have the appellate power u/s 254 of the Act to consider the revised claim or admit a new claim by the assessee: i) National Thermal Co. Ltd. Vs. CIT (1998) 229 ITR 383 (SC) ii) Jute Corporation of India Ltd. Vs. CIT (1991) 187 ITR 688 (SC) iii) CIT vs. M/s. Abhinitha Foundation Pvt Ltd. vide ITA No.811 of 2016 dated 06.06.2017 iv) Sanchit Software & Solutions (P.) Ltd. Vs. CIT (2021) 349 ITR 404 (Bom) 16. Referring to the decision of Hon’ble Supreme Court in the case of CIT vs Mahalakshmi Textile Mills Ltd reported in 66 ITR 710 (SC) and the decision of 10 Hon’ble Bombay High…

Jani Properties Private Limited, Raigad vs. DCIT, Panvel, Circle-Panvel

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

ITA 2168/PUN/2025[2015-16]Status: DisposedITAT Pune19 Jan 2026AY 2015-16

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2015-16

For Appellant: S/Shri Nikhil S Pathak and Ajinkya M VaishampayanFor Respondent: Shri Amol Khairnar, CIT-DR
Section 142(1)Section 147Section 148Section 151Section 50C

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND SHRI VINAY BHAMORE, JUDICIAL MEMBER Assessment year : 2015-16 Jani Properties Pvt. Ltd. DCIT, Panvel Circle, Panvel At Sherli House, Shastrinagar, Vs. Khopoli, Tal. Khalapur, Dist. Raigad – 410203 PAN: AAACJ7356D (Appellant) (Respondent) Assessee by : S/Shri Nikhil S Pathak and Ajinkya M Vaishampayan Department by : Shri Amol Khairnar, CIT-DR Date of hearing : 08-01-2026 Date of pronouncement : 19-01-2026 O R D E R PER R.K. PANDA, V.P: This appeal filed by the assessee is directed against the order dated 24…

Late Shri Duleechanda Through Legal Representative Shri Rajendra Chaudhary, Gautam Budh Nagar vs. ITO, Ward- 1(2), Ghaziabad

In the result, appeal of assessee in ITA No

ITA 1353/DEL/2025[2010-11]Status: DisposedITAT Delhi16 Jan 2026AY 2010-11

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Sahil Sharma, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 120Section 144Section 147Section 151Section 250

…the assessee placed reliance is also placed on decision of the Hon'ble Supreme Court in the case of National Page 3 of 6 [A.Y 2010-11] Shri Duleechanda Vs. ITO Thermal Power Co. Ltd. vs CIT: (1998] 229 ITR 383 and Jute Corporation of India vs CIT: [1991] 187 ITR 688. 6. The ld. counsel for the assessee further submitted that the case of the assessee was reopened u/s 147 and reasons recorded for reopening was under the status of an individual. However, the assessment order was passed under the status of an AOP. Therefore, the assessment order is bad in law. 7. Per contra, the ld. DR pointed out that the a…

Hero Fincorp Limited, New Delhi vs. ACIT, Circle 11(1), Delhi, C.R. Building

ITA 2542/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Satbeer Singh Godara & Shri Brajesh Kumar Singhआ.अ.सं/.I.T.A No.2542/Del/2024 निर्धारणवर्ष/Assessment Year:2017-18 Hero Fincop Ltd., 34 Community Centre, Basant Lok, Vasant Vihar, New Delhi-110057 बनाम Vs. Assistant Commissioner Of Income Tax, Circle-11(1) C. R. Building, New Delhi-110002 अपीलार्थी Appellant प्रत्यर्थी/Respondent Pan:Aaach0157J Assessee By Shri Rohit Jain, Adv., Shri Deepesh Jain, Adv. & Shri Himanshu Aggarwal Adv. Revenue By Ms. Pooja Swaroop, Cit(Dr) सुनवाईकीतारीख / Date Of Hearing: 14.01.2026 उद्घोषणाकीतारीख/Pronouncement On 16.01.2026 आदेश /Order Per Brajesh Kumar Singh, Am, The Assessee Is Engaged In The Business Of ‘Hire Purchase Leasing & Finance'. This Appeal Is Filed By The Assessee Against The Order Of National Faceless Appeal Center (Nfac)/(First Appellate Authority Hereinafter Referred As “Faa”), Delhi Dated 27.03.2024 Arising Out Of Assessment Order U/S 143(3) Of The Act Dated 29.12.2019For The Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: “Disallowance Of Provision For Collection Charges -Rs. 9,75,00,000/-

Section 143(3)Section 154Section 251(1)Section 56(2)(viib)

…the Ld. CIT(A) in para no. 11.9.8 which is as reproduced as under: “11.9.8. The powers of the first appellant authority (FAA) are co-terminus with the powers of the AO as per the decision of Hon'ble Supreme Court in Jute Corporation of India Ltd vs CIT [1991] 187 ITR 688. Further it was held in the case of Yogendra Prasad Santosh Kumar vs CIT [2014] 44 taxmann.com 299 (All HC) that "there is no provision in Income Tax Act which will permit withdrawal of an appeal, once it is filed and registered". Also it was held in "M. Loganathan vs ITO [2012] 25 taxmann.com 174 (Mad HC)" and in "Jagmondas Gokaldas vs CWT [1963…

Deputy Commissioner of Income Tax, Circle-4(2), Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2379/DEL/2023[2013-14]Status: DisposedITAT Delhi09 Jan 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

…cisions of the Supreme Court in National Thermal Power Co. Ltd. v. Commissioner of Income-tax (1998) 229 ITR 383 (SC), Gedore Tools Pvt. Ltd. v. Commissioner of Income-tax (1999) 238 ITR 268, Jute Corporation of India Ltd. v. Commissioner of Income-tax (1991) 187 ITR 688 (SC) and held that the appellate forum could have entertained and decided the sald aspect. The decision in the case of Goetze (India) Ltd. (supra) is distinguishable. In the said case the assessee had filed the return of income for the Assessment Year 1995-96 on 30-11-1995. Thereafter, on 12-1-1998, the assessee wrote a letter to the Assessing Of…