How many judgments cite Karanpura Development Co. Ltd. v. CIT?

157 judgments on BharatTax cite Karanpura Development Co. Ltd. v. CIT (44 ITR 362), spanning 2009 to 2025.

Which sections of the Income Tax Act does Karanpura Development Co. Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 143(2), Section 115BBE, Section 133A, Section 143(1), Section 68.

Karanpura Development Co. Ltd. v. CIT

44 ITR 362Supreme Court of India1962#623 most cited

What is Karanpura Development Co. Ltd. v. CIT authority for?

The income derived from letting out assets, such as coal mining leases, constitutes "profits and gains of business or profession" if the primary object and activity of the assessee company are to acquire, develop, and sub-lease such assets. This classification holds even if the income arises from letting, provided the letting itself constitutes the assessee's business.

157

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2009 to 2025.

Also referred to as

Karanpura Development Co. Ltd. v. CIT · income classification · business income · letting out assets as business · profits and gains of business · coal mining leases · Section 22 · Section 24 · income from business or profession · heads of income

Sections most often in play

Section 143(3)Section 143(2)Section 115BBE Section 133A Section 143(1)Section 68 Section 69A Section 139

Issues it is cited on

section 24(a)annual value annual letting value house property income section 22 profits and gains of business or profession rule of consistency section 69b section 24 income from other sources addition u/s 68 liable to tax

Judgments citing Karanpura Development Co. Ltd. v. CIT

DCIT, CIRCLE -3(1), VISAKHAPATNAM vs. NORD ANGLIA EDUCATION INFRASTRUCTURE PRIVATE LIMITED, VISAKHAPATNAM

In the result, all the appeals filed by the revenue, viz

ITA 314/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2014-15

Bench: Shri Ravish Sood & Shri Balakrishnan S.

For Appellant: 1.Shri Karnjot Singh KhuranaFor Respondent: Shri Badicala Yadagiri, CIT-DR

Section 143(3)

…in business of renting its properties and is receiving rent as its business income, the said income should be taxed under the Head "Profits and gains of business or profession". Hon’ble Supreme Court decision in case of Karanpura Development Co. Ltd. Vs CIT (44 ITR 362) wherein Hon’ble Court held that where a company acquires properties which it leases out with view to acquiring other properties to be dealt with in same manner, company is not treating them as properties to be enjoyed in shape of rents which they yield but as a kind of circulating capital leading to profits of business, which profits may be eithe…

DCIT, CIRCLE - 3(1), VISAKHAPATNAM vs. NORD ANGLIA EDUCATION INFRASTRUCTURE PRIVATE LIMITED, VISAKHAPATNAM

In the result, all the appeals filed by the revenue, viz

ITA 206/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.

For Appellant: 1.Shri Karnjot Singh KhuranaFor Respondent: Shri Badicala Yadagiri, CIT-DR

Section 143(3)

PRANATI BUILDCON, KOTA,KOTA vs. ACIT/DCIT CEN CIR ,KOTA, KOTA

In the result, the appeal of the assessee is allowed

ITA 95/JPR/2025[2018-19]Status: DisposedITAT Jaipur23 Sept 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Hanedra Gargieya, Adv. (V.C.)For Respondent: Mrs. Anita Rinesh, JCIT, Sr.-DR a

Section 115BSection 133ASection 143(3)Section 234ASection 244ASection 69C

…income has to be assessed under the residuary head of income i.e. item F of S.14. Therefore, income added u/s 68 or 69 etc. has to be given a specific head in terms of S.14. 1.3 The Hon’ble Supreme Court in case of Karanpura Development Co Ltd vs. CIT [1962] 44 ITR 362 (SC) held that these heads are in a sense exclusive to one another and income which falls within one head cannot be brought to tax under another head. Further, the Hon’ble Supreme Court in case of Nalinikant Ambalal Mody v CIT [1966] 61 ITR 428, has held that whether an income falls under one head or another is to be decided according to the commo…

M/S. CHENNAI BUSINESS TOWER PVT. LTD.,KANCHIPURAM vs. PCIT-4, CHENNAI

In the result, the appeal of the assessee is allowed

ITA 1570/CHNY/2025[2010-11]Status: DisposedITAT Chennai12 Sept 2025AY 2010-11

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 1570/Chny/2025, धनिाारण वर्ा / Assessment Years: 2010-11 M/S. Chennai Business Tower Pcit-4, Private Limited (Formerly Known Vs Chennai. As Rmz Infinity (Chennai) Pvt. . Ltd), 110, Mount Poonamallee Road, Porur, Porur S.O. Kanchipuram – 600 116. [Pan:Aaacd-2287-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. B. Ramakrishnan, Fca. प्रत्यथी की ओर से/Respondent By : Shri. R. Raghupathy, Addl. Cit. सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोर्णा की तारीख/Date Of Pronouncement : 12.09.2025 आदेश /O R D E R Per S. R. Raghunatha, Am:

For Appellant: Shri. B. Ramakrishnan, FCAFor Respondent: Shri. R. Raghupathy, Addl. CIT

Section 143(1)Section 154Section 24Section 263

…matic and regular business operation and not as a passive owner, the rental income is taxable under the head 'Business Income'. The Hon'ble Supreme court in the cases of Chennai Properties & Investments Limited [373 ITR 673, Karanpura Development Co. Limited [44 ITR 362) and Rayala Corporation (P.) Limited [386 ITR 500] has held that the deciding factor is not the ownership of the land or leases, but the nature of the activity of the assessee and the nature of the operations in relation to the same. Further, the Hon'ble Supreme Court has emphasised that for income to be characterised as "business income," the act…

ARUN ENGINEERING UDYOG PVT. LTD.,,KOLKATA vs. PR. CIT (CENTRAL) - 2, , KOLKATA

In the result, the appeal of the assessee is allowed

ITA 786/KOL/2025[2021-2022]Status: DisposedITAT Kolkata11 Sept 2025AY 2021-2022

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2021-22 Arun Engineering Udyog Pvt. Ltd……………………………….……….……Appellant 151/A, Cotton Street, Burrabazar, Kol - 700007. [Pan: Aalca8127A] Vs. Pcit(Central)-2, Kolkata…………………………………….....……...…..…..Respondent Appearances By: Shri Miraj D Shah, Ar, Appeared On Behalf Of The Appellant. Shri Raja Sengupta, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 04, 2025 Date Of Pronouncing The Order : September 11, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 14.02.2025 Of The Principal Cit(Central), Kolkata [Hereinafter Referred To As The “Ld. Pcit”] Exercising His Revision Jurisdiction U/S 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

Section 132Section 133(6)Section 139Section 143(3)Section 263

…efer to the Constitution Bench judgment in the case of Sultan Brothers (P) Ltd., we would be well advised to discuss the law laid down authoritatively and succinctly by this Court in 'Karanpura Development Co. Ltd. v. Commissioner of Income Tax, West Bengal' [44 ITR 362 (SC)]. That was also a case where the company, which was the assessee, was 4 Arun Engineering Udyog Pvt. Ltd formed with the object, inter alia, of acquiring and disposing of the underground coal mining rights in certain coal fields and it had restricted its activities to acquiring coal mining leases over large areas, developing them as coal field…

DECORUM INFRASTRUCTURE PVT. LTD., ,KOLKATA vs. PR. CIT (CENTRAL) - 2, , KOLKATA

In the result, the appeal of the assessee is allowed

ITA 785/KOL/2025[2021-2022]Status: DisposedITAT Kolkata11 Sept 2025AY 2021-2022

Section 132Section 133(6)Section 139Section 143(3)Section 263

…r to the Constitution Bench judgment in the case of Sultan\nBrothers (P) Ltd., we would be well advised to discuss the law laid down\nauthoritatively and succinctly by this Court in 'Karanpura Development\nCo. Ltd. v. Commissioner of Income Tax, West Bengal' [44 ITR 362 (SC)].\nThat was also a case where the company, which was the assessee, was\nformed with the object, inter alia, of acquiring and disposing of the\nunderground coal mining rights in certain coal fields and it had restricted\nits activities to acquiring coal mining leases over large areas, developing\nthem as coal fields and then sub-leasing them t…

ARIHANT DEVELOPERS ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -1, KALYAN

In the result, all the above appeals of the assessee are\ndismissed

ITA 3398/MUM/2024[2017-18]Status: DisposedITAT Mumbai09 Sept 2025AY 2017-18

For Appellant: \nShri K. Gopal & Akhilesh Deshmukh, ARsFor Respondent: \nShri Aditya Rai (Sr. DR)

Section 143(3)Section 148Section 22Section 24

…ench judgment in Sultan Bros.\n(P) Ltd. [Sultan Bros. (P) Ltd. v. CIT, AIR 1964 SC 1389 : (1964) 5\nSCR 807], we would be well advised to discuss the law laid down\nauthoritatively and succinctly by this Court in Karanpura Development\nCo. Ltd. v. CIT [(1962) 44 ITR 362 (SC)] . That was also a case where\nthe company, which was the assessee, was formed with the object, inter alia,\nof acquiring and disposing of the underground coal mining rights in certain\ncoalfields and it had restricted its activities to acquiring coal mining leases\nover large areas, developing them as coalfields and then sub-leasing them to\…

ARIHANT DEVELOPERS,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -1, KALYAN

In the result, all the above appeals of the assessee are\ndismissed

ITA 3397/MUM/2024[2015-16]Status: DisposedITAT Mumbai09 Sept 2025AY 2015-16

For Appellant: \nShri K. Gopal & Akhilesh Deshmukh, ARsFor Respondent: \nShri Aditya Rai (Sr. DR)

Section 143(3)Section 148Section 22Section 24

ARIHANT DEVELOPERS,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -1, KALYAN

In the result, all the above appeals of the assessee are\ndismissed

ITA 3396/MUM/2024[2014-15]Status: DisposedITAT Mumbai09 Sept 2025AY 2014-15

For Appellant: \nShri K. Gopal & Akhilesh Deshmukh, ARsFor Respondent: \nShri Aditya Rai (Sr. DR)

Section 143(3)Section 148Section 22Section 24

ARIHANT DEVELOPERS,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -1 , KALYAN

In the result, all the above appeals of the assessee are\ndismissed

ITA 3395/MUM/2024[2012-13]Status: DisposedITAT Mumbai09 Sept 2025AY 2012-13

For Appellant: \nShri K. Gopal & Akhilesh Deshmukh, ARsFor Respondent: \nShri Aditya Rai (Sr. DR)

Section 143(3)Section 148Section 22Section 24

HIRALAL VIJAWAT , BHAWANIMANDI,BHAWANIMANDI vs. ACIT / DCIT CENTRAL CIRCLE KOTA, KOTA

ITA 614/JPR/2025[2019-20]Status: DisposedITAT Jaipur21 Aug 2025AY 2019-20

For Appellant: Sh. Mahendra Gargieya, Adv. (VC)\rFor Respondent: Sh. Gaurav Awasthi, JCIT, SR. DR\r

Section 133ASection 139Section 143(2)Section 143(3)Section 234BSection 69C

…be assessed\r\nunder the residuary head of income i.e. item F of S. 14. Therefore, income added\r\nu/s 68 or 69 etc. has to be given a specific head in terms of S. 14.\r\n1.3 The Hon'ble Supreme Court in case of Karanpura Development Co Ltd vs.\r\nCIT [1962] 44 ITR 362 (SC) held that these heads are in a sense exclusive to one\r\nanother and income which falls within one head cannot be brought to tax under\r\nanother head. Further, the Hon'ble Supreme Court in case of Nalinikant Ambalal\r\nMody v CIT [1966] 61 ITR 428, has held that whether an income falls under one\r\nhead or another is to be decided according…

KISHOR JETHALAL MORBIA,MUMBAI vs. INCOME TAX OFFICER 27 (2)(1), MUMBAI , MUMBAI

In the result, the appeal is accordingly allowed in the above terms

ITA 582/MUM/2025[2018-19]Status: DisposedITAT Mumbai14 Jul 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhanvs. Assessing Officer, Kishor Jethalal Morbia Assessment Unit, 304/310, Kailas Plaza, Income Tax Vallabh Baug Lane, Department Ghatkopar (East), Jurisdictional Mumbai-400 075 Assessing Officer, Ito 27(2)(1), Vashi Railway Station, Vashi Navi Mumbai- 400 703 Pan/Gir No. Aabpm4447J (Applicant) (Respondent) Assessee By Shri Anant N. Pai, Ld. Ar Revenue By Shri Hemanshu Joshi, Sr. Dr Date Of Hearing 07.05.2025 Date Of Pronouncement 14.07.2025 आदेश / Order Per Raj Kumar Chauhan, Jm:

Section 250Section 51

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER & SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER Vs. Assessing Officer, Kishor Jethalal Morbia Assessment Unit, 304/310, Kailas Plaza, Income Tax Vallabh Baug Lane, Department Ghatkopar (East), Jurisdictional Mumbai-400 075 Assessing Officer, ITO 27(2)(1), Vashi Railway Station, Vashi Navi Mumbai- 400 703 PAN/GIR No. AABPM4447J (Applicant) (Respondent) Assessee by Shri Anant N. Pai, Ld. AR Revenue by Shri Hemanshu Joshi, Sr. DR Date of Hearing 07.05.2025 Date of Pronouncement 14.07.2025 आदेश / ORDER PER RAJ KUMAR CHA…

INCOME TAX OFFICER, WARD-1, BARMER vs. PUSHP RAJ BOHRA, JALORE

The appeal of the revenue is allowed, in the manner discussed as above

ITA 200/JODH/2024[2017-18]Status: DisposedITAT Jodhpur01 Jul 2025AY 2017-18

Bench: Shri Rajpal Yadav, HonʼBle & Dr. Mitha Lal Meena, Hon'Bleito, Ward-1, Barmer. Vs. Pushp Raj Bohra, M-09, Shivaji Nagar, Jalore - 343001. Pan No. Aanpb4456C Assessee By Shri Goutam Chand Baid, C.A. Revenue By Smt. Runi Pal, Cit (D.R.) Date Of Hearing 29.04.2025. Date Of Pronouncement 01.03.2025. Order Per Dr. Mitha Lal Meena, A.M.: The Captioned Appeal Has Been Filed By The Revenue Against The Order Of The Id. National Faceless Appeal Centre [Nfac/Cit(A)], Delhi Dated 08.02.2024 In Respect Of Assessment Year: 2017-18 Where The Department Has Raised Following Grounds: 1. Whether The Id. Cit(A) Is Justified In Facts & Law In Directing To Treat The Income From The Sale Of Immovable Properties As Capital Gains Instead Of Business Income, By Ignoring The Fact That Assesse & His Business Concerns Are Engaged In The Business Of Property & Real Estate Development & Huge Expenses Of Rs. 8.72 Cr. Were Incurred By Assessee On Development Of Projects To Earn Profit. 2. Whether The Id. Cit(A) Has Erred In Law & Facts By Directing The Ao To Treat The Income From The Sale Of Immovable Properties As Income From Capital Gains Instead Of Business Income By Merely Following The Order Of Hon'Ble

Section 142(1)Section 143(3)Section 250Section 54ESection 54F

…e Tribunal and its conclusion, the first question of law framed will have to be answered against the Appellant-Assessee and is accordingly answered. 19. The Hon'ble Apex Court in the case of Karanpura Development Co. Ltd. vs. Commissioner of Income-tax [1962] 44 ITR 362 (SC) has observed as under: Section 28(i) of the Income-tax Act, 1961 (Corresponding to section 10(1) of the Indian Income-tax Act, 1922) - Business income - Chargeable as - Assessment years 1949-50 and 1950-51 - Whether where a company acquires properties which it sells or leases out with view to acquiring other properties to be dealt with in sam…

DYNAMIC DEALERS PVT. LTD.,KOLKATA vs. DCIT, CIR. 10(1), KOLKATA

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

ITA 740/KOL/2024[2015-16]Status: DisposedITAT Kolkata30 Jun 2025AY 2015-16

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 129Section 131Section 142(1)Section 143(2)

…land with business and dealing with purchase and sale of the land. He has relied on the decision of Hon’ble Supreme Court passed in the case of P. M. Mohammed Meerakhan vs. CIT [1979] 73 ITR 735 (SC) and Karanpura Development Company ltd. vs. Cit reported in 44 ITR 362 (SC). 6. Upon hearing the submissions of the counsel of the respective parties, we have gone through the order passed by the lower authorities and the paper books filed by the assessee. The main ground of the assessee is with regard to addition of Rs. 1,59,22,402/- on account of business income from sale of land. Looking at the audited balance sh…

LIFE CARE HOSPITAL,SIROHI vs. ACIT/DCIT, CIRCLE-1,, JODHPUR

In the result, appeal of the assessee is allowed

ITA 938/JODH/2024[2017-18]Status: DisposedITAT Jodhpur24 Jun 2025AY 2017-18

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

Section 115BSection 133ASection 142(1)Section 143(1)Section 143(2)Section 234ASection 250Section 69A

…in a sense exclusive of one another, and income which falls within one head cannot be assigned to, or taxed under, another head. Our view is also supported by the judgement of Honourable Supreme Court in the case of Karanpura Development Co. Pvt. Ltd. [1962] 44 ITR 362 (SC), relevant para of the case law for your referfence is extracted herein below : “ The Income-tax Act puts the tax on income, profits and gains irrespective of the source from which they are derived. Section 3 of the Act provides, inter alia, that income-tax shall be charged on the total income of every company. Under section 4(1), total incom…

AKSHAT LOYALKA,JAIPUR vs. RJN-C-(101)(1), JAIPUR

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

ITA 1019/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 May 2025AY 2016-17

For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR

Section 144BSection 147Section 234ASection 250Section 5Section 69A

…dded u/s 68,69, 69A of the Act etc. hence\nthere is no question of invoking of S.115BBE of the act.\n1.2 Supporting Case Law:\n1.2.1A reference has been made to the decision of Hon'ble Supreme Court in the case\nof Karanpura Development Co. Ltd vs. CIT [1962] 44 ITR 362 (SC)whereby it was\nheld that:\n“these heads are in a sense exclusive to one another and income whichfalls within one\nhead cannot be brought to tax under another head”.\n1.2.2Further, to rely more upon in the case of Nalinikant Ambalal Mody v CIT [1966]\n61 ITR 428 the Hon'ble Supreme Court held that:\n“Whether an income falls under one head or a…

HYDERABAD INFRATECH PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

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

ITA 1856/HYD/2019[2015-16]Status: DisposedITAT Hyderabad23 May 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri T. Suryanarayana &For Respondent: Ms. M. Narmada, CIT-DR

Section 143(3)Section 92C

…efer to the Constitution Bench judgment in the case of Sultan Brothers (P) Ltd., we would be well advised to discuss the law laid down authoritatively and succinctly by this Court in 'Karanpura Development Co. Ltd. v. Commissioner of Income Tax, West Bengal' [44 ITR 362 (SC)]. That was also a case where the company, which was the assessee, was formed with the object, inter alia, of acquiring and disposing of the underground coal mining rights in certain coal fields and it had restricted its activities to acquiring coal mining leases over large areas, developing them as coal fields and then sub-leasing them to col…

KATH BROTHERS,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 77/JPR/2025[2019-20]Status: DisposedITAT Jaipur28 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT

Section 115BSection 133ASection 143(2)Section 143(3)Section 145(3)Section 234ASection 69

…e case laws relied upon by the AO is not applicable and the additional income declared by the assessee is not liable to tax as per the provisions of section 115BBE of the Act. “ The Hon’ble Supreme Court in case of Karanpura Development Co Ltd vs. CIT [1962] 44 ITR 362 (SC) held that these heads are in a sense exclusive to one another and income which falls within one head cannot be brought to tax under another head. Further, the Hon’ble Supreme Court in case of Nalinikant Ambalal Mody v CIT [1966] 61 ITR 428, has held that whether an income falls under one head or another is to be decided according to the commo…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), , GUNTUR vs. BBM ESTATES PRIVATE LIMITED, GUNTUR

In the result, Revenue appeal is allowed and the C

ITA 185/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam01 Apr 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri S. Balakrishnan.आ.अपी.सं /Ita No.185/Viz/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Acit Vs. Bbm Estates (P) Ltd Circle 1(1) Guntur Guntur Pan: Aaace2607G (Appellant) (Respondent) C.O No.12/Viz/2024 (Arising Out Of Ita No.1895/Viz/2024) Bbm Estates (P) Ltd Vs. Acit Guntur Circle 1(1) Pan: Aaace2607G Guntur (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri G.V.N. Hari, Ca राज" व "ारा/Revenue By:: Shri Satyasai Rath, Dr सुनवाई की तारीख/Date Of Hearing: 07/01/2025 घोषणा की तारीख/Pronouncement: 01/04/2025 आदेश/Order

For Appellant: Shri G.V.N. Hari, CAFor Respondent: : Shri Satyasai Rath, DR

…erties. 8. Before we refer to the Constitution Bench judgment in the case of Sultan Brothers (P.) Ltd. (supra), we would be well advised to discuss the law laid down authoritatively and succinctly by this Court in 'Karanpura Development Co. Ltd. v. CIT [1962] 44 ITR 362 (SC). That was also a case where the company, which was the assessee, was formed with the object, inter alia, of acquiring and disposing of the Page 11 of 17 ITA No 185 of 2024 and CO 12 of 2024 BBM Estates P Ltd underground coal mining rights in certain coal fields and it had restricted its activities to acquiring coal mining leases over large…

PARSHAVNATH ASSOCIATES, KOTA,KOTA vs. ACIT/DCIT,CENTRAL CIRCLE, KOTA, KOTA

In the result, both the appeal filed by separate assessee are allowed in terms of the above observations

ITA 1358/JPR/2024[2018-19]Status: DisposedITAT Jaipur19 Mar 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mahendra Gargieya, Adv.&For Respondent: Smt. Runi Pal, CIT a

Section 133ASection 139Section 143(3)Section 234ASection 244ASection 69C

…ncome has to be assessed under the residuary head of income i.e. item F of S. 14. Therefore, income added u/s 68 or 69 etc. has to be given a specific head in terms of S. 14. 1.3 The Hon’ble Supreme Court in case of Karanpura Development Co Ltd vs. CIT [1962] 44 ITR 362 (SC) held that these heads are in a sense exclusive to one another and income whichfalls within one head cannot be brought to tax under another head. Further, the Hon’ble SupremeCourt in case of Nalinikant Ambalal Mody v CIT [1966] 61 ITR 428, has held that whether anincome falls under one head or another is to be decided according to the common n…

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