Karimtharuvi Tea Estate Ltd. v. State of Kerala

60 ITR 262Supreme Court of India1966#750 most cited

What is Karimtharuvi Tea Estate Ltd. v. State of Kerala authority for?

The law applicable for an assessment year is the law as it stands amended on the first day of April of that financial year. Any amendments coming into force after April 1st do not apply to the assessments for that year.

136

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2026.

Also referred to as

Karimtharuvi Tea Estate Ltd. v. State of Kerala · 60 ITR 262 SC · applicability of law · assessment year · law in force · amendment effective date · Income-tax Act 1961 · Section 143 · Section 142

Sections most often in play

Section 143(3)Section 143(2)Section 142(1)Section 115BBESection 1894Section 10(37)Section 143(1)Section 1961

Issues it is cited on

section 2(viii)section 56(viii)section 45(5)(c)section 155(16)section 23(1a)section 104section 45(5)(b)section 145b(1)section 194lakeyman insurancesection 160section 23(2)

Judgments citing Karimtharuvi Tea Estate Ltd. v. State of Kerala

HYDERABAD SCIENCE SOCIETY,HYDERABAD vs. DCIT., EXEMPTION CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1128/HYD/2024[2015-16]Status: DisposedITAT Hyderabad11 Mar 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1128/Hyd/2024 Assessment Year 2015-2016 Hyderabad Science Society, Hyderabad. The Dcit, Vs. Pin - 500 028. Exemption Circle-1(1), Telangana. Hyderabad. Pan Aaath3789F (Appellant) (Respondent) For Assessee : Sri P Murali Mohan Rao, Ca For Revenue : Dr. Narendra Kumar Naik, Cit-Dr Date Of Hearing : 12.02.2026 Date Of Pronouncement : 11.03.2026 आदेश/Order

For Appellant: Sri P Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 12ASection 143Section 143(3)

…be applied is the law in force in the assessment year unless otherwise stated or implied." This decision and various other decisions were considered by the Constitution Bench of this court in the case of Karimtharuvi Tea Estate Ltd. v. State of Kerala (1966) 60 ITR 262 (SC) and the principle were laid down in the following terms (at pages 264- 266 of 60 ITR): "Now, it is well-settled that the Income-tax, as it stands amended on the first day of April of any financial year must apply to the assessments of that year. Any amendments in the Act which come into force after the first day of April of a financial year,…

SHERNICKRAJ,CHENNAI vs. ITO, NON CORP WARD 6(1), CHENNAI, CHENNAI

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

ITA 2546/CHNY/2025[2017-18]Status: DisposedITAT Chennai07 Jan 2026AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2546/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Shri Shernickraj, The Income Tax Officer, 741, Th Road, Vs. Non-Corporate Ward 6(1), New Washermenpet, Chennai. Chennai – 600 081. Pan: Bllps 0907H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Hitesh, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 06.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 07.01.2026

For Appellant: Shri Hitesh, AdvocateFor Respondent: Ms. Gouthami Manivasagam
Section 115BSection 143(2)Section 143(3)Section 250Section 69

…pply to the assessment for that year, even if the assessment is actually made after the amendments come into force. In this context, we rely on the judgment of the Hon’ble Apex Court in the case of Karimtharuvi Tea Estate Ltd., vs. State of Kerala reported in 60 ITR 262 (SC). 8. The Hon’ble Madras High Court in the case of S.M.I.L.E Microfinance Ltd., supra had categorically held that higher rate of tax at 60% u/s.115BBE of the Act will apply only to transactions from 01.04.2017 onwards and not prior to the said cutoff date. It was further held by the Hon’ble Jurisdictional High Court that for the prior transact…

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

ITA 1271/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Nov 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

…ble for AY 2017-18 (FY 2016-17), since the amendment was made in the middle of a year, it cannot be made applicable for the entire financial year 2016-17 as held by Hon'ble Supreme Court in the case of Karimtharuvi Tea Estate Ltd Vs. State of Kerala in [1966] 60 ITR 262 (SC). 4. As such, adopting the tax rate u/s 115BBE of the Act at 60% or 30% for the AY 2017- 18 has been a debatable issue before various Judicial Forums time and again and accordingly, the said issue cannot be categorized as a “mistake apparent from the record…

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

ITA 1264/CHNY/2025[2017]Status: DisposedITAT Chennai18 Nov 2025

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

…ble for AY 2017-18 (FY 2016-17), since the amendment was made in the middle of a year, it cannot be made applicable for the entire financial year 2016-17 as held by Hon'ble Supreme Court in the case of Karimtharuvi Tea Estate Ltd Vs. State of Kerala in [1966] 60 ITR 262 (SC). 4. As such, adopting the tax rate u/s 115BBE of the Act at 60% or 30% for the AY 2017- 18 has been a debatable issue before various Judicial Forums time and again and accordingly, the said issue cannot be categorized as a “mistake apparent from the record…

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

ITA 1253/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Nov 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

…ble for AY 2017-18 (FY 2016-17), since the amendment was made in the middle of a year, it cannot be made applicable for the entire financial year 2016-17 as held by Hon'ble Supreme Court in the case of Karimtharuvi Tea Estate Ltd Vs. State of Kerala in [1966] 60 ITR 262 (SC). 4. As such, adopting the tax rate u/s 115BBE of the Act at 60% or 30% for the AY 2017- 18 has been a debatable issue before various Judicial Forums time and again and accordingly, the said issue cannot be categorized as a “mistake apparent from the record" to be rectified through an Order passed u/s 154 of the Act. 5. In this regard, relianc…

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

ITA 992/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh11 Nov 2025AY 2023-24

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

BALBIR SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, SIRSA, HARYANA

ITA 483/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

BISHAN CHAND,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5 (5), CHANDIGARH, CHANDIGARH

ITA 458/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

SAT PAL,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5(5), , CHANDIGARH

ITA 243/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

GURDEEP SINGH HUF,CHANDIGARH vs. ITO, WARD 5(5), CHANDIGARH

ITA 1153/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

BALJEET KAUR,NADI MOHALLA AMBALA CITY vs. ITO WARD 1, AMBALA, AMBALA

ITA 92/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

ITA 876/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

ITA 663/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21
For Respondent: \nShri Suraj Bhan Nain, Advocate

…T v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\n\n54\n\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

ANJU,MOHALI vs. INCOME TAX OFFICER WARD 6 (1) , MOHALI

ITA 563/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

ITA 531/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

SAMAY SINGH,YAMUNANAGAR vs. ITO-WARD (5), YAMUNANAGAR

ITA 435/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

INCOME TAX OFFICER, INCOME TAX OFFICE BARNALA vs. LAKHVIR SINGH, GRAIN MARKET, BARNALA

ITA 245/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh11 Nov 2025AY 2021-22
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

BALJIT SINGH,AMBALA CITY vs. INCOME TAX OFFICER, WARD-1, AMBALA, AMBALA

ITA 176/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

BALBIR KUMAR HUF,CHANDIGARH vs. ITO , CHANDIGARH

ITA 172/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

PREETO THROUGH L/H GURMUKH SINGH,PANCHKULA vs. ITO, WARD NO. 3, PANCHKULA

ITA 1176/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…rt in CIT v. Scindia\nSteam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be\ndetermined by the law existing for the assessment year in question. This\nprinciple was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala\n(1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment\nyear governs the assessment unless specifically provided otherwise.\n54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that\ntaxing provisions imposing a new liability are presumed to be prospective\nunless the statute clearly indicates otherwise. Likewise, in CIT v.…

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Karimtharuvi Tea Estate Ltd. v. State of Kerala (60 ITR 262) — Cited in 136 Judgments | BharatTax