Keshavji Ravji and Co. v. CIT

82 ITR 913Supreme Court of India1971#431 most cited
209

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2000 to 2025.

Also referred to as

Keshavji Ravji and Co. v. CIT · Section 269SS penalty · Section 269T penalty · Section 271D penalty · Section 271E penalty · cash transactions penalty · literal interpretation tax law · legislative intent tax · income deemed assessee's · definition of relative

Also reported as

49 Taxmann 87

Sections most often in play

Section 143(3)Section 153ASection 131(1A)Section 132ASection 269SSSection 269TSection 271DSection 271E

Issues it is cited on

section 5(8)closely held companyprincipal director general of income-taxaccumulated profitssection 292bsection 292bbsection 260section 260asection 282section 292section 119section 29

Judgments citing Keshavji Ravji and Co. v. CIT

Lovely Promoters Private Limited, Kolkata vs. ACIT, Central Circle, Ajmer

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

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a
Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

…d by taking recourse to Section 292B of the Act. 11.2 In support of his plea that the 2019 Circular is binding on the revenue, Mr Vohra has relied on the following judgments: i. UCO Bank v. CIT, [1999] 237 ITR 889 (SC); ii. Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC); and iii. DCIT v. Sunita Finlease Ltd., [2011] 330 ITR 491 11.3 Furthermore, to back his contention that recourse cannot be taken to the provisions of Section 292B of the Act, reliance is placed on the following judgments: i. PCIT v. Maruti Suzuki India Ltd. v. CIT, ITA No. 475 of 2011 (Del); and ii. Spice Entertainment Ltd. v. CIT, ITA No. 4…

DCIT, Central Circle, Ghaziabad vs. Ajay Kumar, Meerut

ITA 594/DEL/2022[2017-18]Status: HeardITAT Delhi29 Dec 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…cular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius ITAs No.404 to 406/Del/2022 Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Ajay Kumar, Meerut vs. DCIT, CC, Ghaziabad

ITA 406/DEL/2022[2018-19]Status: HeardITAT Delhi29 Dec 2023AY 2018-19

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…cular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius ITAs No.404 to 406/Del/2022 Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Ajay Kumar, Meerut vs. DCIT, CC, Ghaziabad

ITA 405/DEL/2022[2017-18]Status: HeardITAT Delhi29 Dec 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…cular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius ITAs No.404 to 406/Del/2022 Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Ajay Kumar, Meerut vs. DCIT, CC, Ghaziabad

ITA 404/DEL/2022[2016-17]Status: HeardITAT Delhi29 Dec 2023AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…cular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius ITAs No.404 to 406/Del/2022 Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Vayas Multi Trading Pvt Ltd, New Delhi vs. ACIT, Central Circle-14, New Delhi

The appeal is allowed as above

ITA 2295/DEL/2022[2012-13]Status: DisposedITAT Delhi29 Dec 2023AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2012-13 Vayas Multi Trading Pvt. Ltd., Vs Acit, Ajay Kanjhlia & Associates, Central Circle-14, Lgf, The Statesman House, New Delhi. Barakhamba Road, New Delhi – 110 001. Pan: Aabcl1268K (Appellant) (Respondent) Assessee By : Shri C.S. Anand, Advocate Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 12.12.2023 Date Of Pronouncement : .12.2023 Order Per Anubhav Sharma, Jm:

For Appellant: Shri C.S. Anand, AdvocateFor Respondent: Shri Amit Katoch, Sr. DR
Section 119Section 143(3)

…of assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Tableau Internation Unlimited Copmany the Oval Shelbourne Road Ovel Ballsbridge Dublin, Ireland D04E7K5, Ireland vs. DCIT, Circle3(1)(1) Internatioanal Taxation, Delhi

Appeal stands allowed in terms as indicated above

ITA 1875/DEL/2022[2019-20]Status: DisposedITAT Delhi29 Dec 2023AY 2019-20

Bench: Shri Kul Bharat & Dr. B.R.R. Kumarassessment Year: 2019-20

Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 234DSection 244A

…etation of sub-section (2) and they depart or deviate from such construction. It is now well-settled as a result of two decisions of this Court, one in Navnit Lal C. Jhaveri v. K.K. Sen, AAC [1965] 56 ITR 198 and the other in Ellerman Lines Ltd. v. CIT [1971] 82 ITR 913, that circulars issued by the CBDT under section 119 of the Act are binding on all officers and persons employed in the execution of the Act even if they deviate from the provisions of the Act." 6.5 The Appellant further submits that the Hon'ble Apex Court in the case of UCO Bank vs. CIT: [1999] 237 ITR 889 (SC) has held that the section 119 provi…

DCIT, Central Circle-25, New Delhi vs. Sunil Aggarwal, Faridabad

ITA 1529/DEL/2021[2018-2019]Status: DisposedITAT Delhi29 Dec 2023AY 2018-2019

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 119

…15 assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernaku…

DCIT, Central Circle-25, New Delhi vs. Sunil Aggarwal, Faridabad

ITA 1528/DEL/2021[2017-2018]Status: DisposedITAT Delhi29 Dec 2023AY 2017-2018

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 119

…15 assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernaku…

DCIT, Central Circle-25, New Delhi vs. Sunil Aggarwal, Faridabad

ITA 1527/DEL/2021[2016-2017]Status: DisposedITAT Delhi29 Dec 2023AY 2016-2017

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 119

…15 assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernaku…

DCIT, Central Circle-25, New Delhi vs. Sunil Aggarwal, Faridabad

ITA 1526/DEL/2021[2015-2016]Status: DisposedITAT Delhi29 Dec 2023AY 2015-2016

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 119

…15 assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernaku…

DCIT, Central Circle-25, New Delhi vs. Sunil Aggarwal, Faridabad

ITA 1525/DEL/2021[2014-2015]Status: DisposedITAT Delhi29 Dec 2023AY 2014-2015

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 119

…15 assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernaku…

DCIT, Central Circle-25, New Delhi vs. Sunil Aggarwal, Faridabad

ITA 1524/DEL/2021[2013-2014]Status: DisposedITAT Delhi29 Dec 2023AY 2013-2014

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 119

…15 assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernaku…

DCIT, Central Circle-25, New Delhi vs. Sunil Aggarwal, Faridabad

ITA 1523/DEL/2021[2012-2013]Status: DisposedITAT Delhi29 Dec 2023AY 2012-2013

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 119

…15 assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernaku…

Deepak Kumar, Ghaziabad (U.P) vs. Dy. CIT, Central Circle Gzbd U.P, Uttar Pradesh

ITA 1512/DEL/2021[2017-2018]Status: DisposedITAT Delhi29 Dec 2023AY 2017-2018

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Dr.Rakesh Kumar, Sh.Somil Agarwal&For Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…of assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Deepak Kumar, Ghaziabad (U.P) vs. Dy. CIT, Central Circle Gzbd U.P, Uttar Pradesh

ITA 1511/DEL/2021[2016-2017]Status: DisposedITAT Delhi29 Dec 2023AY 2016-2017

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Dr.Rakesh Kumar, Sh.Somil Agarwal&For Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…of assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Deepak Kumar, Ghaziabad (U.P) vs. Dy. CIT, Central Circle Gzbd U.P, Uttar Pradesh

ITA 1510/DEL/2021[2015-2016]Status: DisposedITAT Delhi29 Dec 2023AY 2015-2016

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Dr.Rakesh Kumar, Sh.Somil Agarwal&For Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…of assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Deepak Kumar, Ghaziabad (U.P) vs. Dy. CIT, Central Circle Gzbd U.P, Uttar Pradesh

ITA 1509/DEL/2021[2014-2015]Status: DisposedITAT Delhi29 Dec 2023AY 2014-2015

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Dr.Rakesh Kumar, Sh.Somil Agarwal&For Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…of assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Deepak Kumar, Ghaziabad (U.P) vs. Dy. CIT, Central Circle Gzbd U.P, Uttar Pradesh

ITA 1508/DEL/2021[2013-2014]Status: DisposedITAT Delhi29 Dec 2023AY 2013-2014

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Dr.Rakesh Kumar, Sh.Somil Agarwal&For Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…of assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…

Deepak Kumar, Ghaziabad (U.P) vs. Dy. CIT, Central Circle Gzbd U.P, Uttar Pradesh

ITA 1507/DEL/2021[2012-2013]Status: DisposedITAT Delhi29 Dec 2023AY 2012-2013

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Dr.Rakesh Kumar, Sh.Somil Agarwal&For Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

…of assessee that the 2019 Circular is binding on the revenue Hon’ble Delhi High Court in Brandix Mauritius Holdings Ltd. (supra) has considered judgments of Hon’ble Supreme Court in UCO Bank v. CIT, [1999] 237 ITR 889 (SC), Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC) and held as follows; “17.1 It is also well established that circulars issued by the CBDT in exercise of its powers under Section 119 of the Act are binding on the revenue. 17.2 The aforementioned principle stands enunciated in a long line of judgements, including the Supreme Court’s judgment rendered in Varghese v. Income Tax Officer, Ernakul…