Laxmipat Singhania v. CIT

72 ITR 291Supreme Court of India1969#1420 most cited

What is Laxmipat Singhania v. CIT authority for?

Income cannot be taxed twice unless expressly provided by law. Income accrued in a particular year must be included in that year's total income and cannot be ignored to be taxed in a subsequent year based on receipt.

81

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2025.

Also referred to as

Laxmipat Singhania v. CIT · 72 ITR 291 · double taxation · income taxed twice · year of taxability · income accrual · Income-tax Officer power · Section 68 · Section 69A · fundamental taxation rule

Sections most often in play

Section 143(3)Section 1961Section 115BBESection 142(1)Section 68Section 132Section 145(3)Section 250

Issues it is cited on

section 23aretention moneysection 145(1)section 211section 115baasection 145(2)project completion methodsection 28(iv)section 43csection 35dpercentage completion methodicds

Judgments citing Laxmipat Singhania v. CIT

KDJP STEELS PRIVATE LIMITED,DELHI vs. NATIONAL FACELESS APPEAL CENTRE, DELHI

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

ITA 5900/DEL/2024[2017-18]Status: DisposedITAT Delhi23 Dec 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2017-18 Kdjp Steels Private Limited, Vs. National Faceless Appeal Centre, Plot No.50, Flat No.A-201, Delhi. Parshav Vihar, Patpar Ganj, Delhi – 110 092. Pan: Aacck6905F (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Sr. Advocate; Shri R.P. Mall, Advocate; Shri Shailesh Gupta, Ca & Shri Madhur Agarwal, Advocate Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 27.10.2025 Date Of Pronouncement : 23.12.2025

For Appellant: Shri Salil Agarwal, Sr. AdvocateFor Respondent: Shri Om Parkash, Sr. DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

…result of such cash sales which have been deposited in the bank cannot be taxed as income under section 68/69A of the Act as that would tantamount to double taxation. Double taxation is not permissible in law. Reliance is placed on the following judgments: i) 72 ITR 291 (SC) CIT v. LaxmiPat Singhania vs. CIT ii) 118 ITR 50 (SC) State of Uttar Pradesh vs. Raja Buland Sugar Co. Ltd. iii) CIT vs. Vishal Exports Overseas Limited (Guj) in Tax Appeal No. 2471 of 2019 iv) CIT vs. Kailash Jewellery House (Del) in ITA 613/2010 6 5.4 Section 68/69A of the Act does not apply to a sum already disclosed as income as held by…

DCIT, CIRCLE-7(1), DELHI vs. DLF LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

ITA 715/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…e. In view thereof, a reduction/adjustment should be allowed to the Appellant in AY 2019-20 towards the IND-AS 115 transition adjustment. Such view finds support from the judgement of the Hon’ble Supreme Court in the case of Laxmipat Singhania vs. CIT (1969) (72 ITR 291) (refer Page 607-611 of Paper Book Vol- 2), wherein, the Hon’ble Court observed as follows – “It is a fundamental rule of the law of taxation that, unless otherwise expressly provided, income cannot be taxed twice. Again, it is not open to the ITO, if income has accrued to the assessee, and is liable to be included in the total income of a particu…

DCIT, CIRCLE-7(1), DELHI vs. DLF LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

ITA 714/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…e. In view thereof, a reduction/adjustment should be allowed to the Appellant in AY 2019-20 towards the IND-AS 115 transition adjustment. Such view finds support from the judgement of the Hon’ble Supreme Court in the case of Laxmipat Singhania vs. CIT (1969) (72 ITR 291) (refer Page 607-611 of Paper Book Vol- 2), wherein, the Hon’ble Court observed as follows – “It is a fundamental rule of the law of taxation that, unless otherwise expressly provided, income cannot be taxed twice. Again, it is not open to the ITO, if income has accrued to the assessee, and is liable to be included in the total income of a particu…

DCIT, CIRCLE-7(1), DELHI vs. DLF LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

ITA 713/DEL/2024[2019-20]Status: DisposedITAT Delhi30 Oct 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…e. In view thereof, a reduction/adjustment should be allowed to the Appellant in AY 2019-20 towards the IND-AS 115 transition adjustment. Such view finds support from the judgement of the Hon’ble Supreme Court in the case of Laxmipat Singhania vs. CIT (1969) (72 ITR 291) (refer Page 607-611 of Paper Book Vol- 2), wherein, the Hon’ble Court observed as follows – “It is a fundamental rule of the law of taxation that, unless otherwise expressly provided, income cannot be taxed twice. Again, it is not open to the ITO, if income has accrued to the assessee, and is liable to be included in the total income of a particu…

DLF LIMITED,DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, appeal of the Revenue is dismissed

ITA 677/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…e. In view thereof, a reduction/adjustment should be allowed to the Appellant in AY 2019-20 towards the IND-AS 115 transition adjustment. Such view finds support from the judgement of the Hon’ble Supreme Court in the case of Laxmipat Singhania vs. CIT (1969) (72 ITR 291) (refer Page 607-611 of Paper Book Vol- 2), wherein, the Hon’ble Court observed as follows – “It is a fundamental rule of the law of taxation that, unless otherwise expressly provided, income cannot be taxed twice. Again, it is not open to the ITO, if income has accrued to the assessee, and is liable to be included in the total income of a particu…

DLF LIMITED,DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, appeal of the Revenue is dismissed

ITA 676/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

…e. In view thereof, a reduction/adjustment should be allowed to the Appellant in AY 2019-20 towards the IND-AS 115 transition adjustment. Such view finds support from the judgement of the Hon’ble Supreme Court in the case of Laxmipat Singhania vs. CIT (1969) (72 ITR 291) (refer Page 607-611 of Paper Book Vol- 2), wherein, the Hon’ble Court observed as follows – “It is a fundamental rule of the law of taxation that, unless otherwise expressly provided, income cannot be taxed twice. Again, it is not open to the ITO, if income has accrued to the assessee, and is liable to be included in the total income of a particu…

LSL TOOLS (P) LTD.,GURGAON vs. ACIT, CC-1, FARIDABAD

In the result, both the appeals are allowed

ITA 5644/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 143(2)Section 143(3)Section 145(3)Section 153DSection 234CSection 40A(2)(b)

…herefore the addition made by disallowing the director remuneration in the hands of the appellant, would lead to double taxation, which is not permissible in law. Reliance is placed upon following judgments: i) 42 ITR 427 (SC) CIT vs. DharamdasHargovandas ii) 72 ITR 291 (SC) LaxmipatSinghaniavs.CIT iii) 118 ITR 50 (SC) State of U.P. vs Raja Buland Sugar Co.Ltd iv) 404 ITR 738 (SC) Mahaveer Kumar Jain v. CIT v) 258 ITR 717 (Del) ITO v. Vinod Kumar Soni ……… 36. It is further submitted that it is settled law that no addition/disallowance can be made on the basis of surmises, suspicion and conjectures. Reliance for t…

LSL TOOLS (P) LTD,GURUGRAM vs. ACIT , CENTRAL CIRCLE-1, FARIDABAD

In the result, both the appeals are allowed

ITA 5643/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 143(2)Section 143(3)Section 145(3)Section 153DSection 234CSection 40A(2)(b)

…herefore the addition made by disallowing the director remuneration in the hands of the appellant, would lead to double taxation, which is not permissible in law. Reliance is placed upon following judgments: i) 42 ITR 427 (SC) CIT vs. DharamdasHargovandas ii) 72 ITR 291 (SC) LaxmipatSinghaniavs.CIT iii) 118 ITR 50 (SC) State of U.P. vs Raja Buland Sugar Co.Ltd iv) 404 ITR 738 (SC) Mahaveer Kumar Jain v. CIT v) 258 ITR 717 (Del) ITO v. Vinod Kumar Soni ……… 36. It is further submitted that it is settled law that no addition/disallowance can be made on the basis of surmises, suspicion and conjectures. Reliance for t…

SURBHIT IMPEX PRIVATE LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -8, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 2570/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Oct 2025AY 2018-19
For Appellant: Shri K. Shivaram Sr. Adv.& Shri Shashi Bekkal, ARFor Respondent: Shri Vivek Perampurna, (CIT-DR)
Section 147Section 263Section 41(1)

…come. Therefore, once an income tax is paid on\nthe said written off then the said income cannot be taxed twice. Reliance\nin this regard is being placed on the decision of the Hon'ble Supreme\nCourt in Laxmipat Singhania Vs. Commissioner of Income Tax,\nU.P. 72 ITR 291, wherein the Hon'ble Supreme Court has observed\nthat "It is a fundamental rule of law of taxation that, unless otherwise\nexpressly provided, income cannot be taxed twice. Similar view was\ntaken by the Hon'ble Apex Court in Jain Brothers and Others Vs.\nUnion of India and Other 77 ITR 107 and Mahaveer Kumar\nJain Vs. Commissioner of income Tax.…

GOODONE TRADERS PRIVATE LIMITED,DELHI vs. CIT(A), DELHI

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

ITA 5591/DEL/2024[2014-15]Status: DisposedITAT Delhi27 Oct 2025AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2014-15 Goodone Traders Private Vs. Commissioner Of Income Tax Limited, 886A/47 (Appeals), Ward No. 6, Mehrauli Delhi Delhi- 1100 30 Pan: Aaacy2998Q (Appellant) (Respondent)

For Appellant: Ms. Meenal Goyal, CA, Ms. VidhiFor Respondent: Shri Sanjeev Kaushal, CIT (DR)
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

…AO has failed to consider that same income cannot be taxed "twice" contrary to settled law qua alleged foreign inward remittances of Rs. 605,07,00,151/- duly disclosed in the financial statements and accordingly offered to tax vide Laxmipat Singhania Vs. CIT (72 ITR 291) (SC). 6. That on the facts and circumstances of the case and in law, the Ld. Authorities have erred by failing to consider that the total sales of Rs.867.48 Crores includes sales to Al Khat Al Fizi Trading LLC and thereby reconciles with the amount disclosed as export sales in the audited financial statements which was duly offered to tax thereby…

SHANTHI VIOLET RODRIGUES,BENGALURU vs. INCOME TAX OFFICER, WARD-4(2)(1), BANGALORE

In the result, appeal of the assessee is allowed

ITA 1475/BANG/2025[2020-21]Status: DisposedITAT Bangalore22 Aug 2025AY 2020-21

Bench: Dr. Dipak P. Ripote & Shri Prakash Chand Yadavassessment Year: 2020-21 Shanthi Violet Rodrigues, The Income Tax Officer, Cp4 Wing-1, 4178, Ward-4(2)(1), Sobha City Casa, Bengaluru. Paradise Enclave, Devin Paradise, Vs. Jalavayuvihar, Bengaluru-560043. Pan No : Avmpr6706M Appellant Respondent Appellant By : Ms. Sunaina Bhatia, Ca Respondent By : Sri Ganesh R Ghale, Advocate-Standing Counsel For Revenue Date Of Hearing : 21.08.2025 Date Of Pronouncement : 22.08.2025 O R D E R Per Dr. Dipak P. Ripote: This Is An Appeal Filed By Shanthi Violet Rodrigues Against The Order Of The Learned Commissioner Of Income Tax (Appeals) (Nfac) (In Short “Ld. Cit(A)”) Passed U/S. 250 Of The Income Tax Act, 1961 (In Short “The Act”) For Asst Year 2020-21 On 05/06/2025 Emanating From Assessment Order Dated 24/02/2025 Passed U/S. 147 R.W.S 144B Of The Act. Submissions Of The Ld. Ar: 2. The Ld. Ar Invited Our Attention To The Assessment Order Dated 24/02/2025 For Asst. Year 2020-21. The Ld. Ar Submitted

For Appellant: Ms. Sunaina Bhatia, CA
Section 147Section 148Section 148ASection 250

…vs. DCIT (Central) on identical facts has held that same income cannot be taxed in the hands of both husband as well as wife. The ITAT, Mumbai in the said case has relied on the decision of the Hon’ble Supreme Court in the case of Laxmipath Singhania vs. CIT (72 ITR 291, 294) (SC). 9. In these facts and circumstances of the case, we are convinced that the assessee’s husband had shown the entire sale consideration in his return of income and hence, by adding the same income in the assessee’s hands will be double taxation. Page 6 of 7 Shanthi Violet Rodrigues vs. ITO Therefore, we direct the Ld. AO to delete the a…

DCIT 42 1 1 , MUMBAI vs. PRATAP UTTAM PUROHIT, MUMBAI

ITA 2042/MUM/2025[2014]Status: DisposedITAT Mumbai16 Jun 2025
For Appellant: \nShri Bharat KumarFor Respondent: \nShri R. A. Dhyani
Section 143(1)Section 250Section 41(1)(a)Section 68Section 69C

…ncome. Therefore, once an income tax is paid on the said written off then\nthe said income cannot be taxed twice. Reliance in this regard is being placed\non the decision of the Hon'ble Supreme Court in Laxmipat Singhania\nVs. Commissioner of Income Tax, U.P. 72 ITR 291, wherein the\nHon'ble Supreme Court has observed that \"It is a fundamental rule of law of\ntaxation that, unless otherwise expressly provided, income cannot be taxed\ntwice. Similar view was taken by the Hon'ble Apex Court in Jain\nBrothers and Others Vs. Union of India and Other 77 ITR 107 and\nMahaveer Kumar Jain Vs. Commissioner of income Tax.…

ALP OVERSEAS PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-20, NEW DELHI

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

ITA 2356/DEL/2023[2018-19]Status: DisposedITAT Delhi16 May 2025AY 2018-19

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarassessment Year: 2018-19 Alp Overseas Pvt. Ltd., Vs. Acit, 25/3, Anbrose House, Central Circle -20, East Patel Nagar, New Delhi New Delhi Pin 1100 08 Pan No. Aaacg6366L (Appellant) (Respondent)

For Appellant: Shri Pranshu Goel, CA & Shri AdityaFor Respondent: Shri Amit Shukla, Sr. DR
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 35Section 35(1)Section 37(1)

…erative to state that the assessment for AY 2019-20 has also been completed and no inference has been drawn in that year. Making the addition again would amount to double taxation, which is impermissible. Hon'ble Apex Court in Laxmipat Singhania v. CIT [1969] 72 ITR 291, has held that unless expressly provided, income cannot be taxed twice. This principle has been reiterated by the Hon'ble High Courts, including the decision in T.N.K. Govindaraju Chetty & Co. v. CIT [1964] 51 ITR 731 (Madras) and CIT v. R. Dalmia [1981] 6 Taxman 47 (Delhi), where it was held 6 that repeated taxation of the same income in the han…

RAMDAS SINGH TOMAR,RAJASTHAN vs. INCOME TAX OFFICER, WARD 1(1), JAIPUR

ITA 1092/JPR/2024[2018-19]Status: DisposedITAT Jaipur01 Apr 2025AY 2018-19

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपील सं. / ITA No. 1092/JP/2024 निर्धारण वर्ष / Assessment Year : 2018-19 Ramdas Singh Tomar M/s Om Sai Construction, Harikand Ka Pura Faraspura, Dholpur बनाम Income Tax Officer, Ward 1(1), Jaipur स्थायीलेखा सं. / जीआईआर सं./PAN/GIR No.: AMZPT4728R अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Rahul Pandya, Adv. राजस्व की ओर से / Revenue by: Sh. Anup Singh, Addl. CIT सुनवा

For Appellant: Sh. Rahul Pandya, AdvFor Respondent: Sh. Anup Singh, Addl. CIT
Section 115BSection 139(1)Section 142(1)Section 147Section 148Section 148ASection 2Section 271ASection 69A

…proceedings initiated under section 263 had admittedly been dropped, assessee could not be taxedonceagain for same income in relevant assessment year - Held, yes [Para 11] [In favour of assessee]” Laxmipat Singhania vs. Commissioner of Income Tax, U.P. (1969) 72 ITR 291 at 294 wherein this Court has observed that “It is a fundamental rule of law of taxation that, unless otherwise expressly provided, income cannot be taxed twice". Jain Brothers and Others vs. Union of India and Others (1970) 77 ITR 107 (SC), it has been held as under:- “6 It is not disputed that there can be double taxation if the legislature has…

THE SARASWAT CO-OPERATIVE BANK LIMITED,PRABHADEVI, MUMBAI vs. DCIT-(1)(3)(1), MUMBAI

In the result the appeal filed by the assessee stands partly allowed for statistical purpose

ITA 4513/MUM/2024[2020-2021]Status: DisposedITAT Mumbai29 Nov 2024AY 2020-2021

Bench: Smt Beena Pillai & Shri Prabhash Shankarassessment Year: 2020-21 The Saraswat Co- Dcit- 1(3)(1) Operative Bank Limited Aayakar Bhavan, Eknath Thakur Bhavan, M. K. Road, 953 Apasaheb Marathe Mumbai- 400020. Marg, Vs. Prabhadevi S. O., Mumbai- 400025. Pan: Aabat4497Q (Appellant) (Respondent)

For Appellant: Shri Anish Thacker & Pranay GandhiFor Respondent: Dr. Kishore Dhule- CIT DR
Section 143(1)Section 250Section 36(1)Section 37Section 37oSection 41

…as income further adjustment u/s section 143(1) of Rs 2,31,41,20,871/- was not required. Assessing a disallowance already disallowed is actually double taxing the same income. Hon'ble Supreme Court in the case of Laxmipat Singhania vs. CIT reported in (1969) 72 ITR 291 (SC) wherein at page 294 Hon'ble Apex Court has observed that "it is a fundamental rule of law of taxation that, unless otherwise expressly provided, income cannot be taxed twice". Taxing the same income twice is not according to the statute and against natural justice. The expenditure not claimed by the appellant as business expense of Rs 2,31,41…

DILIP MAHESHWARI,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3,, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 666/JPR/2024[2017-18]Status: DisposedITAT Jaipur30 Sept 2024AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri S.R. Sharma, CA &For Respondent: Shri Ajey Malik, Ld. CIT
Section 115BSection 132Section 143(2)Section 143(3)Section 153ASection 250Section 68

…he income tax law is to charge tax on income but in the hands of same person only once. There could be no double taxation of the same income in the hands of same person (See also Ghisa Lal Vs. CIT 248 ITR 506). In the case of Laxmipat Singhania Vs. CIT (1969) 72 ITR 291 (SC) at 294 where Hon'ble Supreme Court has observed that “It is fundamental rule of law of taxation that, unless otherwise expressly provided, income cannot be taxed twice (See also Jain Brothers Vs. Union of India (1970) 77 ITR 107 (SC). The amount of Rs. 1,25,00,000/- was deposited in Bank A/c in the period prior to demonetization and in demone…

KHOOBSOORAT FABRICS PVT LTD.,NEW DELHI vs. ITO WARD 14(3), NEW DELHI

Appeal are allowed

ITA 428/DEL/2024[2017-18]Status: DisposedITAT Delhi11 Sept 2024AY 2017-18

Bench: Shri Kul Bharat[Assessment Year: 2017-18

Section 115BSection 68

…esult of such cash sales which have been deposited in the bank cannot be taxed under section 68 of the Act as that tantamount to double taxation. It is submitted that double taxation is not permissible in law. Reliance is placed on the following judgments: i) 72 ITR 291 (SC) CIT v. Laxmi Pat Singhania vs. CIT ii) 118 ITR 50 (SC) State of Uttar Pradesh vs. Raja Buland Sugar Co. Ltd. iii) 344 ITR 294 (MP) CIT v. Jaora Flour and Foods (P) Ltd. (pages 6-87 of JPB) 10 iv) ITA No. 995/Ahd./2014 dated 6.1.2020 Shree Sanad Textiles Industries Ltd. Vs. DCIT (extract pages 170-171 of Paper Book) v) ITA 8761/D/2019 dated 1…

INCOME TAX OFFICER, WARD-6(2), JAIPUR, NCR BUILDING, STATUE CIRCLE JAIPUR vs. VASUDEV HEMRAJANI, ARJUN NAGAR, JAIPUR

The appeal of the revenue stands dismissed

ITA 634/JPR/2024[2020-2021]Status: DisposedITAT Jaipur05 Sept 2024AY 2020-2021

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Anil Dhaka, CIT
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 250Section 68

…ch has already suffered tax. Such an act of the ld. AO is taxation of an income twice. It is a settled proposition of law that an income cannot be taxed twice unless otherwise expressly provided. Hon’ble Supreme court in the case of Laxmipat Singhania v. CIT (72 ITR 291) held that “Taxing Statute should not be interpreted in such a manner that its effect will be to cast a burden twice over the payment of tax on the taxpayer unless the language of the statute is so compellingly certain that the court has no other alternative than to accept it.” 58 ITO vs. Vasudev Hemrajani Hon’ble Apex court in case of Jain Bro…

DCIT CENTRAL CIRCLE 6(1), MUMBAI, NARIMAN POINT MUMBAI vs. GNP REALTY LLP, THANE

In the result, the appeal filed by the Revenue stands partly allowed

ITA 3105/MUM/2023[2021-22]Status: DisposedITAT Mumbai29 May 2024AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

For Appellant: Shri Nishit Gandhi, A.RFor Respondent: Dr. Kishor Dhule, D.R
Section 132Section 139(1)Section 142(1)Section 250

…sive reliance has been placed on the statement of Sh. Girish Pawar. 9.11 Apart from the above, there are various judicial precedents which have held that the same income cannot be taxed twice in the hands of two separate entities: • Laxmipat Singhania v CIT (72 ITR 291) (SC) • Joti Prasad Agarwal vs. ITO [37 ITR 107] [AII] • CIT vs. Murlidhar Jhawar & Purna Ginning and Pressing Factory [60 ITR 95] 9.12 M/s GNP Realty LLP is a Limited Liability Partnership formed and incorporated on 21.12.2017 under The Limited Liability Partnership Act, 2008 with a main object of acquiring, exploring, prospecting, developing an…

PRIYANKA SURANA,JAIPUR vs. ITO WARD 5(1), JAIPUR, JAIPUR

In the result, the appeal of the assesee is allowed

ITA 102/JPR/2024[2017-18]Status: DisposedITAT Jaipur28 May 2024AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sharwan Kumar Gupta, AdvFor Respondent: Smt. Monisha Choudhary, Addl. CIT-DR
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 234ASection 68

…provided, same income cannot be taxed twice. In this preposition kindly refer the decision of this Honble Bench in the case of Sh. Avdesh Dangayach V/s ACIT Cir.6 in ITA No. 464/Jp/2016 dt. 23.02.2017 vide page 10. Also Kindly refer Laxmipat Singhania v/s CIT 72 ITR 291(SC), CIT v/s M.P. JayaRam 100 Taxman 544(Kar), Gyan Chand Jain v/s ITO 73 TTJ 859(Jd). Gem Palace v/s CIT 168 ITR 543(Raj.)., Ramanlal Madan Lal v/s CIT 116 ITR 657(Cal.), Jain Brothers v/s UOI 77 ITR 107(SC), Further the Honble ITAT in the group case of M/s Gowadia Jewellers in ITA No. 776/Ju/05 at page 8-para 15 dt. 30.09.2008 deleted certain ad…

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