M.M. Ipoh & Ors. v. CIT

67 ITR 106Supreme Court of India1968#3296 most cited

What is M.M. Ipoh & Ors. v. CIT authority for?

The doctrine of res judicata does not apply to income tax assessments, meaning a decision on a question of fact or law in one assessment year is not binding in another assessment year. Findings of fact in an earlier year can be cogent evidence, but are not conclusive for subsequent years.

36

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

M.M. Ipoh & Ors. v. CIT · 67 ITR 106 · SC · 1968 · res judicata · income tax assessment · binding decision · subsequent year · facts and law · conclusive findings

Sections most often in play

Section 143(3)Section 1961Section 10AASection 10DSection 131 of the Income Tax ActSection 133(6) of the Income Tax ActSection 139Section 142(1)

Issues it is cited on

section 80absection 245d(4)section 80jsection 245don money receiptassessment order erroneousmanagement feessection 245revision u/s 263domestic companysection 80cforeign tax credit

Judgments citing M.M. Ipoh & Ors. v. CIT

MISRILALL JAIN & SONS,SINGHBHUM WEST vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result the appeal filed by the assessee is allowed

ITA 467/RAN/2024[2014-15]Status: DisposedITAT Ranchi20 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.467/Ran/2024 Assessment Year: 2014-15 Misrilall Jain & Sons….…………….…….…............................……….……Appellant M. D. House, Chaibasa Singhbhum West, Jharkhand – 833201. [Pan: Aabfm2851Q] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 20, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 09.10.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 139Section 143(3)Section 144Section 147Section 148Section 250

…sistency”, which requires that when the facts & circumstances continue to remain the same, then there should not be any variation in the treatment from earlier year. The Hon’ble Supreme Court has held in several cases including M.M. Ipoh & Ors. vs. CIT (1968) 67 ITR 106 (SC) that : The doctrine of res judicata does not apply so as to make a decision on a question of fact or law in a proceeding for assessment in one year binding in another year. At the same time, it is equally true that the principle of consistency has also been advocated by several Hon’ble courts including the Hon’ble Supreme Court in Radhasoami…

DCIT,CENTRAL CIRCLE-1, GUWAHATI vs. SATISH JALAN, SHILLONG

Appeal of the Revenue is allowed for statistical purposes

ITA 62/GTY/2025[2017-18]Status: DisposedITAT Guwahati17 Nov 2025AY 2017-18

Bench: Hon'Ble Itat. 3. There Are Currently More Than 300 Time Barred Assessment & 200 Penalty Cases Are Pending In This Office. Due To Shortage Of Manpower It Was Delayed In The Filing Of Appeal Before Hon'Ble Itat.

Section 131Section 250Section 68

…e same facts on which a decision of an earlier year was arrived at. We may draw strength from the cases of Joint Family of Udayan Chinubhai v. CIT [1967] 63 ITR 416 (SC) and Dwarkadas Kesardeo Morarka v. CIT [1962] 44 ITR 529 (SC). In M.M. Ipoh v. CIT [1968] 67 ITR 106, the Supreme Court held that the rule of res judicata does not apply so as to make a decision on question of facts or law in a proceeding for assessment in one year binding in another year and that the assessment and the facts found are conclusive I.T.A. No. 62/GTY/2025 Satish Jalan only in the year of assessment, the findings on a question of fa…

YCH LOGISTICS INDIA PRIVATE LIMITED,KANCHIPURAM, TAMILNADU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -3(2), CHENNAI, CHENNAI

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

ITA 1330/CHNY/2023[2012-13]Status: DisposedITAT Chennai19 Mar 2025AY 2012-13

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1330/Chny/2023 िनधा"रणवष" / Assessment Year: 2012-13 Ych Logistics India Private Ltd., Assistant Commissioner Of Plot D V 1, Hi-Tech Sez Phase Ii, V. Income Tax, Sirumangadu Village, Sriperumbudur Corporate Circle -3(2), Taluk, Tamil Nadu 602 105. Chennai. [Pan: Aaacy-2873-L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. Ajit Kumar Jain, CA by VirtualFor Respondent: Shri. A. Sasikumar, CIT
Section 10ASection 250Section 92C(3)Section 92D

…ence is made to few cases in which it has been held that the principle of res judicata is not applicable for tax matters:  CITv. Seshasayee industries Ltd[(Mad) 242 ITR 691]  Ace Investments (P) Ltd v. CIT [(Mad) 244 ITR 166]  M.M. lpoh &Ors. v. CIT [(SC) 67 ITR 106]  New Jehangir Vakil Mills Co. Ltdv. CIT[(SC) 49 ITR 137] :-26-: ITA. No: 1330/Chny/2023  Bharat Sanchar Nijam Ltd &Ors v. UOI &Ors. [(SC) 282 ITR 273] 15. Thus, the ld.DR submitted that the claim of the assessee for deduction under Sec 10AA of the Act, is not tenable based on the arguments advanced, authorities cited and submissions made since…

THE DY.CIT, CIRCLE-1(1)(1), VADODARA vs. INA BEARING INDIA PVT. LTD., PUNE

In the result, Ground Nos

ITA 540/AHD/2022[2014-15]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R

…eparate assessment year and the doctrine of res judicata does not apply so as to make a decision on a question of fact or law in a proceeding for assessment in one year binding in another year as held by the Hon'ble Apex Court in the case of M.M. Ipoh & Ors, (67 ITR 106) and accordingly the decision of A.Y. 2009-10 is not binding for A.Y. 2013-14? [viii] On the facts and in the circumstances of the case and in law, the Ld. C1T (A) has erred in granting benefit of +/- 3% margin to the assessee in determining the ALP? [ix] It is, therefore, prayed that the order of the Ld. C1T (A) may be set aside and that of the A…

THE DY.CIT, CIRCLE-1(1)(1), VADODARA vs. INA BEARING INDIA PVT. LTD., PUNE

In the result, Ground Nos

ITA 539/AHD/2022[2013-14]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R

…eparate assessment year and the doctrine of res judicata does not apply so as to make a decision on a question of fact or law in a proceeding for assessment in one year binding in another year as held by the Hon'ble Apex Court in the case of M.M. Ipoh & Ors, (67 ITR 106) and accordingly the decision of A.Y. 2009-10 is not binding for A.Y. 2013-14? [viii] On the facts and in the circumstances of the case and in law, the Ld. C1T (A) has erred in granting benefit of +/- 3% margin to the assessee in determining the ALP? [ix] It is, therefore, prayed that the order of the Ld. C1T (A) may be set aside and that of the A…

CHAND MONAMMAD,AJMER vs. ITO, WARD 1(3), AJMER

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

ITA 340/JPR/2022[2012-12]Status: DisposedITAT Jaipur28 Aug 2023AY 2012-12

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

For Appellant: Shri Nikhlesh Kataria, CAFor Respondent: Shri A.S. Nehra, Addl.CIT
Section 139(1)Section 147Section 148Section 151

…cisions given in an assessment order for an earlier year are not binding either on the assessee or on the Department in a subsequent year. This rule was laid down in the case of CIR vs. Sneath [1932] 17 TC 149 CA. In the case of M.M. Ipoh &Ors. vs. CIT (1968) 67 ITR 106 (SC), the Hon’ble Supreme Court has held that the doctrine of res judicata does not apply so as to make a decision on a question of fact or law in a proceeding for assessment in one year binding in another year. The assessment and the facts found are conclusive only in the year of assessment; the findings on question 16 SHRI CHAND MOHAMMAD VS ITO…

DY COMMISSIONER OF INCOME-TAX, SANGLI CIRCLE,, SANGLI vs. ANAND DEVELOPERS, SANGLI

In the result, the appeal filed by the assessee in ITA

ITA 67/PUN/2021[2014-15]Status: DisposedITAT Pune20 Jun 2023AY 2014-15
For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Keyur Patel &
Section 143(3)Section 42

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI S. S. VISWANETHRA RAVI, JUDICIAL MEMBER आयकर अपील सं. / ITA No.458/PUN/2020 िनधा"रण वष" / Assessment Year : 2014-15 Anand Developers, Vs. ITO, Ward-2(1), Sangli. 365/3/2/2, Sharayu, Nagraj Colony, Vishrambaug, Sangli- 416416. PAN : AAQFA4833M Appellant Respondent आयकर अपील सं. / ITA No.67/PUN/2021 िनधा"रण वष" / Assessment Year: 2014-15 DCIT, Sangli Circle, Sangli. Vs. Anand Developers, 1448, Rajaram Apartments, Timber Area, Sangli- 416416. PAN : AAQFA4833M Appellant Respondent C.O. No.15/PUN/2023 (A…

ANAND DEVELOPERS,SANGLI vs. INCOME-TAX OFFICER, WARD 2(1), SANGLI

In the result, the appeal filed by the assessee in ITA

ITA 458/PUN/2020[2014-15]Status: DisposedITAT Pune20 Jun 2023AY 2014-15
For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Keyur Patel &
Section 143(3)Section 42

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI S. S. VISWANETHRA RAVI, JUDICIAL MEMBER आयकर अपील सं. / ITA No.458/PUN/2020 िनधा"रण वष" / Assessment Year : 2014-15 Anand Developers, Vs. ITO, Ward-2(1), Sangli. 365/3/2/2, Sharayu, Nagraj Colony, Vishrambaug, Sangli- 416416. PAN : AAQFA4833M Appellant Respondent आयकर अपील सं. / ITA No.67/PUN/2021 िनधा"रण वष" / Assessment Year: 2014-15 DCIT, Sangli Circle, Sangli. Vs. Anand Developers, 1448, Rajaram Apartments, Timber Area, Sangli- 416416. PAN : AAQFA4833M Appellant Respondent C.O. No.15/PUN/2023 (A…

DEPUTY COMMISSIONER OF INCOME TAX, ( CENTRAL)-2, RAIPUR vs. SHRI SANJAY KUMAR AGRAWAL, RAIPUR

In the result, both appeals of the revenue are dismissed

ITA 179/RPR/2019[2015-16]Status: DisposedITAT Raipur20 Sept 2022AY 2015-16

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.169 & 179/Rpr/2019 (ननधाारण वषा / Assessment Year : 2015-2016 & 2016-2017) Acit-2, Raipur Vs Shri Sanjay Kumar Agrawal, Shri Shyam Tower, Kavita Nagar, Main Road, Avanti Vihar, Raipur Pan No. : Afdpa 6944 B (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Shri P.K.Mishra, CIT-DR
Section 132Section 145(3)

…आयकर अऩीऱीय अधधकरण, रायऩुर न्यायऩीठ, रायऩुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR श्री रविश सूद, न्याययक सदस्य एवं श्री अरुण खोड़वऩया, ऱेखा सदस्य के समक्ष । BEFORE SHRI RAVISH SOOD, JM & SHRI ARUN KHODPIA, AM आयकर अऩीऱ सं./ITA No.169 & 179/RPR/2019 (ननधाारण वषा / Assessment Year : 2015-2016 & 2016-2017) ACIT-2, Raipur Vs Shri Sanjay Kumar Agrawal, Shri Shyam Tower, Kavita Nagar, Main Road, Avanti Vihar, Raipur PAN No. : AFDPA 6944 B (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. राजस्व की ओर से /Revenue by : Shri P.K.Mishra, CIT-DR ननधााररती की ओर से /Assessee by : Shri Veekaas S Sharma, CA…

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-2, RAIPUR vs. SHRI SANJAY KUMAR AGRAWAL,, RAIPUR

In the result, both appeals of the revenue are dismissed

ITA 169/RPR/2019[2016-17]Status: DisposedITAT Raipur20 Sept 2022AY 2016-17

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.169 & 179/Rpr/2019 (ननधाारण वषा / Assessment Year : 2015-2016 & 2016-2017) Acit-2, Raipur Vs Shri Sanjay Kumar Agrawal, Shri Shyam Tower, Kavita Nagar, Main Road, Avanti Vihar, Raipur Pan No. : Afdpa 6944 B (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Shri P.K.Mishra, CIT-DR
Section 132Section 145(3)

…आयकर अऩीऱीय अधधकरण, रायऩुर न्यायऩीठ, रायऩुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR श्री रविश सूद, न्याययक सदस्य एवं श्री अरुण खोड़वऩया, ऱेखा सदस्य के समक्ष । BEFORE SHRI RAVISH SOOD, JM & SHRI ARUN KHODPIA, AM आयकर अऩीऱ सं./ITA No.169 & 179/RPR/2019 (ननधाारण वषा / Assessment Year : 2015-2016 & 2016-2017) ACIT-2, Raipur Vs Shri Sanjay Kumar Agrawal, Shri Shyam Tower, Kavita Nagar, Main Road, Avanti Vihar, Raipur PAN No. : AFDPA 6944 B (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. राजस्व की ओर से /Revenue by : Shri P.K.Mishra, CIT-DR ननधााररती की ओर से /Assessee by : Shri Veekaas S Sharma, CA…

ACIT 2(3) (1), MUMBAI vs. M/S. THAKKR HOUSING DEVELOPMENT PVT. LTD, MUMBAI

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2135/MUM/2021[2012-13]Status: DisposedITAT Mumbai22 Aug 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ficer. It is trite law that the assessment is final and conclusive between parties and only in relation to assessment for the financial year for which it is made. Reference can be made decision of Hon'ble Supreme Court in the case of M.M. Ipoh & Ors. vs. CIT, 67 ITR 106 (SC). 34. This is underlying principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income i…

ACIT 2(3) (1) , MUMBAI vs. M/S. THAKKAR APANA GHAR PVT. LTD, MUMBAI

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2134/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Aug 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ficer. It is trite law that the assessment is final and conclusive between parties and only in relation to assessment for the financial year for which it is made. Reference can be made decision of Hon'ble Supreme Court in the case of M.M. Ipoh & Ors. vs. CIT, 67 ITR 106 (SC). 34. This is underlying principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income i…

ACIT 2(3) (1) , MUMBAI vs. M/S. THAKKAR APNA GHAR NIRMAN PVT. LTD, MUMBAI

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2133/MUM/2021[2012-13]Status: DisposedITAT Mumbai22 Aug 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ficer. It is trite law that the assessment is final and conclusive between parties and only in relation to assessment for the financial year for which it is made. Reference can be made decision of Hon'ble Supreme Court in the case of M.M. Ipoh & Ors. vs. CIT, 67 ITR 106 (SC). 34. This is underlying principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income i…

ACIT 2(3) 1, MUMBAI vs. M/S. THAKKAR GRIH NIRMAN PVT. LTD, MUMBAI

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2132/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Aug 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ficer. It is trite law that the assessment is final and conclusive between parties and only in relation to assessment for the financial year for which it is made. Reference can be made decision of Hon'ble Supreme Court in the case of M.M. Ipoh & Ors. vs. CIT, 67 ITR 106 (SC). 34. This is underlying principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income i…

ACIT 2(3) (1) , MUMBAI vs. M/S. THAKKAR HOUSING DEVELOPEMENT PVT. LTD, MUMBAI

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2131/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Aug 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ficer. It is trite law that the assessment is final and conclusive between parties and only in relation to assessment for the financial year for which it is made. Reference can be made decision of Hon'ble Supreme Court in the case of M.M. Ipoh & Ors. vs. CIT, 67 ITR 106 (SC). 34. This is underlying principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income i…

THE ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-2, RAIPUR vs. SHRI SANJAY KUMAR AGRAWAL, RAIPUR

ITA 43/RPR/2018[2014-15]Status: DisposedITAT Raipur31 May 2022AY 2014-15

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 43/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15

For Appellant: Shri Veekaas S. Sharma, ARFor Respondent: Shri P.K Mishra, CIT DR
Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 245D(4)

…om the assessment for a specific year cannot in the absence of any supporting evidence be extrapolated to another year. Our aforesaid conviction is supported by the judgment of the Hon’ble Supreme Court in the case of, viz. (i). M.M Ipoh & Ors. Vs. CIT (1968) 67 ITR 106 (SC); (ii). ITO Vs. Murlidhar Bhagwandas (1964) 52 ITR 335 (SC); and (iii). Bharat Sanchar Nigam Ltd. & Anr. Vs. UPI & Ors. (2006) 282 273 (SC). Interestingly, if the observations of the AO are to be accepted, then, it would mean that once an assessee is visited with search proceedings, and he after considering the incriminating documents unearthe…

THE ASSISTANT COMMISSIONER OF INCOME TAX(CENTRAL)-2, RAIPUR vs. M/S RADHESHYAM AGRAWAL , RAIPUR

ITA 42/RPR/2018[2014-15]Status: DisposedITAT Raipur31 May 2022AY 2014-15

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 42/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income Tax, (Central)-2, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Radheshyam Agarwal L-24, Avanti Vihar, Raipur (C.G.) Pan : Aacfr8916J ……""यथ" / Respondent

For Appellant: Shri Veekaas S. Sharma, ARFor Respondent: Shri P.K Mishra, DR
Section 132(1)Section 143(2)Section 143(3)Section 153ASection 245D(4)

…om the assessment for a specific year cannot in the absence of any supporting evidence be extrapolated to another year. Our aforesaid conviction is supported by the judgment of the Hon’ble Supreme Court in the case of, viz. (i). M.M Ipoh & Ors. Vs. CIT (1968) 67 ITR 106 (SC); (ii). ITO Vs. Murlidhar Bhagwandas (1964) 52 ITR 335 (SC); and (iii). Bharat Sanchar Nigam Ltd. & Anr. Vs. UPI & Ors. (2006) 282 273 (SC). Interestingly, if the observations of the AO are to be accepted, then, it would mean that once an assessee is visited with search proceedings, and he after considering the incriminating documents unearthe…

ACIT,, NEW DELHI vs. M/S KRISHAK BHARATI COOPERATIVE LTD.,, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2973/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Dec 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

…t view adopted by the Department itself whereas the principle of res- judicata is not applicable in income tax proceedings as held by the Apex court in the case of Joint Family of Udayan Chinu Bhai vs. CIT, 63 ITR 416(SC) and in the case of M.M. Ipoh vs. CIT, 67 ITR 106(SC) and new facts such as legal value of letter interpreting DT AA were expounded by CIT." 8. "On the facts and in the circumstances of the case, the Ld. CIT(A) did not consider the ratio of judgement of Hon'ble Supreme Court in the case of Tarulata Shyam, 108 ITR 345 wherein in was that held that there is no scope importing into the statute words…

ACIT,, NEW DELHI vs. M/S KRISHAK BHARATI COOPERATIVE LTD.,, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2972/DEL/2017[2010-11]Status: DisposedITAT Delhi29 Dec 2021AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

…t view adopted by the Department itself whereas the principle of res- judicata is not applicable in income tax proceedings as held by the Apex court in the case of Joint Family of Udayan Chinu Bhai vs. CIT, 63 ITR 416(SC) and in the case of M.M. Ipoh vs. CIT, 67 ITR 106(SC) and new facts such as legal value of letter interpreting DT AA were expounded by CIT." 8. "On the facts and in the circumstances of the case, the Ld. CIT(A) did not consider the ratio of judgement of Hon'ble Supreme Court in the case of Tarulata Shyam, 108 ITR 345 wherein in was that held that there is no scope importing into the statute words…

M/S. KRISHAK BHARTI COOPERATIVE LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2342/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Dec 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

…t view adopted by the Department itself whereas the principle of res- judicata is not applicable in income tax proceedings as held by the Apex court in the case of Joint Family of Udayan Chinu Bhai vs. CIT, 63 ITR 416(SC) and in the case of M.M. Ipoh vs. CIT, 67 ITR 106(SC) and new facts such as legal value of letter interpreting DT AA were expounded by CIT." 8. "On the facts and in the circumstances of the case, the Ld. CIT(A) did not consider the ratio of judgement of Hon'ble Supreme Court in the case of Tarulata Shyam, 108 ITR 345 wherein in was that held that there is no scope importing into the statute words…

Showing 1–20 of 36 · Page 1 of 2