Mahendra Mills Ltd. v. Appellate Assistant Commissioner

99 ITR 135Supreme Court of India1975#3611 most cited

What is Mahendra Mills Ltd. v. Appellate Assistant Commissioner authority for?

A court decision serves as a precedent based on its specific facts, requiring tax authorities and tribunals to apply its reasoning to new cases with careful consideration of the individual circumstances.

33

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

Mahendra Mills Ltd. · Appellate Assistant Commissioner · 99 ITR 135 SC · precedent on own facts · apply ratio with care · discern facts · tax authorities · tribunals

Sections most often in play

Section 153ASection 153DSection 148Section 143(2)Section 143(3)Section 144ASection 145(3)Section 147

Issues it is cited on

section 274(2)section 243section 245hacasus omissussection 245csettlement applicationsection 245d(4)section 153(4)section 135asection 144basection 245dsection 244

Judgments citing Mahendra Mills Ltd. v. Appellate Assistant Commissioner

ACIT, CENTRAL CIRCLE-II, LUCKNOW, LUCKNOW vs. RAKESH KUMAR PANDEY, GONDA U.P.

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 460/LKW/2025[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 351/LKW/2025[2018-19]Status: DisposedITAT Lucknow11 Dec 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 349/LKW/2025[2016-17]Status: DisposedITAT Lucknow11 Dec 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

ASSISTANT COMMISSIONER OF INCOME TAX, ALLAHABAD vs. JYOTI MEDISERVICES LTD., ALLAHABAD

ITA 129/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 44 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

JYOTI MEDISERVICES PRIVATE LIMITED, ,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, , ALLAHABAD

ITA 115/ALLD/2025[2013-14]Status: DisposedITAT Allahabad21 Nov 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 44 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

JYOTI MEDISERVICES PRIVATE LIMITED,,ALLAHABAD vs. DCIT, CENTRAL CIRCLE,, ALLAHABAD

ITA 114/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 44 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

JYOTI MEDISERVICES PRIVATE LIMITED,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, ALLAHABAD, ALLAHABAD

ITA 113/ALLD/2025[2011-12]Status: DisposedITAT Allahabad21 Nov 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 44 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

JEEVAN JYOTI INFRASTRUCTURE COMPANY PRIVATE LIMITED,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, ALLAHABAD , ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 56/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

MINTO COLONIZERS PRIVATE LIMITED,ALLAHABAD vs. DCIT CENTRAL CIRCLE , ALLAHABAD, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 54/ALLD/2025[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

DEPUTY COMMISSIONER OF INCOME TAX, ALLAHABAD vs. NAVJEEVAN PEDIATRICS PRIVATE LIMITED, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 44/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 41/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

DEPUTY COMMISSIONER OF INCOME TAX, ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 40/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

DEPUTY COMMISSIONER OF INCOME TAX(CENTRAL CIRCLE), ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 39/ALLD/2025[2011-12]Status: DisposedITAT Allahabad30 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

ARPIT HOSPITAL PRIVATE LIMITED,,ALLAHABAD vs. DCIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 14/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

ARPIT HOSPITAL PRIVATE LIMITED,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, , ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 13/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 40/ALLD/2019[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 39/ALLD/2019[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 38/ALLD/2019[2011-12]Status: DisposedITAT Allahabad30 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 37/ALLD/2019[2010-11]Status: DisposedITAT Allahabad30 Sept 2025AY 2010-11

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 36/ALLD/2019[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…t the irregularity supervened not at the initial stage, but at a later stage of the proceedings would not lead to nullity. Learned Departmental Representatives further placed reliance on the case law in Mahendra Mills Ltd. vs. Appellate Assistant Commissioner 99 ITR 135 (SC) for the proposition that a decision is a precedent on its own facts; that each case presents its own features; and that Income Tax authorities and Tribunals are supposed to apply the ratio of a decision to the facts of particular cases with due care and discernment. They also placed reliance on the case laws in the cases of 155 ITR 120 (SC) D…

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Mahendra Mills Ltd. v. Appellate Assistant Commissioner (99 ITR 135) — Cited in 33 Judgments | BharatTax