Mewal Day (1976) 103 ITR 437 (SC), Divya Capital One (P) Ltd. v. ACIT

463 ITR 139High Court#17959 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 344,197 Indian tax judgments — from 2025 to 2026.

Sections most often in play

Section 143(3)Section 147Section 148Section 149Section 151Section 250

Issues it is cited on

section 148bsanction under section 151approval under section 151paper companyorder under section 148a(d)short term capital gainsspecified authorityincome escaping assessmentprincipal commissioner of income-taxsection 148a(b)short term capital gainsection 148a(d)

Judgments citing Mewal Day (1976) 103 ITR 437 (SC), Divya Capital One (P) Ltd. v. ACIT

Lasco Chemie Private Limited, Delhi vs. Income Tax Officer, Ward-15(2), New Delhi, Delhi

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

ITA 3811/DEL/2025[2012-13]Status: DisposedITAT Delhi08 Apr 2026AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarlasco Chemie Private Vs. Income Tax Officer, Limited, Ward-15(2), Delhi 10489 Kalptaru, Sadar Thana Road Motia Khan, New Delhi 110055 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcl 3502 E Appellant .. Respondent

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 147Section 148Section 149Section 151Section 250

…the hands of the assessee is a sine qua non for initiation of reassessment proceedings [refer ITO Lakhmani Mewal Day (1976) 103 ITR 437 (SC), Divya Capital One (P) Ltd. vs. ACIT [2022] 139 taxmann.com 461 (Del). Angelatoni Test Technologies SRL vs. ACIT [2024/463 ITR 139 (Del); Vasanthi Ramdas Pai vs. ITO [2024] 159 taxmann.com 392 (Kar). P a g e | 16 Lasco Chemie (P) Ltd. (AY 2012-13) 31. It is submitted that once the income from the disputed transactions stands disclosed and subjected to tax, the basic jurisdictional condition prescribed under section 147 of the Act stands unfulfilled. Re (d): Re-assessment i…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Rosha Alloys Pvt. Ltd., Mandi Gobindgarh

In the result, the appeals filed by the Revenue are dismissed,

ITA 923/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh28 May 2025AY 2020-21
Section 148BSection 151

…e a notice of re- assessment under Section 148A(b) but would certainly not vest it with the power to issue a re-assessment notice under Section 148 post an order under Section 148A(d). i) Similarly, in the case of Angelantoni Test Technologies SRL reported in 463 ITR 139 (Refer page no. 166 to 170 of case law index book), the Hon'ble Delhi High Court reiterated that under the amended reassessment regime, the existence of “information which suggests that income chargeable to tax has escaped assessment” remains the sine qua non for invoking jurisdiction under Section 147 of the Act. The Court emphasized that the th…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Rosha Alloys Pvt. Ltd., Mandi Gobindgarh

In the result, the appeals filed by the Revenue are dismissed,

ITA 922/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh28 May 2025AY 2019-20
Section 148BSection 151

…e a notice of re- assessment under Section 148A(b) but would certainly not vest it with the power to issue a re-assessment notice under Section 148 post an order under Section 148A(d). i) Similarly, in the case of Angelantoni Test Technologies SRL reported in 463 ITR 139 (Refer page no. 166 to 170 of case law index book), the Hon'ble Delhi High Court reiterated that under the amended reassessment regime, the existence of “information which suggests that income chargeable to tax has escaped assessment” remains the sine qua non for invoking jurisdiction under Section 147 of the Act. The Court emphasized that the th…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Rosha Alloys Pvt. Ltd., Mandi Gobindgarh

In the result, the appeals filed by the Revenue are dismissed,

ITA 921/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh28 May 2025AY 2018-19
Section 148BSection 151

…e a notice of re- assessment under Section 148A(b) but would certainly not vest it with the power to issue a re-assessment notice under Section 148 post an order under Section 148A(d). i) Similarly, in the case of Angelantoni Test Technologies SRL reported in 463 ITR 139 (Refer page no. 166 to 170 of case law index book), the Hon'ble Delhi High Court reiterated that under the amended reassessment regime, the existence of “information which suggests that income chargeable to tax has escaped assessment” remains the sine qua non for invoking jurisdiction under Section 147 of the Act. The Court emphasized that the th…

Rosha Alloys P Limited, Amloh Road, Village Turan, Mandi Gobindgarh, Punjab vs. DCIT Central Circle 1, Ludhiana, Punjab

In the result, the appeals filed by the Revenue are dismissed,

ITA 888/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh28 May 2025AY 2018-2019
Section 148BSection 151

…e a notice of re- assessment under Section 148A(b) but would certainly not vest it with the power to issue a re-assessment notice under Section 148 post an order under Section 148A(d). i) Similarly, in the case of Angelantoni Test Technologies SRL reported in 463 ITR 139 (Refer page no. 166 to 170 of case law index book), the Hon'ble Delhi High Court reiterated that under the amended reassessment regime, the existence of “information which suggests that income chargeable to tax has escaped assessment” remains the sine qua non for invoking jurisdiction under Section 147 of the Act. The Court emphasized that the th…

Mewal Day (1976) 103 ITR 437 (SC), Divya Capital One (P) Ltd. v. ACIT (463 ITR 139) — Cited in 5 Judgments | BharatTax