Modi Xerox Ltd. v. DCIT

Commissioner of Income Tax vs. Xerox Modicorp Limited

Appeals are dismissed

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MS. JUSTICE REVA KHETRAPAL

…here is no doubt in our mind that assessment proceedings have been initiated on the basis of mere change of opinion. On same facts, ITA No. 1274 of 2007 & Others Page 14 of 22 ITAT, Delhi Bench in the case of Modi Xerox Ltd., Vs. DCIT, 67 ITD 252, for the assessment years 1991-92 and 1992-93, where the CIT revised the order u/s 263 had held that the CIT assumed the jurisdiction on the basis of change of opinion. Further, on same facts, ITAT Delhi Bench in the case of the assessee considered this issue for the A.Y. 1991-92 (supra) where the order of CIT(A) was upheld on the ground t…

Commissioner of Income Tax vs. Xerox Modicorp Limited

Appeals are dismissed

…an 95, Duli Chand Singhania, 269 ITR 192. Now in the present case, there is no doubt in our mind that assessment proceedings have been initiated on the basis of mere change of opinion. On same facts, ITAT, Delhi Bench in the case of Modi Xerox Ltd., Vs. DCIT, 67 ITD 252, for the assessment years 1991-92  and 1992-93, where the CIT revised the order u/s 263 had held that the CIT assumed the jurisdiction on the basis of change of opinion. Further, on same facts, ITAT Delhi Bench in the case of the assessee considered this issue for the A.Y. 1991-92 (supra) where the order of CIT(A) was…

Commissioner of Income Tax Central I vs. Xerox Modicorp Ltd

Appeals are dismissed

…an 95, Duli Chand Singhania, 269 ITR 192. Now in the present case, there is no doubt in our mind that assessment proceedings have been initiated on the basis of mere change of opinion. On same facts, ITAT, Delhi Bench in the case of Modi Xerox Ltd., Vs. DCIT, 67 ITD 252, for the assessment years 1991-92  and 1992-93, where the CIT revised the order u/s 263 had held that the CIT assumed the jurisdiction on the basis of change of opinion. Further, on same facts, ITAT Delhi Bench in the case of the assessee considered this issue for the A.Y. 1991-92 (supra) where the order of CIT(A) was…

Commissioner of Income Tax vs. Xerox Modicorp Limited

Appeals are dismissed

…269 ITR 192. Now in the present case, there is no doubt in our mind that assessment proceedings have been initiated on the basis of mere change of opinion. On same facts, 2010:DHC:4533-DB ITAT, Delhi Bench in the case of Modi Xerox Ltd., Vs. DCIT, 67 ITD 252, for the assessment years 1991-92 and 1992-93, where the CIT revised the order u/s 263 had held that the CIT assumed the jurisdiction on the basis of change of opinion. Further, on same facts, ITAT Delhi Bench in the case of the assessee considered this issue for the A.Y. 1991-92 (supra) where the order of CIT(A) was upheld on the ground t…