N.D. Bhatt, IAC v. I.B.M. World Trade Corpn

216 ITR 811High Court1995#4541 most cited

What is N.D. Bhatt, IAC v. I.B.M. World Trade Corpn authority for?

Reasons for reopening a case under Section 148 must be recorded by the assessing authority before issuing the notice. Only these recorded reasons can be used to validate or invalidate the notice.

26

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

N.D. Bhatt · IAC v. I.B.M. World Trade Corpn · Section 148 · Section 148(2) · reasons for reopening · notice under section 148 · recorded reasons · arbitrary exercise of powers

Sections most often in play

Section 147Section 148Section 68Section 151Section 133ASection 143(3)Section 153CSection 132(4)

Issues it is cited on

books or books of accountsection 2(12a)section 2(40)section 92esection 148(2)section 55(2)section 139(9)section 49approval under section 151dumb documentsfresh tangible materialsection 55

Judgments citing N.D. Bhatt, IAC v. I.B.M. World Trade Corpn

KOGOD BASAVARAJU JAYACHANDRA ,HASSAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result the ITA No

ITA 1618/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 May 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh, CAFor Respondent: Shri.Shivanand Kalakeri, CIT(DR)(ITAT), Bangalore
Section 132(4)Section 133(6)Section 133ASection 143(3)Section 147Section 148Section 151Section 153CSection 234A

…of that requirement ensures against an arbitrary exercise of powers under s. 148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom): "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under s. 148 by virtue of the provisions of s. 148(2) at the relevant time. Only the reasons so recorded can be looked at for sustaining or setting aside a notice issued under s. 148. In the case of Equit…

KOGOD BASAVARAJU JAYACHANDRA ,HASSAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

ITA 1617/BANG/2024[2015-16]Status: DisposedITAT Bangalore26 May 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

Section 132(4)Section 133(6)Section 133ASection 143(3)Section 147Section 148Section 151Section 153CSection 234A

…n of that requirement ensures against an arbitrary exercise of powers under s.148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom):…

SMT. NISHITA NANDISH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

ITA 1616/BANG/2024[2017-18]Status: DisposedITAT Bangalore23 May 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh, CAFor Respondent: Shri.Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 132(4)Section 133(6)Section 133ASection 147Section 148Section 151Section 153CSection 234A

…of that requirement ensures against an arbitrary exercise of powers under s. 148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom): "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under s. 148 by virtue of the provisions of s. 148(2) at the relevant time. Only the reasons so recorded can be looked at for sustaining or setting aside a notice issued under s. 148. In the case of Equit…

SMT. NISHITA NANDISH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

ITA 1615/BANG/2024[2016-17]Status: DisposedITAT Bangalore23 May 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh, CAFor Respondent: Shri.Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 132(4)Section 133(6)Section 133ASection 147Section 148Section 151Section 153CSection 234A

…of that requirement ensures against an arbitrary exercise of powers under s. 148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom): "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under s. 148 by virtue of the provisions of s. 148(2) at the relevant time. Only the reasons so recorded can be looked at for sustaining or setting aside a notice issued under s. 148. In the case of Equit…

SMT. NISHITA NANDISH ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

ITA 1614/BANG/2024[2015-16]Status: DisposedITAT Bangalore23 May 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh, CAFor Respondent: Shri.Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 132(4)Section 133(6)Section 133ASection 147Section 148Section 151Section 153CSection 234A

…of that requirement ensures against an arbitrary exercise of powers under s. 148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom): "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under s. 148 by virtue of the provisions of s. 148(2) at the relevant time. Only the reasons so recorded can be looked at for sustaining or setting aside a notice issued under s. 148. In the case of Equit…

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

ITA 1658/BANG/2024[2017-18]Status: DisposedITAT Bangalore22 May 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 132(4)Section 133(6)Section 133ASection 147Section 148Section 151Section 153CSection 234A

…of that requirement ensures against an arbitrary exercise of powers under s. 148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom): "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under s. 148 by virtue of the provisions of s. 148(2) at the relevant time. Only the reasons so recorded can be looked at for sustaining or setting aside a notice issued under s. 148. In the case of Equit…

HUNGRY AND FOOLISH INTELLECTUAL PROPERTIES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BENGALURU

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

ITA 1575/BANG/2024[2015-16]Status: DisposedITAT Bangalore24 Mar 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri C. Ramesh, CAFor Respondent: Ms. Neha Sahay, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 147Section 148Section 151Section 153CSection 37Section 68

…of that requirement ensures against an arbitrary exercise of powers under s. 148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom): "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under s. 148 by virtue of the provisions of s. 148(2) at the relevant time. Only the reasons so recorded can be looked at for sustaining or setting aside a notice issued under s. 148. In the case of Equit…

HUNGRY AND FOOLISH INTELLECTUAL PROPERTIES PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BENGALURU

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

ITA 1573/BANG/2024[2013-14]Status: DisposedITAT Bangalore24 Mar 2025AY 2013-14

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri C. Ramesh, CAFor Respondent: Ms. Neha Sahay, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 147Section 148Section 151Section 153CSection 37Section 68

…of that requirement ensures against an arbitrary exercise of powers under s. 148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom): "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under s. 148 by virtue of the provisions of s. 148(2) at the relevant time. Only the reasons so recorded can be looked at for sustaining or setting aside a notice issued under s. 148. In the case of Equit…

N 9 SPORTS & LEISURE HOLDINGS PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1(2), BENGALURU

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

ITA 1570/BANG/2024[2015-16]Status: DisposedITAT Bangalore24 Mar 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri C. Ramesh, CAFor Respondent: Ms. Neha Sahay, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 147Section 148Section 151Section 153CSection 37Section 68

…of that requirement ensures against an arbitrary exercise of powers under s. 148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom): "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under s. 148 by virtue of the provisions of s. 148(2) at the relevant time. Only the reasons so recorded can be looked at for sustaining or setting aside a notice issued under s. 148. In the case of Equit…

N 9 SPORTS & LEISURE HOLDINGS PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

ITA 1568/BANG/2024[2013-14]Status: DisposedITAT Bangalore24 Mar 2025AY 2013-14

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri C. Ramesh, CAFor Respondent: Ms. Neha Sahay, Jt.CIT(DR)(ITAT), Bengaluru
Section 131Section 132(4)Section 147Section 148Section 151Section 153CSection 37Section 68

…of that requirement ensures against an arbitrary exercise of powers under s. 148. 10. A Division Bench of this Court speaking through Mrs. Justice Sujata Manohar (as the learned Judge then was) held thus in N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom): "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under s. 148 by virtue of the provisions of s. 148(2) at the relevant time. Only the reasons so recorded can be looked at for sustaining or setting aside a notice issued under s. 148. In the case of Equit…

RAKESH MULCHAND KOTHARI,MUMBAI vs. INCOME TAX OFFICER, WD-26(2)(5), MUMBAI

ITA 6598/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Feb 2025AY 2015-16
Section 131Section 139(4)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 68

…ent ensures against\nan arbitrary exercise of powers under section 148.\n\n10. A Division Bench of this Court speaking through Mrs. Justice\nSujata Manohar (as the learned Judge then was) held thus\nin N.D.\nBhatt,\nIAC v. I.B.M.\nWorld Trading\nCorpn. [1995] 216 ITR 811\n\"It is also well-settled that the reasons for reopening\nare required to be recorded by the assessing authority\nbefore issuing any notice under section 148 by virtue of\nthe provisions of section 148(2) at the relevant time.\nOnly the reasons so recorded can be looked at for\nsustaining or setting aside a notice issued under section\n148. In t…

WINSOME TEXTILE INDUSTRIES LIMITED,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 528/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh27 Feb 2025AY 2011-12

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Ved Parkash Kalia Sr. DR
Section 115JSection 143(1)Section 143(3)Section 147Section 148

…h are supposed to sustain the formation of an opinion, is challengeable. The reasons to believe are required to be recorded by the Assessing Officer. 16. In this regard, it is apt to reproduce a passage from N.D. Bhatt, IAC v. I.B.M. World Trade Corpn. [1995] 216 ITR 811 (Bom.) :— "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under section 148 by virtue of the provisions of section 148(2) at the relevant time. Only the reason so recorded can be looked at for sustaining or setting aside a notice issued under section 148. In…

ACIT, CENTRAL CRCLE-18, NEW DELHI vs. SHIMMER DEVELOPERS P.LTD, NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 1497/DEL/2018[2011-12]Status: DisposedITAT Delhi21 Oct 2024AY 2011-12

Bench: Pradip Kumar Kedia & Shri Anubhav Sharma

Section 132Section 143(3)Section 147Section 150Section 68

…ich are supposed to sustain the formation of an opinion, is challengeable. The reasons to believe are required to he recorded by the Assessing Officer. In this regard, it is apt to reproduce a passage from N.D. Bhatt, IAC v. 16. IB.M. World Trade Corpn [1995] 216 ITR 811 (Bom.) "It is also well-settled that the reasons for reopening are required to be recorded by the assessing authority before issuing any notice under section 148 by virtue of the provisions of section 148(2) at the relevant time. Only the reason so recorded can be looked at for sustaining or setting aside a notice issued under section 148. In the…

MESERS SHREE BHAGWATI COTTON TRADERS,BATHINDA vs. INCOME TAX OFFICER,WARD 1 (2), BATHINDA

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

ITA 480/ASR/2018[2009-10]Status: DisposedITAT Amritsar13 Oct 2022AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 250(6)Section 68

…n held that reasons should be discernible from the material record in the following cases: (iii) CIT vs Sfil Stock Broking Ltd. [2010] 325 ITR 285 (Delhi) (iv) Prashant S. Joshi vs ITO [2010] 324 ITR 154 (Bom) (v) ACIT vs. I.B.M World Trade Corporation [1995] 216 ITR 811 (Bom) (vi) Hindustan Lever Ltd. vs RB Wadekar [2004] 137 Taxman 479 (BOM.) 6.3. In the present case, nothing is discernible to form the reasons as recorded by the AO, since how can self-withdrawals by the third party from his regular account be treated as reason to believe and further payment of Rs. 17.80 has been made towards purchases and that…

INCOME TAX OFFICER,WARD 1 (2), BATHINDA vs. MESERS SHREE BHAGWATI COTTON TRADERS ,, BATHINDA

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

ITA 479/ASR/2018[2009-10]Status: DisposedITAT Amritsar13 Oct 2022AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 250(6)Section 68

…n held that reasons should be discernible from the material record in the following cases: (iii) CIT vs Sfil Stock Broking Ltd. [2010] 325 ITR 285 (Delhi) (iv) Prashant S. Joshi vs ITO [2010] 324 ITR 154 (Bom) (v) ACIT vs. I.B.M World Trade Corporation [1995] 216 ITR 811 (Bom) (vi) Hindustan Lever Ltd. vs RB Wadekar [2004] 137 Taxman 479 (BOM.) 6.3. In the present case, nothing is discernible to form the reasons as recorded by the AO, since how can self-withdrawals by the third party from his regular account be treated as reason to believe and further payment of Rs. 17.80 has been made towards purchases and that…

ACIT, JAMMU vs. SH VIKRAMADITYA SINGH, JAMMU

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

ITA 269/ASR/2007[1998-99]Status: DisposedITAT Delhi24 Jan 2022AY 1998-99

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri C.S. Aggarwal, SrFor Respondent: Shri S.D. Kapila, Spl
Section 139(9)Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “D” : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER ITA Nos.263/ASR/2003 Assessment Year 1998-99 ACIT, Shri M.K. Ajat Shatru, Circle-II, vs The Palace, Jammu Jammu. Assessment Year 1998-99 ACIT, Dr. Karan Singh, Circle-II, vs. The Palace, Jammu Jammu. CO NO.43/ASR/2007 Arising out of ITA No.267/ASR/2007 - Assessment Year 1998-99 Dr. Karan Singh, ACIT, The Palace, vs. Circle-II, Jammu Jammu Assessment Year 1998-99 ACIT, Yashorajya Lakshmi Circle-II, Dr. Karan Singh, Legal Heir of Jammu vs. Smt. Yashorajya Laks…

ACIT, CIR-II, JAMMU vs. SMT. YASHORAJYA LAXMI, JAMMU

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

ITA 268/ASR/2007[1998-99]Status: DisposedITAT Delhi24 Jan 2022AY 1998-99

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri C.S. Aggarwal, SrFor Respondent: Shri S.D. Kapila, Spl
Section 139(9)Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “D” : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER ITA Nos.263/ASR/2003 Assessment Year 1998-99 ACIT, Shri M.K. Ajat Shatru, Circle-II, vs The Palace, Jammu Jammu. Assessment Year 1998-99 ACIT, Dr. Karan Singh, Circle-II, vs. The Palace, Jammu Jammu. CO NO.43/ASR/2007 Arising out of ITA No.267/ASR/2007 - Assessment Year 1998-99 Dr. Karan Singh, ACIT, The Palace, vs. Circle-II, Jammu Jammu Assessment Year 1998-99 ACIT, Yashorajya Lakshmi Circle-II, Dr. Karan Singh, Legal Heir of Jammu vs. Smt. Yashorajya Laks…

ACIT, JAMMU vs. DR KARAN SINGH, JAMMU

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

ITA 267/ASR/2007[1998-99\u005cu005cu005cu005cu005cu005cu005cu005c]Status: DisposedITAT Delhi24 Jan 2022

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri C.S. Aggarwal, SrFor Respondent: Shri S.D. Kapila, Spl
Section 139(9)Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “D” : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER ITA Nos.263/ASR/2003 Assessment Year 1998-99 ACIT, Shri M.K. Ajat Shatru, Circle-II, vs The Palace, Jammu Jammu. Assessment Year 1998-99 ACIT, Dr. Karan Singh, Circle-II, vs. The Palace, Jammu Jammu. CO NO.43/ASR/2007 Arising out of ITA No.267/ASR/2007 - Assessment Year 1998-99 Dr. Karan Singh, ACIT, The Palace, vs. Circle-II, Jammu Jammu Assessment Year 1998-99 ACIT, Yashorajya Lakshmi Circle-II, Dr. Karan Singh, Legal Heir of Jammu vs. Smt. Yashorajya Laks…

ACIT, JAMMU vs. SH M.K. AJAT SHATRU, JAMMU

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

ITA 263/ASR/2003[1998-99]Status: DisposedITAT Delhi24 Jan 2022AY 1998-99

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri C.S. Aggarwal, SrFor Respondent: Shri S.D. Kapila, Spl
Section 139(9)Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “D” : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER ITA Nos.263/ASR/2003 Assessment Year 1998-99 ACIT, Shri M.K. Ajat Shatru, Circle-II, vs The Palace, Jammu Jammu. Assessment Year 1998-99 ACIT, Dr. Karan Singh, Circle-II, vs. The Palace, Jammu Jammu. CO NO.43/ASR/2007 Arising out of ITA No.267/ASR/2007 - Assessment Year 1998-99 Dr. Karan Singh, ACIT, The Palace, vs. Circle-II, Jammu Jammu Assessment Year 1998-99 ACIT, Yashorajya Lakshmi Circle-II, Dr. Karan Singh, Legal Heir of Jammu vs. Smt. Yashorajya Laks…

M/S NAVODAYA GRAMA VIKAS CHARITABLE TRUST ,MANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS) CIRCLE-1 , MANGALORE

In the result, both the appeals of the assessee are allowed

ITA 553/BANG/2018[2014-15]Status: DisposedITAT Bangalore16 Oct 2020AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri V.Srinivasan, AdvocateFor Respondent: Smt. R. Premi, JCIT (D.R)
Section 11Section 12ASection 13(1)(c)Section 13(2)Section 143Section 143(3)Section 147Section 148Section 151

…ded must either stand or fall on the reasons as recorded alone and nothing else. Reliance is placed on the decisions of Jamanalal Kabra reported in 69 ITR 461 (All.), Equitable investment Vs. CIT reported in 174 ITR 714 (Cal) and N.D. Bhat VS. IBM reported in 216 ITR 811 (Bom). In the case of Hindustan Lever Limited V.R.B. Wadkar vs. Assistant Commissioner of Income Tax, 268 ITR 332, the Bombay High Court in its decision at page 338 it has been held that: “It is needless to mention that the reasons are required to be read as they were recorded by the Assessing Officer. No substitution or deletion is permissible.…

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