How many judgments cite Narayanappa v. CIT?

187 judgments on BharatTax cite Narayanappa v. CIT (63 ITR 219), spanning 2010 to 2026.

Which sections of the Income Tax Act does Narayanappa v. CIT come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 151, Section 250, Section 143(1).

Narayanappa v. CIT

63 ITR 219Supreme Court of India1967#503 most cited

What is Narayanappa v. CIT authority for?

The approval required from a higher authority under section 153D of the Income Tax Act is an administrative act, not a quasi-judicial one. Consequently, an opportunity of hearing is not required to be given to the assessee at the stage of obtaining such approval, provided the approving authority is competent.

187

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2010 to 2026.

Also referred to as

Narayanappa v. CIT · 63 ITR 219 · section 153D · administrative act · quasi-judicial act · approval from higher authority · opportunity of hearing · JCIT approval · judicial scrutiny · search assessment

Sections most often in play

Section 147 Section 148 Section 143(3)Section 151 Section 250 Section 143(1)Section 153A Section 153D

Read the full judgment

Issues it is cited on

section 114(e)section 43(3)section 147(a)section 151(1)section 158bb kelvinator section 153b within four years section 158bc section 151(2)live link section 158bg

Judgments citing Narayanappa v. CIT

DCIT, Circle-1(Exemption), Chandigarh vs. M/S Manav Mangal School( Manav Mangal Society), Chandigarh

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 27/CHANDI/2020[2013-14]Status: DisposedITAT Chandigarh27 May 2021AY 2013-14

For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR

Section 13(3)

…bove judgment, the Hon'ble Rajasthan High Court has relied on the following celebrated judgments:- i). CIT Vs Kelvinator of India Ltd. [2010] 320 ITR 561 (SC) ii). Calcutta Discount Co. Ltd. vs. ITO [1961) 41 ITR 191 (SC). iii). S. Narayanappa Vs CIT[1967] 63 ITR 219 (SC) iv). ITO Vs Lakhmani Mewal Dass [1976] 103 ITR 437 (SC) v). S. Ganga Saran and Sons P. Ltd. Vs ITO [1981] 130 ITR 1(SC) vi). Sri Krishna P. Ltd. V. ITO [1996] 221 ITR 538 (SC). b). The Hon'ble Delhi High Court in the case of Director of Income Tax Vs. Rolls Royce Industrial Power India Ltd. has held as under: 8. That in case proceedings…

M/S Manav Mangal Society, Chandigarh vs. DCIT, C-1, (E), Chandigarh

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 2/CHANDI/2020[2010-11]Status: DisposedITAT Chandigarh27 May 2021AY 2010-11

For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR

Section 13(3)

DCIT, C-1, (E), Chandigarh vs. M/S Manav Mangal Society, Chandigarh

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 137/CHANDI/2020[2011-12]Status: DisposedITAT Chandigarh27 May 2021AY 2011-12

For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR

Section 13(3)

DCIT, C-1, (E), Chandigarh vs. M/S Manav Mangal Society, Chandigarh

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 136/CHANDI/2020[2010-11]Status: DisposedITAT Chandigarh27 May 2021AY 2010-11

For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR

Section 13(3)

ACIT Cir. 12(1)(2), Mumbai vs. Bharti Axa Life Insurance Company Ltd., Mumbai

In the result, the appeal of the revenue is dismissed and cross objection of the assessee is allowed

ITA 2930/MUM/2019[2007-08]Status: DisposedITAT Mumbai31 Mar 2021AY 2007-08

Section 143(3)Section 147Section 149Section 151

…form the basis of re-opening Assessment and its reasons which would evidence the linkage/nexus to the conclusion that income chargeable to tax has escaped Assessment. This is a settled position as observed by the Supreme Court in S. Narayanappa v. CIT [1967] 63 ITR 219, that it is open to examine whether the reason to believe has rational connection with the formation of the belief. To the same effect, the Apex Court in ITO v. LakhmaniMerwal Das [1976] 103 ITR 437 had laid down that the reasons to believe must have rational connection with or relevant bearing on the formation of belief i.e. there must be a live…

Space Chem Engineers Private Limited, Ghaziabad vs. ITO Ward-2(3), Ghaziabad

In the result the appeal filed by the assessee is allowed

ITA 1791/DEL/2019[2008-09]Status: DisposedITAT Delhi18 Mar 2021AY 2008-09

Bench: Shri R.K. Pandaasstt. Year 2008-09

For Appellant: Shri Akhilesh Kumar, AdvocateFor Respondent: Shri Sanjiv Mahajan, Sr. DR

Section 142(1)Section 147Section 148Section 271(1)(b)Section 68

…moters Pvt Ltd. and Micro Land Developers Pvt. Ltd. The above companies were also owned by Shri Surendra Kumar Jain and Shri Virendra Kumar Jain and AO has rightly placed reliance on the decision of Hon'ble Supreme Court in the case of S S. Narayanappa vs CIT 63 ITR 219 (SC) to hold that the proceedings initiated u/s 147 are valid. The appellant placed reliance on Hon'ble Supreme Court in the case of CIT vs Kelvinator of India 312Taxman 187 wherein Hon'ble Apex Court laid down the law that AO should have information in his possession for reasons to believe that income chargeable to tax has escaped assessment and…

Late Shri Ganpat Singh, L/H Bikram Singh, Rewari vs. ITO, Ward-1, Rewari

ITA 2880/DEL/2019[2009-10]Status: DisposedITAT Delhi03 Mar 2021AY 2009-10

Bench: Shri R.K. Pandaasstt. Year 2009-10

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri Frat Khan,Sr. DR

Section 142(1)Section 143(2)Section 147Section 148Section 68

…e where the AO has written in the reasons recorded that he suspects or he has to investigate the cash deposits. Thus the case laws cited by assessee does not come to his rescue and is not squarely applicable in his case. In the case of S, Narayanappa vs. CIT 63 ITR 219 Hon'ble Supereme Court has 4.4 held that “The sufficiency of the grounds which induced the ITO to act is not a justifiable issue. It is of course open for the assessee to contend that the ITO did not hold the belief that there had been 5 such non-disclosure. In other words, the existence of the belief can be challenged by the assessee but not the…

Addl. CIT, New Delhi vs. M/S. Ircon International Ltd., New Delhi

In the result, the appeal of the Revenue is accordingly dismissed

ITA 3768/DEL/2017[2009-10]Status: DisposedITAT Delhi22 Jan 2021AY 2009-10

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

Section 143(3)Section 148

…ons to believe" is stronger than the expression "is satisfied". Belief entertained by the AO should not be irrational and arbitrary. To put it differently, it must be reasonable and must be based on reasons which are material. In S. Narayanappa vs. CIT (1967) 63 ITR 219 (SC) : TC 51R.651 it was noted by the apex Court that expression "reasons to believe" in s. 147 does not mean purely a subjective satisfaction on the part of the AO, belief must be held in good faith; it cannot be merely a pretence. It is open to the Court to examine whether reasons for the belief have a rational nexus or a relevant bearing to the…

ACIT, Central Circle - 4(3), Kolkata vs. M/S. Grd Commodities Ltd., Kolkata

In the result, the appeals of the Revenue are dismissed and the cross objections of assessee are allowed

ITA 2277/KOL/2018[2014-15]Status: DisposedITAT Kolkata04 Dec 2020AY 2014-15

Bench: Shri P.M. Jagtap(Kz) &Shri A. T. Varkey, Jm] It(Ss)A Nos.120 To123/Kol/2018 Assessment Years: 2009-10 To 2012-13

Section 132Section 133ASection 143Section 143(3)Section 147Section 148Section 153A

…s stronger than the expression "is satisfied". The belief entertained by the Assessing Officer should not be irrational and arbitrary. To put it differently, it must be reasonable and must be based on reasons which are material. In S.Narayanappa v. CIT [1967] 63 ITR 219, it was noted by the apex court that the expression "reason to believe" in section 147 does not mean purely a subjective satisfaction on the part of the Assessing Officer, the belief must be held in good faith ; it cannot be merely a pretence. It is open to the court to examine whether the reasons for the belief have a rational nexus or a relevant…

DCIT, Central Circle - 1(1), Kolkata vs. M/S. Alembic Merchants Pvt. Ltd., Kolkata

In the result, the appeal of revenue fails

ITA 1826/KOL/2018[2009-10]Status: DisposedITAT Kolkata20 Nov 2020AY 2009-10

Bench: Hon’Ble Shri J.Sudhakar Reddy, Am & Hon’Ble Shri A. T. Varkey, Jm Assessment Year: 2009-10 Dcit, Central Cir-1(1), Kolkata Vs. M/S. Alembic Merchants Pvt. Ltd Pan: Aacca 0918Q Appellant Respondent

Section 142(1)Section 147Section 148Section 153(2)Section 68

…form the basis of re-opening . Assessment and its reasons which would evidence the linkage/nexus to the conclusion that income chargeable to tax has escaped Assessment This is a settled position as observed by the Supreme Court In S. Narayanappa v. CIT [1967] 63 ITR 219, that it is open to examine whether the reason to believe has rational connection with the formation of the belief. To the same effect, the Apex Court in ITO v. LakhmaniMerwal Das [1976] 103 ITR 437 had laid down that the reasons to believe must have rational connection with or relevant bearing on the formation of belief 20 A.Y 2009-10 M/s. Alemb…