Narrondas Manordass v. Commissioner of Income-tax

31 ITR 909High Court1957#2980 most cited

What is Narrondas Manordass v. Commissioner of Income-tax authority for?

The Appellate Assistant Commissioner's (AAC) power to enhance an assessment is broad and not limited to the specific items of appeal, but it is restricted to income that was originally before the Income Tax Officer and cannot introduce entirely new sources of income.

40

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

Narrondas Manordass v. CIT · section 31(3) · Appellate Assistant Commissioner powers · enhancement of assessment · new sources of income · scope of appeal powers · Income Tax Act 1961

Sections most often in play

Section 143(3)Section 147Section 153ASection 263Section 115-OSection 115QSection 132Section 132(1)

Issues it is cited on

section 31(3)section 205section 36(l)(vii)section 9(1)(ii)section 36(2)(v)section 41(4)section 43b(f)section 211section 31section 245hasection 52section 36(l)

Judgments citing Narrondas Manordass v. Commissioner of Income-tax

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. SATYANARAYANA REDDY MANNE, HYDREABAD

ITA 472/HYD/2025[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA M.V. Prasad andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 153ASection 251(1)(a)

…e Supreme Court had also considered the Judgment of Hon'ble Madras High Court in the case of Sri Gajalakshmi Ginning Factory Ltd vs. CIT [1952] 22 ITR 502 (Madras) and the decision of Hon'ble Bombay High Court in the case of Narrondas Manordass vs. CIT [1957] 31 ITR 909 (Bom.) and in both the cases, it was held that, the power conferred upon the AAC is undoubtedly wider and is not restricted to the subject matter of the appeal. It was held that, though the appeal was confined in its subject-matter to a portion of the order, it would be open to the AAC to deal with the whole of the assessment order of the Income T…

SATYANARAYANA REDDY MANNE,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeal filed by the Assessee is allowed and appeal filed by the Revenue is dismissed

ITA 382/HYD/2025[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA M.V. Prasad and Shri K.S. Rajendra KumarFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 153ASection 251(1)(a)

…e Supreme Court had also considered the Judgment of Hon'ble Madras High Court in the case of Sri Gajalakshmi Ginning Factory Ltd vs. CIT [1952] 22 ITR 502 (Madras) and the decision of Hon'ble Bombay High Court in the case of Narrondas Manordass vs. CIT [1957] 31 ITR 909 (Bom.) and in both the cases, it was held that, the power conferred upon the AAC is undoubtedly wider and is not restricted to the subject matter of the appeal. It was held that, though the appeal was confined in its subject-matter to a portion of the order, it would be open to the AAC to deal with the whole of the assessment order of the Income T…

OCHHAB LAL JAIN,UDAIPUR vs. DCIT CENTRAL CIRCLE-1, UDAIPUR, UDAIPUR

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

ITA 429/JODH/2025[2016-17]Status: DisposedITAT Jodhpur29 May 2025AY 2016-17
Section 132Section 132(1)Section 132(4)Section 139(1)Section 143(3)Section 153ASection 69A

…y nugatory. The controversy in this case is about his discovering new sources, not mentioned in the return and not considered by the Income-tax Officer. The High Court held following its earlier view in NarrondasManordass vs. Commissioner of Income-tax [1957] 31 ITR 909, that the Appellate Assistant Commissioner has revisional powers, but that they are confined to what was before the Income-tax Officer and considered by the latter. The correctness of this view is challenged in this appeal by the Commissioner of Income-tax, Bombay. The earliest case, which considered the meaning of section 31(3), was JagarnathTher…

AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRLE, KOTA, KOTA

In the result, the appeal of the assessee is partly allowed

ITA 1277/JPR/2024[2015-16]Status: DisposedITAT Jaipur11 Apr 2025AY 2015-16
For Appellant: Shri Rajendra SisodiaFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 132Section 132(1)Section 132(4)Section 139Section 143(3)Section 153ASection 250

…xplained by the Hon'ble Supreme Court in a number of cases. In particular, the Hon'ble Supreme Court in the case of CIT v. McMillan & Co. [1958] 33 ITR 182, 193 has quoted, with approval, the observations of Justice Chagla in Narrondas Manordass v. CIT [1957] 31 ITR 909 (Bom.) as under:- x x x x The Hon'ble Punjab & Haryana High Court in the case of Dalmia Dadri Cement Ltd. v. CIT [1973] 90 ITR 297, after referring to the decision of Hon'ble Supreme Court in the case of McMillan & Co. (supra) held that if a mistake has been committed by the Assessing Officer in the Assessment order, which has been discovered by…

JCIT (OSD) CIRCLE-2, TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

In the result, appeal filed by the Revenue for assessment year

ITA 635/CHNY/2020[2017-18]Status: DisposedITAT Chennai20 Sept 2024AY 2017-18

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 620/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of Income M/S. Karur Vysya Bank, V. Tax, Finance &Control Dept., Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 635/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. Karur Vysya Bank, The Joint Commissioner Of V. Finance &Control Dept., Income Tax, Erode Road, Circle -2, Karur – 639 002. No.44, Williams Road, [Pan: Aaact-3373-J] Contanment, Trichy – 620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Ananthan, Ca & Smt. R. Lalitha, Ca Department By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 05.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 20.09.2024 आदेश /O R D E R Per S. R. Raghunatha:

For Appellant: Shri. Ananthan, CA & Smt. R. Lalitha, CAFor Respondent: Shri. Nilay Baran Som, CIT
Section 145Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(2)(v)

…ria's case (supra) still holds the feet. It may be noted that the issue was considered in CIT v. McMillan and Co. (1958) 33 ITR 182 (SC). Referring to a decision of the Bombay High Court in :-17-: ITA. Nos: 620 & 635/Chny/2020 Narondas Manordass v. CIT (1957) 31 ITR 909 (Bom), it was held that the language used in section 31 of the old Act is wide enough to enable the first appellate authority to correct the Income Tax Officer not only with regard to a matter which has been raised by the assessed but also with regard to a matter which has been considered by the assessing officer and determined in the course of th…

PARRY INFRASTRUCTURE CO P LTD. ,CHENNAI vs. DCIT CORPORATE CIRCLE 5(1) , CHENNAI

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

ITA 1653/CHNY/2019[2013-14]Status: DisposedITAT Chennai03 Jul 2024AY 2013-14

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri Philip George, AdvocateFor Respondent: Shri Nilay Baran Som, CIT-DR
Section 143(2)Section 143(3)Section 14A

…llonji Mistri [1962] 44 ITR 891, this court, while considering the extent of the power of the Appellate Assistant Commissioner, referred to a number of cases decided by various High Courts including the Bombay High Court judgment in Narrondas Manordass [1957] 31 ITR 909 and also the decision of this court in McMillan & Co. [1958] 33 ITR 182 and held that, in an appeal filed by the assessed, the AAC has no power to enhance the assessment by discovering new sources of income not considered by the Income Tax Officer in the order appealed against. It was urged on behalf of the revenue that the words 'enhance the asse…

M/S GANESH BUILDERS,PANCHKULA vs. DCIT, CC-1, CHANDIGARH

In the result, the respective appeals and stay applications are disposed off in light of aforesaid directions

ITA 452/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh16 May 2024AY 2012-13

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Rohit Sharma, CIT DR &
Section 132Section 153ASection 153CSection 153DSection 251Section 251(1)Section 271

…rom the point of taxability. It was pointed out that the AO has considered to apply rate of Rs. 7000/- in respect of only 54 plots. 11.10 The Ld. AR placed reliance upon the decision of Hon'ble Bombay High Court in the case of CIT vs Narrondas Manordas (Bom) 31 ITR 909, Hon'ble Delhi High Court in the case of CIT vs Gurinder Mohan Singh Nindrajog (2012J 348 ITR 170 (Del), Hon'ble Delhi High Court in the case of CIT vs Union Tyres (1999) 240 ITR 556 (Del), Hon'ble Delhi High Court in the case of CIT vs Sardari Lai and Co. [2001] 251 ITR 864 (Delhi) (FB) in his favour on the issue of powers of the CIT (A) to make…

M/S LUXMI BUILDERS,CHANDIGARH vs. DCIT, CHANDIGARH

In the result, the respective appeals and stay applications are disposed off in light of aforesaid directions

ITA 451/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh16 May 2024AY 2012-13

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Rohit Sharma, CIT DR &
Section 132Section 153ASection 153CSection 153DSection 251Section 251(1)Section 271

…rom the point of taxability. It was pointed out that the AO has considered to apply rate of Rs. 7000/- in respect of only 54 plots. 11.10 The Ld. AR placed reliance upon the decision of Hon'ble Bombay High Court in the case of CIT vs Narrondas Manordas (Bom) 31 ITR 909, Hon'ble Delhi High Court in the case of CIT vs Gurinder Mohan Singh Nindrajog (2012J 348 ITR 170 (Del), Hon'ble Delhi High Court in the case of CIT vs Union Tyres (1999) 240 ITR 556 (Del), Hon'ble Delhi High Court in the case of CIT vs Sardari Lai and Co. [2001] 251 ITR 864 (Delhi) (FB) in his favour on the issue of powers of the CIT (A) to make…

KARUR VYSYA BANK LTD.,KARUR vs. DCIT CIRCLE 2(1), TRICHY

ITA 678/CHNY/2019[2015-16]Status: DisposedITAT Chennai09 Apr 2024AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 677 & 678/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 M/S. Karur Vysya Bank Ltd, Deputy Commissioner Of Central Office, V. Income Tax, Erode Road, Circle -2(1), Karur – 639 002. Trichy. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita Nos.: 1343 & 1321/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 Deputy Commissioner Of M/S. Karur Vysya Bank Ltd, Income Tax, V. Central Office, Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Anandhan, Ca & Smt. Lalitha, Ca Revenue By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 13.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

For Appellant: Shri. Anandhan, CA and Smt. Lalitha, CAFor Respondent: Shri. Nilay Baran Som, CIT
Section 36(1)(viii)Section 41(1)Section 43B

…a) and RaiBahadurHardutroyMotilalChamaria's case (supra) still holds the feet. It may be noted that the issue was considered in CIT v. McMillan and Co. (1958) 33 ITR 182 (SC). Referring to a decision of the Bombay High Court in NarondasManordass v. CIT (1957) 31 ITR 909 (Bom), it was held that the language used in section 31 of the old Act is wide enough to enable the first appellate authority to correct the Income Tax Officer not only with regard to a matter which has been raised by the assessed but also with regard to a matter which has been considered by the assessing officer and determined in the course of th…

KARUR VYSYA BANK LTD.,KARUR vs. DCIT CIRCLE 2(1), TRICHY

ITA 677/CHNY/2019[2014-15]Status: DisposedITAT Chennai09 Apr 2024AY 2014-15

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 677 & 678/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 M/S. Karur Vysya Bank Ltd, Deputy Commissioner Of Central Office, V. Income Tax, Erode Road, Circle -2(1), Karur – 639 002. Trichy. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita Nos.: 1343 & 1321/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 Deputy Commissioner Of M/S. Karur Vysya Bank Ltd, Income Tax, V. Central Office, Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Anandhan, Ca & Smt. Lalitha, Ca Revenue By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 13.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

For Appellant: Shri. Anandhan, CA and Smt. Lalitha, CAFor Respondent: Shri. Nilay Baran Som, CIT
Section 36(1)(viii)Section 41(1)Section 43B

…a) and RaiBahadurHardutroyMotilalChamaria's case (supra) still holds the feet. It may be noted that the issue was considered in CIT v. McMillan and Co. (1958) 33 ITR 182 (SC). Referring to a decision of the Bombay High Court in NarondasManordass v. CIT (1957) 31 ITR 909 (Bom), it was held that the language used in section 31 of the old Act is wide enough to enable the first appellate authority to correct the Income Tax Officer not only with regard to a matter which has been raised by the assessed but also with regard to a matter which has been considered by the assessing officer and determined in the course of th…

DCIT CIRCLE 2(1), TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

ITA 1343/CHNY/2019[2014-15]Status: DisposedITAT Chennai09 Apr 2024AY 2014-15

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 677 & 678/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 M/S. Karur Vysya Bank Ltd, Deputy Commissioner Of Central Office, V. Income Tax, Erode Road, Circle -2(1), Karur – 639 002. Trichy. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita Nos.: 1343 & 1321/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 Deputy Commissioner Of M/S. Karur Vysya Bank Ltd, Income Tax, V. Central Office, Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Anandhan, Ca & Smt. Lalitha, Ca Revenue By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 13.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

For Appellant: Shri. Anandhan, CA and Smt. Lalitha, CAFor Respondent: Shri. Nilay Baran Som, CIT
Section 36(1)(viii)Section 41(1)Section 43B

…a) and RaiBahadurHardutroyMotilalChamaria's case (supra) still holds the feet. It may be noted that the issue was considered in CIT v. McMillan and Co. (1958) 33 ITR 182 (SC). Referring to a decision of the Bombay High Court in NarondasManordass v. CIT (1957) 31 ITR 909 (Bom), it was held that the language used in section 31 of the old Act is wide enough to enable the first appellate authority to correct the Income Tax Officer not only with regard to a matter which has been raised by the assessed but also with regard to a matter which has been considered by the assessing officer and determined in the course of th…

DCIT CIRCLE 2(1), TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

ITA 1321/CHNY/2019[2015-16]Status: DisposedITAT Chennai09 Apr 2024AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 677 & 678/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 M/S. Karur Vysya Bank Ltd, Deputy Commissioner Of Central Office, V. Income Tax, Erode Road, Circle -2(1), Karur – 639 002. Trichy. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita Nos.: 1343 & 1321/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 Deputy Commissioner Of M/S. Karur Vysya Bank Ltd, Income Tax, V. Central Office, Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Anandhan, Ca & Smt. Lalitha, Ca Revenue By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 13.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

For Appellant: Shri. Anandhan, CA and Smt. Lalitha, CAFor Respondent: Shri. Nilay Baran Som, CIT
Section 36(1)(viii)Section 41(1)Section 43B

…a) and RaiBahadurHardutroyMotilalChamaria's case (supra) still holds the feet. It may be noted that the issue was considered in CIT v. McMillan and Co. (1958) 33 ITR 182 (SC). Referring to a decision of the Bombay High Court in NarondasManordass v. CIT (1957) 31 ITR 909 (Bom), it was held that the language used in section 31 of the old Act is wide enough to enable the first appellate authority to correct the Income Tax Officer not only with regard to a matter which has been raised by the assessed but also with regard to a matter which has been considered by the assessing officer and determined in the course of th…

M/S ALPHA REALITY,CHENNAI vs. ACIT NON CORPORATE CIRCLE 3, CHENNAI

The appeal stands partly allowed in terms of our above order

ITA 1706/CHNY/2018[2014-15]Status: DisposedITAT Chennai01 Nov 2023AY 2014-15

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1706/Chny/2018 (िनधा"रण वष" / Assessment Year: 2014-15) M/S. Alpha Reality Acit No.1-A, 4Th Floor, Jhava Plaza, Non-Corporate Circle-3, बनाम/ Vs. Nungambakkam High Road, Chennai Nungambakkam, Chennai-600 034. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aajfa-8210-B (अपीलाथ"/Appellant) : (!"थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri N. Arjunraj (Ca)- Ld.Ar !"थ"कीओरसे/Respondent By : Shri P. Sajit Kumar (Jcit)-Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 01-11-2023 आदेश / O R D E R

For Appellant: Shri N. Arjunraj (CA)- Ld.ARFor Respondent: Shri P. Sajit Kumar (JCIT)-Ld. Sr. DR
Section 143(3)Section 68

…a) and Rai Bahadur Hardutroy Motilal Chamaria's case (supra) still holds feet. It may be noted that the issue was considered in CIT v. McMillan & Co. [1958] 33 ITR 182 (SC). Referring to a decision of the Bombay High Court in Narrondas Manordass v. CIT [1957] 31 ITR 909 , it was held that the language used in section 31 is wide enough to enable the first appellate authority to correct the ITO not only with regard to a matter which has been raised by the assessee but also with regard to a matter which has been considered by the Assessing Officer and determined in the course of assessment. It is also relevant to no…

I.T.O. vs. M/S KUMAR CONSTRUCLTION,

In the result, the appeal of the Revenue is partly allowed

ITA 10/PAT/2015[2009-10]Status: DisposedITAT Patna17 Oct 2023AY 2009-10

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 142(1)Section 143(2)Section 271(1)(b)Section 40A(3)

…A) in appellate proceedings, following observations of the Supreme Court in the case of Jute Corporation of India Limited Vs. CIT reported in 187 ITR 688 is relevant; the Bombay High Court considered the question in detail in Narrondas Manordass v. CIT [1957] 31 ITR 909 and held that the AAC was empowered to correct the ITO not only with regard to a matter which had been raised by the assessee but also with regard to a matter which may have been considered by the ITO and determined in the course of the assessment. The High Court observed that since the AAC had been the revising authority against the decisions of…

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

ITA 4973/DEL/2018[2009-10]Status: DisposedITAT Delhi08 Aug 2023AY 2009-10

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G.C. Srivastava, Adv
Section 143(3)Section 147Section 148

…y nugatory. The controversy in this case is about his discovering new sources, not mentioned in the return and not considered by the Income-tax Officer. The High Court held following its earlier view in Narrondas Manordass v. Commissioner of Income-tax [1195] 31 ITR 909, that the Appellate Assistant Commissioner has revisional powers, but that they are confined to what was before the Income-tax Officer and considered by the latter.” 24. Again, the Hon'ble Supreme Court in the case of Rai Bahadur Hardutroy Motilal Chamaria 66 ITR 443 had an occasion to adjudicate on similar grievance as under: “The AAC has no…

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

ITA 4972/DEL/2018[2011-12]Status: DisposedITAT Delhi08 Aug 2023AY 2011-12

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G.C. Srivastava, Adv
Section 143(3)Section 147Section 148

…y nugatory. The controversy in this case is about his discovering new sources, not mentioned in the return and not considered by the Income-tax Officer. The High Court held following its earlier view in Narrondas Manordass v. Commissioner of Income-tax [1195] 31 ITR 909, that the Appellate Assistant Commissioner has revisional powers, but that they are confined to what was before the Income-tax Officer and considered by the latter.” 24. Again, the Hon'ble Supreme Court in the case of Rai Bahadur Hardutroy Motilal Chamaria 66 ITR 443 had an occasion to adjudicate on similar grievance as under: “The AAC has no…

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

ITA 4971/DEL/2018[2010-11]Status: DisposedITAT Delhi08 Aug 2023AY 2010-11

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G.C. Srivastava, Adv
Section 143(3)Section 147Section 148

…y nugatory. The controversy in this case is about his discovering new sources, not mentioned in the return and not considered by the Income-tax Officer. The High Court held following its earlier view in Narrondas Manordass v. Commissioner of Income-tax [1195] 31 ITR 909, that the Appellate Assistant Commissioner has revisional powers, but that they are confined to what was before the Income-tax Officer and considered by the latter.” 24. Again, the Hon'ble Supreme Court in the case of Rai Bahadur Hardutroy Motilal Chamaria 66 ITR 443 had an occasion to adjudicate on similar grievance as under: “The AAC has no…

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

ITA 4970/DEL/2018[2008-09]Status: DisposedITAT Delhi08 Aug 2023AY 2008-09

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G.C. Srivastava, Adv
Section 143(3)Section 147Section 148

…y nugatory. The controversy in this case is about his discovering new sources, not mentioned in the return and not considered by the Income-tax Officer. The High Court held following its earlier view in Narrondas Manordass v. Commissioner of Income-tax [1195] 31 ITR 909, that the Appellate Assistant Commissioner has revisional powers, but that they are confined to what was before the Income-tax Officer and considered by the latter.” 24. Again, the Hon'ble Supreme Court in the case of Rai Bahadur Hardutroy Motilal Chamaria 66 ITR 443 had an occasion to adjudicate on similar grievance as under: “The AAC has no…

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

ITA 4969/DEL/2018[2007-08]Status: DisposedITAT Delhi08 Aug 2023AY 2007-08

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G.C. Srivastava, Adv
Section 143(3)Section 147Section 148

…y nugatory. The controversy in this case is about his discovering new sources, not mentioned in the return and not considered by the Income-tax Officer. The High Court held following its earlier view in Narrondas Manordass v. Commissioner of Income-tax [1195] 31 ITR 909, that the Appellate Assistant Commissioner has revisional powers, but that they are confined to what was before the Income-tax Officer and considered by the latter.” 24. Again, the Hon'ble Supreme Court in the case of Rai Bahadur Hardutroy Motilal Chamaria 66 ITR 443 had an occasion to adjudicate on similar grievance as under: “The AAC has no…

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

ITA 4968/DEL/2018[2006-07]Status: DisposedITAT Delhi08 Aug 2023AY 2006-07

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G.C. Srivastava, Adv
Section 143(3)Section 147Section 148

…y nugatory. The controversy in this case is about his discovering new sources, not mentioned in the return and not considered by the Income-tax Officer. The High Court held following its earlier view in Narrondas Manordass v. Commissioner of Income-tax [1195] 31 ITR 909, that the Appellate Assistant Commissioner has revisional powers, but that they are confined to what was before the Income-tax Officer and considered by the latter.” 24. Again, the Hon'ble Supreme Court in the case of Rai Bahadur Hardutroy Motilal Chamaria 66 ITR 443 had an occasion to adjudicate on similar grievance as under: “The AAC has no…

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