How many judgments cite Parashuram Pottery Works Co. Ltd. v. ITO?

486 judgments on BharatTax cite Parashuram Pottery Works Co. Ltd. v. ITO (106 ITR 1), spanning 1991 to 2026.

Which sections of the Income Tax Act does Parashuram Pottery Works Co. Ltd. v. ITO come up under?

It is most often cited in judgments turning on Section 143(3), Section 147, Section 148, Section 263, Section 142(1), Section 151.

Parashuram Pottery Works Co. Ltd. v. ITO

106 ITR 1Supreme Court of India1977#143 most cited

What is Parashuram Pottery Works Co. Ltd. v. ITO authority for?

The principle of finality dictates that stale issues should not be reactivated, and lapse of time brings repose to judicial and quasi-judicial controversies. A Commissioner cannot substitute their judgment for the Assessing Officer's unless the assessment order is legally erroneous, not merely less elaborate, thus limiting revisionary powers under Section 263.

486

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 1991 to 2026.

Also referred to as

Parashuram Pottery Works Co. Ltd. v. ITO · Parashuram Pottery · Section 263 · erroneous order · revision power · substitution of Commissioner's judgment · finality of assessment · stale issues · judicial precedent · 106 ITR 1

Sections most often in play

Section 143(3)Section 147 Section 148 Section 263 Section 142(1)Section 151 Section 69C Section 68

Read the full judgment

Issues it is cited on

section 10(31a)section 100 section 76 section 142(2c)section 153b(1)(b)section 150(1)section 153b(1)rectification under section 154 section 144ba section 33(4)section 206c section 158bc

Judgments citing Parashuram Pottery Works Co. Ltd. v. ITO

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

…fully and truly disclosed by the assessees. 44. The Apex Court while dwelling on the scope of the requirement to disclose fully and truly all material facts as comprehended in the proviso to section 147 held in Parashuram Pottery Works Co. Ltd. v. ITO [1977] 106 ITR 1 (SC), that the duty of the assessee in any case does not extend beyond making a true and full disclosure of primary facts and it is not its responsibility to advise the Assessing Officer with regard to the inference which he should draw therefrom. If such officer draws any inference which appears to be subsequently erroneous, a mere change of opini…

M/S. Om Prakash Badaya (HUF), Jaipur vs. Pr.CIT, Alwar

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

ITA 217/JPR/2020[2015-16]Status: DisposedITAT Jaipur13 Nov 2020AY 2015-16

For Appellant: Shri Manish Agrawal (AR)For Respondent: Shri A.S. Nehra (ACIT-DR)

Section 10(38)Section 143(3)Section 263

…n inserting Explanation 2 to sec. 263 of the Act, since it would lead to unending litigations and there would not be any point of finality in the legal proceedings. The Hon’ble Supreme Court has held in the case Parashuram Pottery Works Co. Ltd Vs. ITO (1977)(106 ITR 1) that there must be a point of finality in all legal proceedings and the stale issues should not be reactivated beyond a particular stage and the lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity. 20. Further clause (a) of Explanation states that an order shal…

Shri Mohd. Ilyas Ansari, Mumbai vs. Income Tax Officer 23(2)(3), Mumbai

In the result, appeal of the assessee is allowed as indicated above

ITA 6174/MUM/2017[2014-15]Status: DisposedITAT Mumbai06 Nov 2020AY 2014-15

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleshri Mohd. Ilyas Ansari V. Income Tax Officer - 23(2)(3) Room No. 22, 1St Floor Room No. 110 Building No. 41, Bootwala Manzil Matru Mandir, Tardev Road Navpada, Bandra(E) Mumbai – 400 007 Mumbai - 400051 Pan: Aexpa7459N (Appellant) (Respondent)

For Appellant: Shri Hariom TulsyanFor Respondent: Ms. Kavita P. Kaushik

Section 56(2)Section 56(2)(vii)Section 56(2)(viib)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B”, MUMBAI (THROUGH VIRTUAL COURT) BEFORE SHRI C.N. PRASAD, HON'BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER Shri Mohd. Ilyas Ansari v. Income Tax Officer - 23(2)(3) Room No. 22, 1st Floor Room No. 110 Building No. 41, Bootwala Manzil Matru Mandir, Tardev Road Navpada, Bandra(E) Mumbai – 400 007 Mumbai - 400051 PAN: AEXPA7459N (Appellant) (Respondent) Assessee by : Shri Hariom Tulsyan Department by : Ms. Kavita P. Kaushik Date of Hearing : 21.10.2020 Date of Pronouncement : 06.11.2020 O R D E R PER C.N. PRASAD (JM) 1. This appeal is…

M/S Mbl Infrastructures Ltd., Kolkata vs. DCIT, Central Circle-2(2), Kolkata

Appeal is allowed

ITA 427/KOL/2018[2012-13]Status: DisposedITAT Kolkata22 Oct 2020AY 2012-13

Bench: Shri P. M. Jagtap, V.P & Shri S. S. Godara, Jm आयकर अपीलसं./I.T.A No.427/Kol/2018 ("नधा"रण वष" / Assessment Year: 2012-13) M/S. Mbl Infrastructure Ltd. Vs Dcit, Central Circle-2(2), Kolkata . 1St Floor, Divine Bliss, 2/3, Judges Court Road, Kolkata – 700027. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccm0564C (Appellant) .. (Respondent) Appellant By : Shri S. K. Tulsiyan, Advocate Respondent By : Shri Ram Bilash Meena, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 06/10/2020 घोषणाक"तार"ख/Date Of Pronouncement : 22/10/2020

For Appellant: Shri S. K. Tulsiyan, AdvocateFor Respondent: Shri Ram Bilash Meena, CIT(DR)

Section 143(3)Section 14ASection 263Section 35DSection 80Section 80I

…sues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity. (See Parashuram Pottery Works Co. Ltd. v. ITO [1977] 106 ITR 1 (SC) at page 10) . . . From the aforesaid definitions it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income- tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him, the order should have…

DCIT, Circle- 8(1), New Delhi vs. Ebix Software India Pvt. Ltd., New Delhi

ITA 5274/DEL/2017[2013-14]Status: DisposedITAT Delhi30 Sept 2020AY 2013-14

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms Nidhi Srivastava, CIT, DR

Section 10ASection 115J

…plaintiff and traversable by the defendant, has not been traversed. In that case also a defendant is bound by the judgment, although it may be true enough that taken." 30. Reference was also made to Parashuram Pottery Works Ltd. v. Income Tax Officer, [1977] 106 ITR 1 (SC) and then it was held: "We are aware of the fact that strictly speaking res judicata does not apply to income-tax proceedings. Again, each assessment year being a unit, what is decided in one year may not apply in the following year but where a fundamental aspect permeating through the different assessment years has been found as a fact one way…

M/S. Guru Kripa Career Institute Pvt. Ltd., Sikar vs. Pr.CIT-3, Jaipur

In the result, appeal of the assessee is allowed

ITA 283/JPR/2020[2015-16]Status: DisposedITAT Jaipur01 Sept 2020AY 2015-16

For Appellant: Shri S.R. Sharma &For Respondent: Shri B.K. Gupta (CIT-DR)

Section 115BSection 133ASection 143(3)Section 263Section 40A(3)Section 68

…ting Explanation 2 to section 263 of the Act. Such interpretation would lead to unending litigations and there would not be any point of finality in the legal proceedings. The Hon’ble Supreme Court in the case of Parshuram Pottery Works Co. Ltd. Vs ITO (1977) 106 ITR 1 held there must be point of finality in all legal proceedings. In our considered view, this provision shall apply if the order has been passed without making enquiries or verification which a reasonable and prudent officer should have carried out in such 15 ITA 283/JP/2020_ M/s Guru Kripa Career Institute P Ltd. Vs PCIT cases. Under these facts and…

The Commissioner of Income Tax vs. M/S Rajmahal Silks

The appeal is disposed of

ITA/81/2011HC Karnataka01 Sept 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 132Section 143(2)Section 143(3)Section 153ASection 260Section 260ASection 37(1)Section 40Section 40A(3)Section 40a

…t at rest judicial and quasi judicial controversies as it must in other spheres of human activity. In this connection, reliance has been placed on decision of the Supreme Court in ‘PARASHURAM POTTERY WORKS CO. LTD., VS. INCOME-TAX OFFICER’, (1977) 106 ITR 1 (SC). 7. We have considered the submissions made by learned counsel on both the sides and have perused the record. Before proceeding further, we may advert to the well settled legal principles. It is trite law that Income Tax Appellate Tribunal is the fact finding authority and it should normally record its conclusion on every disputed qu…

Johnson & Johnson Ltd, Mumbai vs. Addl CIT Large Taxpayer Unit, Mumbai

In the result, the appeal of the assessee is allowed in the terms aforesaid

ITA 4912/MUM/2013[2004-05]Status: DisposedITAT Mumbai10 Aug 2020AY 2004-05

Bench: Shri Vikas Awasthy & Shri Manoj Kumar Aggarwalआअसं. 4912/मुं/2013 ("न.व.2004-05) Johnson & Johnson Private Limited (Earlier Known As Johnson & Johnson Limited) 501, Arena Space, Off Jvlr, Behind Majas Bus Depot, Jogeshwari (East) Mumbai 400 060 Pan: Aaacj0866E ...... अपीलाथ" /Appellant बनाम Vs. Additional Commissioner Of Income Tax, Large Taxpayer Unit, 29Th Floor, Centre No.1, World Trade Centre, Cuffe Parade, Mumbai 400 005 ..... ""तवाद"/Respondent

For Appellant: Shri Rajan VoraFor Respondent: Shri Akhtar H. Ansari

Section 143(3)Section 147Section 148Section 234B

…ollowing decisions: (1) Tao Publishing (P) Ltd. vs. Dy. CIT, 370 ITR 135 (Bom.) (2) Hindustan Lever Ltd. vs. R.B. Wadkar, 268 ITR 332 (Bom.) (3) Akshar Anshul Construction LLP vs. Asstt. CIT, 264 Taxman 65 (Bom.) (4) Parashuram Pottery Works Co. Ltd. vs. ITO, 106 ITR 1(SC) 3.2. The third argument of ld. Authorized Representative of the assesse against reopening is that the Assessing Officer while taking permission from the CIT for issuing notice under section 148 of the Act has expressed his opinion that the case is time barred and hence, cannot be reopened again. However, the CIT in a mechanical manner vide com…

Padam Kumae Jain, Ranchi vs. CIT, Central, Patna

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

ITA 289/RAN/2019[2012-13]Status: DisposedITAT Ranchi08 Jul 2020AY 2012-13

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am आयकरअपीलसं./Ita No.289/Ran/2019 (िनधा"रणवष" / Assessment Year: 2012-13) Padam Kumar Jain Vs. Cit, Central, Cr Building, Beer Chand Patel Marg, Patna – 800001. Ratanlalsurajmal Compound, Main Road, Ranchi – 834001, Jharkhand "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abrpj 0001 E (Assessee) .. (Revenue)

For Appellant: Shri M.K. Chaudhury & Shri Devesh Poddar, AdvocateFor Respondent: Shri Inderjeet Singh, CIT (DR)

Section 132(4)Section 143(3)Section 153ASection 263

…ime must induce repose in and set at rest judicial and quasi-judicial controversies as it is must in other spheres of human activity. For that we rely on the judgment of the Hon'ble Supreme Court in the case of Parashuram Pottery Works Co. Ltd. vs. ITO (1977) 106 ITR 1 (SC), wherein it was held as follows: "It has been said that the taxes are the price that we pay for civilization. If so, it is essential that those who are entrusted with the task of calculating and realizing that price should familiarize themselves with the relevant provisions and become well-versed with the law on the subject. Any remissness on…

Gaursons Sportswood Pvt Ltd, New Delhi vs. ITO Ward-11(3), New Delhi

Accordingly direct the Assessing Officer to delete the addition of Rs.17,32,78,878/-. The appeal is accordingly allowed

ITA 9017/DEL/2019[2014-15]Status: DisposedITAT Delhi30 Jun 2020AY 2014-15

Bench: Ms. Sushma Chowla, Vice– & Shri N. K. Billaiyaassessment Year: 2014-15 M/S Gaursons Sportswood Income Tax Officer, Private Limited, Vs. Ward : 11 (3), D–25, Vivek Vihar, New Delhi New Delhi – 110 095. Pan : Aaacx0984F (Appellant) (Respondent)

For Appellant: Shri S. Krishnan, AdvFor Respondent: Ms. Sunita Singh [CIT]–DR

…case also a defendant is bound by the judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." 30. Reference was also made to Parashuram Pottery Works Ltd. v. Income Tax Officer, [1977] 106 ITR 1 (SC) and then it was held: "We are aware of the fact that strictly speaking res judicata does not apply to income-tax proceedings. Again, each assessment year being a unit, what is decided in one year may not apply in the following year but where a fundamental aspect permeating through the different assessment years has been found as a fact one way…

Gouri Shankar Goyal, Siliguri vs. I.T.O.Ward-1(3), Siliguri

In the result, the appeal of the assessee is allowed

ITA 517/KOL/2019[2014-15]Status: DisposedITAT Kolkata12 Jun 2020AY 2014-15

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.517/Kol/2019 (निर्धारणवर्ा / Assessment Year:2014-15) Gouri Shankar Goyal Vs. Pcit, Siliguri

For Appellant: Shri Subash Agarwal, A.RFor Respondent: Shri Dhrubajyoti Roy, JCIT

Section 143(3)Section 263

…nserting Explanation 2 to sec. 263 of the Act, since it would lead to unending litigations and there would not be any point of finality in the legal proceedings. The Hon’ble Supreme Court has held in the case of Parashuram Pottery Works Co. Ltd Vs. ITO (1977)(106 ITR 1) that there must be a point of finality in all legal proceedings and the stale issues should not be reactivitated beyond a particular stage and the lapse of time must induce repose in and set at rest judicial and quasi- judicial controversies as it must in other spheres of human activity. 20. Further clause (a) of Explanation states that an order s…

M/S. Bhandari Hospital and Research Centre, Indore vs. The Pr. CIT-1, Indore

ITA 355/IND/2017[2012-13]Status: DisposedITAT Indore20 Mar 2020AY 2012-13

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2012-13 M/S Bhandari Hospital & Pr. Cit-(I) Research Centre, Gf-21 & Indore बनाम/ 22, Opp. Meghdoot Garden, Vs. Vijay Nagar, Indore (Appellant) (Revenue ) P.A. No.Aadfb8151A

Section 131(1)(d)Section 143(3)Section 144ASection 263Section 35A

…nserting Explanation 2 to sec. 263 of the Act, since it would lead to unending litigations and there would not be any point of finality in the legal proceedings. The Hon’ble Supreme Court has held in the case of Parashuram Pottery Works Co. Ltd Vs. ITO (1977)(106 ITR 1) that there must be a point of finality in all legal proceedings and the stale issues should not be reactivated beyond a particular stage and the lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity. 20. Further clause (a) of Explanation states that an order shal…

Afcons Infrastructure Ltd, Mumbai vs. Pr.CIT 9, Mumbai

The appeal stands allowed to the extent indicated in the order

ITA 3159/MUM/2019[2014-15]Status: DisposedITAT Mumbai17 Mar 2020AY 2014-15

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ I.T.A. No.3159/Mum/2019 (िनधा"रण वष" / Assessment Year:2014-15) Afcons Infrastructure Limited Pr. Cit-9 16, Afcons House Room No.214, Aaykar Bhavan बनाम/ 2Nd Floor, M.K. Road Shah Industrial Estate Vs. Veera Desai Road, Andheri West Mumbai. Mumbai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaca-9067-G (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ" की ओर से/ Appellant By : S/Shri J.D. Mistry & Nitesh Joshi-Ld. Ars ""थ"कीओरसे/Respondent By : Shri Anadi Varma-Ld.Cit-Dr सुनवाईकीतारीख/ : 05/09/2019 & 19/12/2019 Date Of Hearing घोषणाकीतारीख / : 17/03/2020 Date Of Pronouncement आदेश / O R D E R

For Appellant: S/Shri J.D. Mistry & Nitesh Joshi-Ld. ArsFor Respondent: Shri Anadi Varma-Ld.CIT-DR

Section 263

…issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity [Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. It was further observed as under: - "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to hi…

Sleek International, Mumbai vs. Asst CIT 32(3), Mumbai

The appeal stands allowed in terms of our above order

ITA 3327/MUM/2019[2014-15]Status: DisposedITAT Mumbai25 Feb 2020AY 2014-15

Bench: Hon’Ble Shri C.N. Prasad, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: S/Shri Vijay Mehta & Govind Jhaveri-For Respondent: Shri Sushil Kumar Poddar - Ld.CIT-DR

Section 263

…issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi- judicial controversies as it must in other spheres of human activity [Parashuram Pottery Works Co. Ltd. vs. ITO, (1977) 106 ITR 1 (SC)]. 5 M/s. Sleek International Assessment Year :2014-15 It was further observed as under: - "From the aforesaid definitions as it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous…

Deep Multiplex Pvt. Ltd., Baroda vs. DCIT, Circle 1(1) (1), Baroda

In the results, appeal of the assessee is allowed

ITA 1719/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad12 Feb 2020AY 2012-13

Bench: Shri Rajpal Yadav, Vice-आयकर अपील सं./ Ita.No.1719/Ahd/2017 "नधा"रण वष"/ Asstt. Year: 2012-13 Deep Muliplex P.Ltd. Dcit, Cir.1(1)(4) 9, Arunoday Society Baroda. Vs 2, Mangaljyot Apartment Alkapuri Baroda Pan : Aabck 4719 Q अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri M.K. Patel, Ar Revenue By : Shri Dilip Kumar, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 03/02/2020 घोषणा क" तार"ख /Date Of Pronouncement: 12/02/2020 आदेश/O R D E R

For Appellant: Shri M.K. Patel, ARFor Respondent: Shri Dilip Kumar, Sr.DR

Section 249Section 253Section 3Section 5

…defendant is bound by the judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." ITA No.1719 /Ahd/2017 11 30. Reference was also made to Parashuram Pottery Works Ltd. v. ITO [1977] 106 ITR 1 (SC) and then it was held: "We are aware of the fact that strictly speaking res judicata does not apply to income-tax proceedings. Again, each assessment year being a unit, what is decided in one year may not apply in the following year but where a fundamental aspect permeating through the different assessment years has been found as a fact one way…

Seth Madan Lal Palriwala Foundation, New Delhi vs. CIT(Exemption), New Delhi

ITA 4670/DEL/2019[2014-15]Status: DisposedITAT Delhi31 Jan 2020AY 2014-15

Bench: Shri R.K. Panda & Shri Kuldip Singh

For Appellant: Dr. Shashwat Bajpai, AdvocateFor Respondent: Shri S.S. Rana, CIT DR

Section 143(3)Section 263

…sues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity. (See Parashuram Pottery Works Co. Ltd. v. ITO [1977] 106 ITR 1 (SC) at page 10) . . . From the aforesaid definitions it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him, the order should have…

Dena Bank, Mumbai vs. Principal Commissioner of Income Tax 2, Mumbai

In the result, appeal filed by the assesse is allowed

ITA 2159/MUM/2018[2014-15]Status: DisposedITAT Mumbai23 Jan 2020AY 2014-15

Bench: Shri G. Manjunatha & Shri Ravish Sooddena Bank Vs. Pcit-2 Room No.344, 3Rd Floor Accounts Department Dena Bank Building Aaykar Bhawan 2Nd Floor M.K.Road 17/B, Horniman Circle Mumbai-400 020 Fort, Mumbai-400 023 Pan/Gir No.Aaacd4249B Appellant) .. Respondent)

Section 115Section 143(3)Section 263Section 36(1)(vii)Section 36(1)(viia)Section 43B

…n. It is an important decision and the same cannot be based on the whims or caprice of the revising authority. There must be materials available from records called for by the Commissioner.-- Parashuram Pottery Works Co. Ltd, vs. [TO 1977 CTR (SC) 32 : (1977) 106 ITR 1 (SC), Sirpur Paper Mills Ltd, vs. ITQ 1977 CTR (AP) 138 : (1978) 114 ITR 404 (AP), Dawjee Dadabhov & Co. vs. S.P. Jain & Anr. (1957) 31 ITR 872 (Cal) and Russell Properties 1M. Ltd, vs. A. Chowdhury, Addl. CIT (1977) 109 ITR 229 (Cal) relied on ." 13. The assesse also relied upon the decision of Hon'ble Delhi High Court in the case of CIT vs Sunbe…

Asian Homes P.Ltd, Mumbai vs. Principal Commissioner of Income Tax- 9, Mumbai

The appeal stands allowed in terms of our above order

ITA 2593/MUM/2018[2013-14]Status: DisposedITAT Mumbai03 Jan 2020AY 2013-14

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am

For Appellant: S/Shri Paras Nath &For Respondent: Shri Anadi Varma-Ld.CIT-DR

Section 143(3)Section 263Section 56

Anand Lilaram Raisinghani, Mumbai vs. Pr. CIT - 16, Mumbai

In the result, the appeal stands partly allowed to the extent specified in the order

ITA 3385/MUM/2019[2014-15]Status: DisposedITAT Mumbai02 Jan 2020AY 2014-15

Bench: Hon’Ble Shri Vikas Awasthy, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri Anadi Varma - Ld. CIT-DR

Section 143(3)Section 2(22)(e)Section 263Section 43B

Coast Line Shipping (India) Pvt. Ltd., Mumbai vs. DCIT, CC- 5(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 4943/MUM/2018[2015-16]Status: DisposedITAT Mumbai30 Dec 2019AY 2015-16

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Ble

For Appellant: Shri Ravi SawanaFor Respondent: Shri Kumar Padmapani Bora

Section 271(1)(c)Section 274

…nvalid and void in the eyes of law. Also contentions were raised stating that section 292B was inapplicable. The Hon’ble Delhi High Court held as under: “21. Our attention was drawn to Parashuram Pottery Works Co. Ltd. V. ITO, Circle I, Ward A, Rajkot, (1977) 106 ITR 1 (SC) which records that the Assessing Officer entrusted with the task of calculating and realizing tax should familiarize themselves with the relevant provisions and become well versed with the law on the subject. This is a salutary advice. Indeed, there have been lapses and faults resulting in the present litigation. Notice under Section 147/148 o…