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 367,154 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

Issues it is cited on

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

DCIT, CC-VIII, Kolkata vs. M/S Elar Securities Pvt Ltd., Kolkata

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 832/KOL/2014[2010-2011]Status: DisposedITAT Kolkata11 Jan 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2010-11 Dcit, Central Circle- V/S. M/S Ascent Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaafca 3896 G] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Panchmukhi Properties Viii, Room No. 403, Pvt. Ltd., 71 Park Street, 4Th Floor, Aayakar Kolakta-16 Bhawan, Poorva, 110, [Pan No.Aadcp 0770 C] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Braggart Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaccb 7030 Q] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11

…judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." These observations were made in a case where taxation was in issue. This court in Parashuram Pottery Works Co.Ltd. v. ITO [1077] 106 ITR 1 at p.10 stated : “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that, stale issues should not be reactivate beyond particular stage and that lapse of time must be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest j…

DCIT, CC-VIII, Kolkata vs. M/S Tapasya Finvest Pvt. Ltd., Kolkata

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 831/KOL/2014[2010-2011]Status: DisposedITAT Kolkata11 Jan 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2010-11 Dcit, Central Circle- V/S. M/S Ascent Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaafca 3896 G] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Panchmukhi Properties Viii, Room No. 403, Pvt. Ltd., 71 Park Street, 4Th Floor, Aayakar Kolakta-16 Bhawan, Poorva, 110, [Pan No.Aadcp 0770 C] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Braggart Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaccb 7030 Q] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11

…judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." These observations were made in a case where taxation was in issue. This court in Parashuram Pottery Works Co.Ltd. v. ITO [1077] 106 ITR 1 at p.10 stated : “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that, stale issues should not be reactivate beyond particular stage and that lapse of time must be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest j…

DCIT, CC-VIII, Kolkata vs. M/S Brilliant Vyapaar Pvt. Ltd., Kolkata

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 828/KOL/2014[2010-2011]Status: DisposedITAT Kolkata11 Jan 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2010-11 Dcit, Central Circle- V/S. M/S Ascent Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaafca 3896 G] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Panchmukhi Properties Viii, Room No. 403, Pvt. Ltd., 71 Park Street, 4Th Floor, Aayakar Kolakta-16 Bhawan, Poorva, 110, [Pan No.Aadcp 0770 C] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Braggart Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaccb 7030 Q] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11

…judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." These observations were made in a case where taxation was in issue. This court in Parashuram Pottery Works Co.Ltd. v. ITO [1077] 106 ITR 1 at p.10 stated : “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that, stale issues should not be reactivate beyond particular stage and that lapse of time must be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest j…

DCIT, CC-VIII, Kolkata vs. M/S Piyush Mercantile Pvt. Ltd., Kolkata

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 827/KOL/2014[2010-2011]Status: DisposedITAT Kolkata11 Jan 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2010-11 Dcit, Central Circle- V/S. M/S Ascent Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaafca 3896 G] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Panchmukhi Properties Viii, Room No. 403, Pvt. Ltd., 71 Park Street, 4Th Floor, Aayakar Kolakta-16 Bhawan, Poorva, 110, [Pan No.Aadcp 0770 C] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Braggart Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaccb 7030 Q] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11

…judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." These observations were made in a case where taxation was in issue. This court in Parashuram Pottery Works Co.Ltd. v. ITO [1077] 106 ITR 1 at p.10 stated : “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that, stale issues should not be reactivate beyond particular stage and that lapse of time must be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest j…

DCIT, CC-VIII, Kolkata vs. M/S Rajrishabh Finance & Investment, Kolkata

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 826/KOL/2014[2010-2011]Status: DisposedITAT Kolkata11 Jan 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2010-11 Dcit, Central Circle- V/S. M/S Ascent Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaafca 3896 G] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Panchmukhi Properties Viii, Room No. 403, Pvt. Ltd., 71 Park Street, 4Th Floor, Aayakar Kolakta-16 Bhawan, Poorva, 110, [Pan No.Aadcp 0770 C] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Braggart Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaccb 7030 Q] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11

…judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." These observations were made in a case where taxation was in issue. This court in Parashuram Pottery Works Co.Ltd. v. ITO [1077] 106 ITR 1 at p.10 stated : “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that, stale issues should not be reactivate beyond particular stage and that lapse of time must be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest j…

DCIT, CC-VIII, Kolkata vs. M/S Bpo Finance & Investment Pvt Ltd., Kolkata

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 822/KOL/2014[2010-2011]Status: DisposedITAT Kolkata11 Jan 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2010-11 Dcit, Central Circle- V/S. M/S Ascent Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaafca 3896 G] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Panchmukhi Properties Viii, Room No. 403, Pvt. Ltd., 71 Park Street, 4Th Floor, Aayakar Kolakta-16 Bhawan, Poorva, 110, [Pan No.Aadcp 0770 C] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Braggart Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaccb 7030 Q] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11

…judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." These observations were made in a case where taxation was in issue. This court in Parashuram Pottery Works Co.Ltd. v. ITO [1077] 106 ITR 1 at p.10 stated : “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that, stale issues should not be reactivate beyond particular stage and that lapse of time must be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest j…

DCIT, CC-VIII, Kolkata vs. M/S Braggart Vyapaar Pvt Ltd., Kolkata

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 818/KOL/2014[2010-2011]Status: DisposedITAT Kolkata11 Jan 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2010-11 Dcit, Central Circle- V/S. M/S Ascent Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaafca 3896 G] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Panchmukhi Properties Viii, Room No. 403, Pvt. Ltd., 71 Park Street, 4Th Floor, Aayakar Kolakta-16 Bhawan, Poorva, 110, [Pan No.Aadcp 0770 C] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Braggart Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaccb 7030 Q] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11

…judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." These observations were made in a case where taxation was in issue. This court in Parashuram Pottery Works Co.Ltd. v. ITO [1077] 106 ITR 1 at p.10 stated : “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that, stale issues should not be reactivate beyond particular stage and that lapse of time must be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest j…

DCIT, CC-VIII, Kolkata vs. M/S Panchmukhi Properties Pvt. Ltd., Kolkata

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 816/KOL/2014[2010-2011]Status: DisposedITAT Kolkata11 Jan 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2010-11 Dcit, Central Circle- V/S. M/S Ascent Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaafca 3896 G] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Panchmukhi Properties Viii, Room No. 403, Pvt. Ltd., 71 Park Street, 4Th Floor, Aayakar Kolakta-16 Bhawan, Poorva, 110, [Pan No.Aadcp 0770 C] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Braggart Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaccb 7030 Q] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11

…judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." These observations were made in a case where taxation was in issue. This court in Parashuram Pottery Works Co.Ltd. v. ITO [1077] 106 ITR 1 at p.10 stated : “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that, stale issues should not be reactivate beyond particular stage and that lapse of time must be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest j…

DCIT, CC-VIII, Kolkata vs. M/S Ascent Vyapaar Pvt. Ltd., Kolkata

In the result, Revenue’s appeal is allowed for statistical purpose

ITA 814/KOL/2014[2010-2011]Status: DisposedITAT Kolkata11 Jan 2018AY 2010-2011

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2010-11 Dcit, Central Circle- V/S. M/S Ascent Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaafca 3896 G] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Panchmukhi Properties Viii, Room No. 403, Pvt. Ltd., 71 Park Street, 4Th Floor, Aayakar Kolakta-16 Bhawan, Poorva, 110, [Pan No.Aadcp 0770 C] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11 Dcit, Central Circle- V/S. M/S Braggart Vyapaar Pvt. Viii, Room No. 403, Ltd., 33/1 N.S. Road, 4Th Floor, Aayakar Kolakta-001 Bhawan, Poorva, 110, [Pan No.Aaccb 7030 Q] Shanti Pally, E.M.Bye- Pass, Kolkata-107 .. अपीलाथ" /Appellant ""यथ"/Respondent Assessment Year: 2010-11

…judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." These observations were made in a case where taxation was in issue. This court in Parashuram Pottery Works Co.Ltd. v. ITO [1077] 106 ITR 1 at p.10 stated : “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that, stale issues should not be reactivate beyond particular stage and that lapse of time must be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest j…