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

Sections most often in play

Section 143(3)Section 147Section 148Section 263Section 142(1)Section 151Section 69CSection 68
Read the full judgment

Issues it is cited on

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

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

M/S the Kasaragod Toddy Tappers and Shop Workers Co-Op Society Ltd, Kasargod vs. ITO Ward 1, Kasargod

In the result, the appeals by the assessee are dismissed as not maintainable

ITA 909/COCH/2022[2011-12]Status: DisposedITAT Cochin30 Jun 2023AY 2011-12

Bench: Shri Sanjay Arora & Shri Aby T.Varkey

For Appellant: Shri Arun Raj S., AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 143(3)Section 147Section 260A(2)(a)Section 5

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Sanjay Arora, Accountant Member and Shri Aby T.Varkey, Judicial Member ITA Nos. 908& 909/Coch/2022 (Assessment Years: 2010-11& 2011-12) Kasaragod Tody Tappers and The Income Tax Officer Shop Workers Co-opeative Ward -1, Kasargod Society Ltd. vs. Munnad P.O., Kasargod 671541 [PAN:AABAK4028Q] (Appellant) (Respondent) Appellant by: Shri Arun Raj S., Advocate Respondent by: Smt. J.M. Jamuna Devi, Sr. DR Date of Hearing: 15.05.2023 Date of Pronouncement: 30.06.2023 O R D E R Per Sanjay Arora, AM This is a set of two Appeals by the assessee c…

M/S the Kasaragod Toddy Tappers and Shop Workers Co-Op Society Ltd, Kasargod vs. ITO Ward -1, Kasargod

In the result, the appeals by the assessee are dismissed as not maintainable

ITA 908/COCH/2022[2010-11]Status: DisposedITAT Cochin30 Jun 2023AY 2010-11

Bench: Shri Sanjay Arora & Shri Aby T.Varkey

For Appellant: Shri Arun Raj S., AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 143(3)Section 147Section 260A(2)(a)Section 5

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Sanjay Arora, Accountant Member and Shri Aby T.Varkey, Judicial Member ITA Nos. 908& 909/Coch/2022 (Assessment Years: 2010-11& 2011-12) Kasaragod Tody Tappers and The Income Tax Officer Shop Workers Co-opeative Ward -1, Kasargod Society Ltd. vs. Munnad P.O., Kasargod 671541 [PAN:AABAK4028Q] (Appellant) (Respondent) Appellant by: Shri Arun Raj S., Advocate Respondent by: Smt. J.M. Jamuna Devi, Sr. DR Date of Hearing: 15.05.2023 Date of Pronouncement: 30.06.2023 O R D E R Per Sanjay Arora, AM This is a set of two Appeals by the assessee c…

Gandevi Taluka Khedut Sahakari Sangh Ltd., Na vs. Arivs.Income Tax Officer Ward-2, Navsari

In the result, appeal filed by the assessee in ITA No

ITA 138/SRT/2023[2008-09]Status: DisposedITAT Surat26 Jun 2023AY 2008-09

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

For Appellant: Shri Vinod Kumar, Sr. DRFor Respondent: Shri Suresh K. Kabra, CA
Section 143(3)Section 234BSection 251(1)(a)Section 80P(2)(A)Section 80P(2)(a)Section 80P(2)(c)

…lled “the justice of the common law. The above proposition was held by Lord Morris of Borth-y-Gest, Wisemjan v. Borneman 45 TC 540, 554 (HL), [1970] 75 ITR 652, 657. 12. The Hon'ble Supreme Court in the case of Parashuram Pottery Works Co. Ltd. vs. ITO (1977) 106 ITR 1 (SC) observed that there should be finality in the legal proceedings. The relevant observation of the Hon`ble Court is reproduced below: "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…

Gandevi Taluka Khedut Sahakari Sangh Ltd., Na vs. Arivs.Income Tax Officer Ward-2, Navsari

In the result, appeal filed by the assessee in ITA No

ITA 137/SRT/2023[2007-08]Status: DisposedITAT Surat26 Jun 2023AY 2007-08

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

For Appellant: Shri Vinod Kumar, Sr. DRFor Respondent: Shri Suresh K. Kabra, CA
Section 143(3)Section 234BSection 251(1)(a)Section 80P(2)(A)Section 80P(2)(a)Section 80P(2)(c)

…lled “the justice of the common law. The above proposition was held by Lord Morris of Borth-y-Gest, Wisemjan v. Borneman 45 TC 540, 554 (HL), [1970] 75 ITR 652, 657. 12. The Hon'ble Supreme Court in the case of Parashuram Pottery Works Co. Ltd. vs. ITO (1977) 106 ITR 1 (SC) observed that there should be finality in the legal proceedings. The relevant observation of the Hon`ble Court is reproduced below: "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…

Assistant Commissioner of Income Tax, Na vs. Arivs.Gandevi Taluka Khedut Sahakari Sangh Ltd., Navsari

In the result, appeal filed by the assessee in ITA No

ITA 130/SRT/2023[2008-09]Status: DisposedITAT Surat26 Jun 2023AY 2008-09

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

For Appellant: Shri Vinod Kumar, Sr. DRFor Respondent: Shri Suresh K. Kabra, CA
Section 143(3)Section 234BSection 251(1)(a)Section 80P(2)(A)Section 80P(2)(a)Section 80P(2)(c)

…lled “the justice of the common law. The above proposition was held by Lord Morris of Borth-y-Gest, Wisemjan v. Borneman 45 TC 540, 554 (HL), [1970] 75 ITR 652, 657. 12. The Hon'ble Supreme Court in the case of Parashuram Pottery Works Co. Ltd. vs. ITO (1977) 106 ITR 1 (SC) observed that there should be finality in the legal proceedings. The relevant observation of the Hon`ble Court is reproduced below: "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…

Assistant Commissioner of Income Tax, Na vs. Arivs.Gandevi Taluka Khedut Sahakari Sangh Ltd., Navsari

In the result, appeal filed by the assessee in ITA No

ITA 129/SRT/2023[2007-08]Status: DisposedITAT Surat26 Jun 2023AY 2007-08

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

For Appellant: Shri Vinod Kumar, Sr. DRFor Respondent: Shri Suresh K. Kabra, CA
Section 143(3)Section 234BSection 251(1)(a)Section 80P(2)(A)Section 80P(2)(a)Section 80P(2)(c)

…lled “the justice of the common law. The above proposition was held by Lord Morris of Borth-y-Gest, Wisemjan v. Borneman 45 TC 540, 554 (HL), [1970] 75 ITR 652, 657. 12. The Hon'ble Supreme Court in the case of Parashuram Pottery Works Co. Ltd. vs. ITO (1977) 106 ITR 1 (SC) observed that there should be finality in the legal proceedings. The relevant observation of the Hon`ble Court is reproduced below: "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…

Rajkumar Impex Private Limited, Chennai vs. PCIT - 4, Chenai

The appeal stand allowed in terms of our above order

ITA 631/CHNY/2022[2017-2018]Status: DisposedITAT Chennai16 Jun 2023AY 2017-2018

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri B. Ramakrishnan (FCA) &For Respondent: Shri R. Mohan Reddy (CIT) – Ld.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 him…

Ga Infra Private Limited, Jaipur vs. PCIT, Jaipur-2

In the result, appeal of the assessee is allowed

ITA 219/JPR/2023[2018-19]Status: DisposedITAT Jaipur14 Jun 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Shailendra Sharma (CIT) a
Section 142(1)Section 143(2)Section 143(3)Section 263Section 80I

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 219/JPR/2023 fu/kZkj.k o"kZ@Assessment Years : 2018-19 GA Infra Private Limited cuke The Principal Commissioner of Vs. Plot No. 61, Keshav Nagar, Hawa Income Tax, Jaipur-2, Jaipur. Sadak, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAECG 6222 D vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Mani…

Kaur Kookies (P) Ltd., New Delhi vs. Pr, CIT, Delhi-4, New Delhi

Appeal are allowed

ITA 1119/DEL/2022[2017-18]Status: DisposedITAT Delhi11 May 2023AY 2017-18

Bench: Shri Kul Bharat & Shri Pradip Kumar Kediaassessment Year: 2017-18

Section 263Section 36

…es 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. vs. ITO, (1977) 106 ITR 1 (SC)].” 8.3 The Hon’ble Delhi high Court in the case of CIT vs. Sunbeam Auto Ltd. reported in 332 ITR 16it has held as under: “Therefore, one has to see from the record as to whether there was application of mind before allowing the expenditure in question as revenue expenditure. Learned counsel for the assessee is right in his submission that one…

DCIT, New Delhi vs. M/S. Sahara India Power Corporation Ltd., Pune

In the result, the appeal filed by the revenue for the AY 2005-06 in I

ITA 5067/DEL/2013[2005-06]Status: PendingITAT Delhi28 Apr 2023AY 2005-06

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

For Appellant: Shri Ajay VohraFor Respondent: Shri Kanv Bali

…nt, 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. 12. This Court in Parashuram Pottery Works Co. Ltd. v. ITO [1977] 106 ITR 1 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 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 o…

Sahara India Power Corporation Ltd, Pune vs. DCIT, New Delhi

In the result, the appeal filed by the revenue for the AY 2005-06 in I

ITA 1155/DEL/2009[2004-05]Status: DisposedITAT Delhi28 Apr 2023AY 2004-05

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

For Appellant: Shri Ajay VohraFor Respondent: Shri Kanv Bali

…nt, 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. 12. This Court in Parashuram Pottery Works Co. Ltd. v. ITO [1977] 106 ITR 1 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 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 o…

Sahara India Power Corporation Ltd., Pune vs. Assistant Commissioner of Income-Tax

In the result, the appeal filed by the revenue for the AY 2005-06 in I

ITA 109/PUN/2007[2003-04]Status: DisposedITAT Delhi28 Apr 2023AY 2003-04

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

For Appellant: Shri Ajay VohraFor Respondent: Shri Kanv Bali

…nt, 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. 12. This Court in Parashuram Pottery Works Co. Ltd. v. ITO [1977] 106 ITR 1 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 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 o…

Dharmendra Mehta, Jaipur vs. Principal Commissioner of Income Tax-2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 201/JPR/2022[2012-13]Status: DisposedITAT Jaipur13 Apr 2023AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Avadhesh Kumar (CIT)
Section 143(3)Section 147Section 148Section 263Section 44A

…e issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasijudicial 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 him…

V.L Jewellers, Delhi vs. Circle-49(1), Delhi

In the result, appeal of the assessee is allowed

ITA 836/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Mar 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.836/Del/2022 िनधा"रणवष"/Assessment Year:2017-18 बनाम V.L. Jewellers, Pr. Commissioner Of 2775, 1St Floor, Gali No. 20-21, Vs. Income Tax, Beadon Pura, Karol Bagh, Circle 49(1), New Delhi. Room No. 1202, 12, Civic Centre, Minto Road, New Delhi. Pan No. Aadfv7989A अपीलाथ" Appellant ""यथ"/Respondent

Section 142(1)Section 143(1)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…

Madaan Associates, New Delhi vs. Pr, CIT Delhi-15, New Delhi

In the result, the appeal of the assessee is allowed

ITA 974/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Mar 2023AY 2017-18

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Ms. Rano Jain, AdvFor Respondent: Ms. Sarita Kumar, CIT DR
Section 143(3)Section 263Section 263(1)Section 36(1)(iii)

…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 re-activated 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 sh…

DCIT(Ltu) - 1, Mumbai vs. Acc Ltd., Mumbai

In the result, appeal filed by assessee is partly allowed

ITA 3177/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Feb 2023AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151

…impugned order was to be dismissed on ground of low tax effect - Held, yes [Paras 4, 5 and 6] [In favour of assessee]” 18. It is relevant to refer to decision of Hon’ble Supreme Court in case of Parashuram Pottery Works Co. Ltd. v. Income-tax Officer [1977] 106 ITR 1 which reads as under: “……………….The words "omission or failure to disclose fully and truly all material facts necessary for his assessment for that year" postulate a duty on the assessee to disclose fully and truly all material facts necessary for his assessment. What facts are material and necessary for assessment will differ from case to case. In…

Acc Ltd., Mumbai vs. Addl CIT(Ltu), Mumbai

In the result, appeal filed by assessee is partly allowed

ITA 3137/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Feb 2023AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151

…impugned order was to be dismissed on ground of low tax effect - Held, yes [Paras 4, 5 and 6] [In favour of assessee]” 18. It is relevant to refer to decision of Hon’ble Supreme Court in case of Parashuram Pottery Works Co. Ltd. v. Income-tax Officer [1977] 106 ITR 1 which reads as under: “……………….The words "omission or failure to disclose fully and truly all material facts necessary for his assessment for that year" postulate a duty on the assessee to disclose fully and truly all material facts necessary for his assessment. What facts are material and necessary for assessment will differ from case to case. In…

M/S. Corporate Leisure & Property Development Pvt. Ltd., Bengaluru vs. DCIT, Central Circle-2(1)(1), Bengaluru

In the result, the appeal fails and is hereby dismissed

ITA 1053/BANG/2022[2013-14]Status: DisposedITAT Bangalore27 Feb 2023AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Prashanth G.S., A.RFor Respondent: Shri Sankarganesh K., D.R

…ITA No.1053/Bang/2022 M/s. Corporate Leisure & Property Development Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI GEORGE GEORGE K., JUDICIAL MEMBER Assessment Year: 2013-14 M/s. Corporate Leisure & Property Development Pvt. Ltd. Deputy Commissioner No108/114, Oxford Towers of Income-tax 139 Airport Road, Kodihalli Vs. Central Circle-2(1)(1) Bangalore 560 008 Bangalore PAN NO : AACCC3744Q APPELLANT RESPONDENT Appellant by : Shri Prashanth G.S., A.R. Respondent by : Shri Sankarganesh K., D.R. Date of Hearing : 21.02.20…

Kamalesh Kumar Sheth (HUF), Chennai vs. The Principal Commissioner of Income Tax-3, Chennai

In the result, the appeal stands allowed in terms of our above order

ITA 215/CHNY/2022[2017-18]Status: DisposedITAT Chennai17 Feb 2023AY 2017-18

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri B.Ramakrishnan, FCA &For Respondent: Shri S.Senthil Kumar, (CIT)-Ld. DR
Section 142(1)Section 143(3)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…

DCIT, CC-2(1), Chennai vs. M/S, Jan De Nul Dredging (I)(P)Ltd, Chennai

In the result, the appeal filed by the Revenue is dismissed

ITA 870/CHNY/2020[2011-12]Status: DisposedITAT Chennai08 Feb 2023AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.870/Chny/2020 िनधा"रण वष"/Assessment Year: 2011-12 The Deputy Commissioner Of Vs. M/S. Jan De Nul Dredging (I)(P) Ltd., “Capital”, 10Th Floor, No. 554/555, Income Tax, Corporate Circle 2(1), Room No. 511, 5Th Floor, Wanaparthy Mount Road, Chennai 600 018. Block, No. 121, M.G. Road, Chennai 600 034. [Pan:Aaacj6482G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Hema Bhupal, Jcit ""थ" की ओर से/Respondent By : Shri Ashik Shah, C.A. & Ms. C. Sowndarya, C.A. सुनवाई की तारीख/ Date Of Hearing : 02.02.2023 घोषणा की तारीख /Date Of Pronouncement : 08.02.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 6, Chennai, Dated 26.08.2020 Relevant To The Assessment Year 2011-12. 2. Facts Are, In Brief, That The Assessee Is Engaged In The Business Of Dredging Services & Filed Its Return Of Income For The Assessment Year 2011-12 On 30.11.2011 Admitting Total Income Of ₹.3,86,20,850/-. The Return Filed By The Assessee Was Initially Processed Under Section 143(1)

For Appellant: Shri D. Hema Bhupal, JCITFor Respondent: Shri Ashik Shah, C.A. &
Section 139Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

…आयकर अपीलीय अिधकरण, ’बी’ "ायपीठ, चे"ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी वी दुगा" राव "ाियक सद" एवं "ी जी. मंजुनाथा, लेखा सद" के सम" Before Shri V. Durga Rao, Judicial Member & Shri G. Manjunatha, Accountant Member आयकर अपील सं./I.T.A. No.870/Chny/2020 िनधा"रण वष"/Assessment Year: 2011-12 The Deputy Commissioner of Vs. M/s. JAN DE NUL Dredging (I)(P) Ltd., “Capital”, 10th Floor, No. 554/555, Income Tax, Corporate Circle 2(1), Room No. 511, 5th Floor, Wanaparthy Mount Road, Chennai 600 018. Block, No. 121, M.G. Road, Chennai 600 034. [PAN:AAACJ6482G] (अपीलाथ"/Appellant) (""थ"/Respondent) अप…