PCIT v. S S Con Build Ltd.

445 ITR 506Reported decision#3758 most cited

What is PCIT v. S S Con Build Ltd. authority for?

The issue concerning the initiation of reassessment proceedings under sections 147/148 of the Income Tax Act, 1961, is settled by the Supreme Court's decision in Abhisar Buildwell Pvt Ltd, which was followed in PCIT v. S.S. Con. Build Ltd. The Assessing Officer can examine the possibility of taking action under these sections if the conditions are fulfilled, as directed by CBDT Instruction No. 1 dated 23.08.2023.

32

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2024 to 2025.

Also referred to as

PCIT v. S.S. Con. Build Ltd · 445 ITR 506 · Abhisar Buildwell Pvt Ltd · Section 147 · Section 148 · reassessment proceedings · CBDT Instruction No. 1 · settled issue · Supreme Court decision

Sections most often in play

Section 1961Section 132Section 147Section 148Section 153ASection 69ASection 133ASection 250

Issues it is cited on

section 133a(3)(iii)substantive assessmentsurvey under section 133aretraction of statementbusiness connectionblock periodsection 65bsection 65documents seizedsection 132arejection of books of accountcross objection

Judgments citing PCIT v. S S Con Build Ltd.

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 392/ASR/2024[2012-13]Status: DisposedITAT Amritsar30 Oct 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 391/ASR/2024[2011-12]Status: DisposedITAT Amritsar30 Oct 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 390/ASR/2024[2019-20]Status: DisposedITAT Amritsar30 Oct 2025AY 2019-20

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 389/ASR/2024[2018-19]Status: DisposedITAT Amritsar30 Oct 2025AY 2018-19

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 388/ASR/2024[2017-18]Status: DisposedITAT Amritsar30 Oct 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 387/ASR/2024[2016-17]Status: DisposedITAT Amritsar30 Oct 2025AY 2016-17

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 386/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 385/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAXQ, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 384/ASR/2024[2013-14]Status: DisposedITAT Amritsar30 Oct 2025AY 2013-14

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. ANKUSH MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 383/ASR/2024[2018-19]Status: DisposedITAT Amritsar30 Oct 2025AY 2018-19

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 382/ASR/2024[2017-18]Status: DisposedITAT Amritsar30 Oct 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 340/ASR/2024[2016-17]Status: DisposedITAT Amritsar30 Oct 2025AY 2016-17

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DCIT CENTRAL CIRCLE 1, JALANDHAR, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 339/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DCIT CENTRAL CIRCLE 1 JALANDHAR, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 338/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 337/ASR/2024[2013-14]Status: DisposedITAT Amritsar30 Oct 2025AY 2013-14

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 266/ASR/2024[2012-13]Status: DisposedITAT Amritsar30 Oct 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. ANKUR MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 265/ASR/2024[2011-12]Status: DisposedITAT Amritsar30 Oct 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. RAJNI MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 251/ASR/2024[2019-20]Status: DisposedITAT Amritsar30 Oct 2025AY 2019-20

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. RAJNI MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 250/ASR/2024[2018-19]Status: DisposedITAT Amritsar30 Oct 2025AY 2018-19

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. RAJNI MARWAHA, JALANDHAR

In the result, all the appeals filed by the revenue are dismissed

ITA 249/ASR/2024[2017-18]Status: DisposedITAT Amritsar30 Oct 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. K. Mehboob Ali Khan, CIT-DR
Section 153ASection 250Section 69A

…hence deleted. 5.4.5 This decision of Hon'ble Apex Court In the case of Abhisar Buildwell Pvt Ltd has been followed by the Hon'ble Apex Court in the cases of 'King Buildcon Pvt. Ltd. in Civil Appeal No. 4326/2023 and PCIT Vs. S.S. Con. Build Ltd. reported in 445 ITR 506. Therefore, this issue has now been settled. Also, Hon'ble CBDT has issued Instruction vide Instruction No. 1 dated 23.08.2023 [F No. 279/MISC./M-54/2023-ITJJ in which certain directions have been issued by the Hon'ble CBDT that how the effect to such judgment is to be given. In view of this decision in the Abhisar Buildwell case and in view the…

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