Pharmaceuticals Ltd. v. DCIT

476 ITR 193Reported decision#25092 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 341,001 Indian tax judgments — from 2025 to 2025.

Sections most often in play

Section 147Section 36(1)(iii)Section 132Section 139Section 145(3)Section 250Section 36(1)(vii)Section 44AB

Issues it is cited on

section 148section 147section 14indiatotal income

Judgments citing Pharmaceuticals Ltd. v. DCIT

Manoj Kumar Dugar, Erode vs. ITO, Ward-1(1), Erode

In the result, the appeal of the assessee is allowed

ITA 2170/CHNY/2025[2013-14]Status: DisposedITAT Chennai10 Nov 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Shri S. Sridhar (Erode), AdvocateFor Respondent: Ms. Pryati Sharma, JCIT
Section 143(3)Section 147Section 148Section 68

…four years. Reliance was placed on several judicial precedents including CIT v. Kelvinator of India Ltd. [320 ITR 561 (SC)], Foramer France v. CIT [264 ITR 566 (SC)] and jurisdictional High Court decisions reported in 430 ITR 515 (Mad), 455 ITR 292 (Mad) and 476 ITR 193 Mad) holding that reassessment beyond four years is bad in law when there is no failure by the assessee to disclose material facts. 5. We have carefully considered the rival submissions and perused the records. It is undisputed that the original assessment was completed u/s 143(3) on 22.03.2016. The notice u/s 148 was issued on 27.03.2019, i.e.,…

DCIT, Cen Cir 2(2), Chennai vs. Jayapriya Company, Chennai

In the result, both the appeals of the Revenue are dismissed and

ITA 1252/CHNY/2025[2022-23]Status: DisposedITAT Chennai12 Sept 2025AY 2022-23

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.G. Baskar, AdvocateFor Respondent: Mrs. Yamuna, CIT
Section 132Section 139Section 147Section 148Section 250

…above judgment (supra) was followed with by the Hon’ble jurisdictional Madras High Court in the case of Citadel Fine ITA Nos.1251 & 1252/Chny/2025 & CO Nos.43 & 44/Chny/2025 (AYs 2021-22 & 2022-23) Jayapriya Company :: 22 :: Pharmaceuticals Ltd. v. DCIT (476 ITR 193) wherein it was held that, the deduction for bad debts is allowable upon write-off in relevant year, without necessitating justification that debt has actually gone bad. The relevant portion of the decision is as follows:- “22. The Supreme Court in TRF Ltd (supra), has held that post amendment to Section 36(1)(vii) of the Act, with effect from…

DCIT, CC2(2), Chennai vs. Jayapriya Company, Chennai

In the result, both the appeals of the Revenue are dismissed and

ITA 1251/CHNY/2025[2021-22]Status: DisposedITAT Chennai12 Sept 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.G. Baskar, AdvocateFor Respondent: Mrs. Yamuna, CIT
Section 132Section 139Section 147Section 148Section 250

…above judgment (supra) was followed with by the Hon’ble jurisdictional Madras High Court in the case of Citadel Fine ITA Nos.1251 & 1252/Chny/2025 & CO Nos.43 & 44/Chny/2025 (AYs 2021-22 & 2022-23) Jayapriya Company :: 22 :: Pharmaceuticals Ltd. v. DCIT (476 ITR 193) wherein it was held that, the deduction for bad debts is allowable upon write-off in relevant year, without necessitating justification that debt has actually gone bad. The relevant portion of the decision is as follows:- “22. The Supreme Court in TRF Ltd (supra), has held that post amendment to Section 36(1)(vii) of the Act, with effect from…