Puri v. CIT

151 ITR 584High Court1985#3446 most cited

What is Puri v. CIT authority for?

A third judge's opinion in a reference is decisive, effectively forming a majority opinion equivalent to a full bench, even if not sitting together with the original two judges.

34

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2018 to 2026.

Also referred to as

P. C. Puri v. CIT · 151 ITR 584 · third judge · reference · difference of opinion · majority opinion · full bench · Tribunal · section 153D

Sections most often in play

Section 143(3)Section 147Section 148Section 153ASection 153DSection 263Section 271(1)(c)Section 139

Issues it is cited on

section 274(2)section 243section 245hacasus omissussection 245csection 271(1)(a)settlement applicationsection 245d(4)section 153(4)section 135asection 144basection 245d

Judgments citing Puri v. CIT

Mahaveer Singh, Ahmedabad vs. The PCIT, Ahmedabad-1, Ahmedabad

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 840/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 139(1)Section 142(1)Section 143(3)Section 148Section 234FSection 263(1)Section 270ASection 270A(2)(b)Section 272A(1)(d)Section 44A

…IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH Before: DR. BRR Kumar, Vice President And Shri T. R. Senthil Kumar, Judicial Member ITA No: 840/Ahd/2025 Assessment Years: 2018-19 Mahaveer Singh The PCIT, 466, Karnavati Platinium, Ahmedabad-1, K 9, Ahmedabad G.P.O., Vs Ahmedabad Ahmedabad-380001 Gujarat PAN: FCTPS0920M (Appellant) (Respondent) Assessee Represented: Shri P.F. Jain, A.R. Revenue Represented: Shri Alpesh Parmar, CIT-DR Date of hearing : 25-02-2026 Date of pronouncement : 03-03-2026 आदेश/ORDER PER: T.R. SENTHIL KUMAR, JUDICIAL MEMBER This appeal is filed by the Assessee as against R…

ACIT, Central Circle-II, Lucknow vs. Rakesh Kumar Pandey, Gonda U.P

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 460/LKW/2025[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT (Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 351/LKW/2025[2018-19]Status: DisposedITAT Lucknow11 Dec 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT (Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 349/LKW/2025[2016-17]Status: DisposedITAT Lucknow11 Dec 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Assistant Commissioner of Income Tax, Allahabad vs. Jyoti Mediservices Ltd., Allahabad

ITA 129/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 107 between the A two judges. Whether th…

Jyoti Mediservices Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

ITA 115/ALLD/2025[2013-14]Status: DisposedITAT Allahabad21 Nov 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 107 between the A two judges. Whether th…

Jyoti Mediservices Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

ITA 114/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 107 between the A two judges. Whether th…

Jyoti Mediservices Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

ITA 113/ALLD/2025[2011-12]Status: DisposedITAT Allahabad21 Nov 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 107 between the A two judges. Whether th…

Jeevan Jyoti Infrastructure Company Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 56/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Minto Colonizers Private Limited, Allahabad vs. DCIT Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 54/ALLD/2025[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Deputy Commissioner of Income Tax, Allahabad vs. Navjeevan Pediatrics Private Limited, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 44/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Deputy Commissioner of Income Tax (Central Circle), Allahabad vs. Jeevan Jyoti Charitable Trust, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 41/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Deputy Commissioner of Income Tax, Allahabad vs. Jeevan Jyoti Charitable Trust, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 40/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Deputy Commissioner of Income Tax(Central Circle), Allahabad vs. Jeevan Jyoti Charitable Trust, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 39/ALLD/2025[2011-12]Status: DisposedITAT Allahabad30 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Arpit Hospital Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 14/ALLD/2025[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Arpit Hospital Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 13/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 40/ALLD/2019[2013-14]Status: DisposedITAT Allahabad30 Sept 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 39/ALLD/2019[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 38/ALLD/2019[2011-12]Status: DisposedITAT Allahabad30 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 37/ALLD/2019[2010-11]Status: DisposedITAT Allahabad30 Sept 2025AY 2010-11

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…case, order has been passed by Tribunal in the case of Dheeraj Chaudhary vs. ACIT [2025] 178 taxmann.com 360 (Delhi-Trib._ (TM), on the issue of validity of approval u/s 153D of the Act. Also, we are conscious of order in the case of P. C. Puri vs. CIT [1985] 151 ITR 584 (Delhi), in which Hon'ble Delhi High Court held: There is no difference, really speaking, between a full bench of three judges sitting together and this method of referring to the third judge in the case of a difference of opinion between the A two judges. Whether the first method is adopted or the second, ""opinion of the majority"" will be deci…