Ralies India Ltd. v. ACIT & Another

323 ITR 54High Court2010#3229 most cited

What is Ralies India Ltd. v. ACIT & Another authority for?

Reassessment is unsustainable if based merely on a change of opinion in the absence of tangible material.

37

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

Rallies India Ltd. v. ACIT · reassessment unsustainable · change of opinion · tangible material · section 147 · income escaping assessment · section 148 · section 143(3)

Issues it is cited on

Judgments citing Ralies India Ltd. v. ACIT & Another

YES BANK LIMITED,MUMBAI vs. ADDITIONAL COMMISSIONER OF INCOME TAX (APPEALS), PANCHKULA

In the result, the appeal of the assessee bearing ITA No

ITA 1093/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeeyes Bank Limited Vs Additional Commissioner Of Income Yes Bank House, 8Th Floor, Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent Additional Commissioner Of Vs Yes Bank Limited Yes Bank House, 8Th Floor Income Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent

For Appellant: Shri Yogesh Thard &Ms.Vidhi SalotFor Respondent: Ms. Ramapriya Raghavan - CIT DR&
Section 139(1)Section 143(1)Section 234ASection 234CSection 250Section 36(1)(va)Section 43B

…erein it was held that where two views were possible at the time of the original assessment, a subsequent retrospective amendment would not justify invoking revisionary powers under Section 263. Further reliance was placed on Rallis India Ltd. v. ACIT, (2010) 323 ITR 54 (Bom), where the Hon’ble Bombay High Court held that reassessment was unsustainable if based merely on a change of opinion in the absence of tangible material. 5. On merits, the Ld. AR submitted that the assessee, Yes Bank Ltd., was placed under a moratorium by the Reserve Bank of India from 05.03.2020 to 18.03.2020, under the directions of the G…

ASST. COMM. OF INCOME TAX - 11(3)(1), MUMBAI vs. TPL PLASTECH LTD., MUMBAI

The appeal stands dismissed

ITA 6206/MUM/2017[2011-12]Status: DisposedITAT Mumbai07 Jan 2020AY 2011-12

Bench: Hon’Ble Shri C.N. Prasad, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ I.T.A. No.6206/Mum/2017 (िनधा"रण वष" / Assessment Year: 2011-12) Acit-11-(3)(1) M/S. Tpl Plastech Ltd. बनाम/ Room No.204, 2Nd Floor 10-11, Shivali Indl. Estate Aaykar Bhavan Andheri(E) Vs. M.K. Marg, Mumbai-400 020. Mumbai -400 072. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaact-1968-P (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Rakesh Joshi – Ld. Ar Revenue By : Shri Mayura Pratap-Ld.Dr सुनवाई की तारीख/ : 02/12/2019 Date Of Hearing घोषणा की तारीख / : 07/01/2020 Date Of Pronouncement आदेश / O R D E R

For Appellant: Shri Rakesh Joshi – Ld. ARFor Respondent: Shri Mayura Pratap-Ld.DR
Section 143(2)Section 143(3)Section 148

…le under law. Reliance was placed on various judicial pronouncements including the decision of Hon’ble Supreme Court rendered in CIT V/s Kelvinator of India Ltd. (320 ITR 561) as followed by Hon’ble Bombay High Court in the case of Rallis India Ltd. V/s ACIT (323 ITR 54). 3.3 On merits, the assessee submitted that the Machinery under consideration was acquired from ‘Machinery Division’ of its holding company situated at Pantnagar and Daman and it was entirely new plant and machinery which was eligible for claiming additional depreciation. It was wrong presumption in the mind of Ld. AO that machinery was used mach…

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