Rampyari Devi Saraogi v. CIT

67 ITR 84Supreme Court of India1968#97 most cited

What is Rampyari Devi Saraogi v. CIT authority for?

An assessment order is erroneous and prejudicial to the Revenue's interests if the Assessing Officer accepts a sum offered as income by an assessee, even when that sum was not actually earned, thereby allowing revision under Section 263.

616

judgments rely on this decision, according to BharatTax’s citation analysis of 366,416 Indian tax judgments — from 2009 to 2026.

Also referred to as

Rampyari Devi Saraogi v. CIT · Section 263 revision · assessment erroneous and prejudicial · unearned income offered · Assessing Officer accepting income · Commissioner's power of revision · inadequate inquiry by AO · Malabar Industrial Co. Ltd. reference · Income Tax Act 1961 Section 263

Also reported as

3 SCC 482240 Taxmann 221

Sections most often in play

Section 263Section 143(3)Section 142(1)Section 1961Section 147Section 144BSection 148Section 143(2)

Issues it is cited on

section 263(1)inadequate enquirymalabar industriallack of enquiryprejudicial to interest of revenuerevision under section 263assessment order erroneousrevision u/s 263erroneous and prejudicialsection 263non-application of mindsection 26

Judgments citing Rampyari Devi Saraogi v. CIT

M/S. Eta Star Infopark, Bengaluru vs. The Principal Commissioner of Income Tax, Bengaluru-1, Bengaluru

ITA 248/BANG/2021[2016-17]Status: DisposedITAT Bangalore02 Sept 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Annamalai, A.RFor Respondent: Dr. Manjunath Karkihalli, D.R
Section 143(3)Section 2Section 263

…his return and fails to make enquiries or examine the genuineness of the claim which are called for in the circumstances of the case. In taking the aforesaid view, we are supported by the decisions of the Hon'ble Supreme Court in Rampyari Devi Saraogi v. CIT (67 ITR 84) (SC), Smt. Tara Devi Aggarwal v. CIT (88 ITR 323) (SC), and Malabar Industrial Co. Ltd's case ( 243 ITR 83) (SC). 4.4 In our humble view, arbitrariness in decision-making would always need correction regardless of whether it causes prejudice to an assessee or to the State Exchequer. The Legislature has taken ample ITA No.415/Bang/2020 & M/s. ETA…

M/S. Eta Star Infopark, Bengaluru vs. Principal Commissioner of Income Tax-1, Bengaluru

ITA 415/BANG/2020[2015-16]Status: DisposedITAT Bangalore02 Sept 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Annamalai, A.RFor Respondent: Dr. Manjunath Karkihalli, D.R
Section 143(3)Section 2Section 263

…his return and fails to make enquiries or examine the genuineness of the claim which are called for in the circumstances of the case. In taking the aforesaid view, we are supported by the decisions of the Hon'ble Supreme Court in Rampyari Devi Saraogi v. CIT (67 ITR 84) (SC), Smt. Tara Devi Aggarwal v. CIT (88 ITR 323) (SC), and Malabar Industrial Co. Ltd's case ( 243 ITR 83) (SC). 4.4 In our humble view, arbitrariness in decision-making would always need correction regardless of whether it causes prejudice to an assessee or to the State Exchequer. The Legislature has taken ample ITA No.415/Bang/2020 & M/s. ETA…

M/S Kinnor Kinnoree, Kolkata vs. CIT-X, Kolkata

In the result, the appeal of the assessee is allowed

ITA 176/KOL/2022[2005-06]Status: DisposedITAT Kolkata30 Aug 2022AY 2005-06

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Manish Borad

Section 143(2)Section 143(3)Section 263

…t in the submission of the assessee. From the above, it is quite clear that the AO had passed a stereotyped order, and make enquiries which are called for in the circumstances of the case. The order is s in view of the decisions in Rampyari Devi V. CIT 1968) 67 ITR 84 (SC) and Tara 'garwal V. CIT(1973) 88 ITR 232 (SC). He failed to make necessary enquiry. The order is also prejudicial to the interest of revenue in view of decisions in Malabar Industrial Co.Ltd. 243 ITR 83 (SC). The assessing Officer had accepted assessee’s submission without examining the points discussed above.Thus , the AO failed to make nece…

Mallikarjun Virupaxappa Yarasi, Gadag vs. Principal Commissioner of Income Tax, Hubli

In the result, the appeal of the assessee is dismissed

ITA 437/BANG/2022[2017-18]Status: DisposedITAT Bangalore30 Aug 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2017-18

For Appellant: Shri S.V. Ravishankar, A.RFor Respondent: Sri Manjunath Karkihalli, D.R
Section 142(1)Section 143(2)Section 143(3)Section 263

…his return and fails to make enquiries or examine the genuineness of the claim which are called for in the circumstances of the case. In taking the aforesaid view, we are supported by the decisions of the Hon'ble Supreme Court in Rampyari Devi Saraogi v. CIT (67 ITR 84) (SC), Smt. Tara Devi Aggarwal v. CIT (88 ITR 323) (SC), and Malabar Industrial Co. Ltd's case ( 243 ITR 83) (SC). 6.4 In Malabar Industrial Co. Ltd. case the Hon'ble Court has held as under: “There can be no doubt that the provision cannot be invoked to correct each and every type of mistake or error committed by the Assessing Officer, it is onl…

Vinod Kumar Gupta, Uttarpradesh vs. Circle-1(1)(1), Meerut

In the result, the appeal of the assessee is allowed

ITA 664/DEL/2022[2014-15]Status: DisposedITAT Delhi30 Aug 2022AY 2014-15

Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma

For Appellant: Sh. Salil Kapoor, Adv. &For Respondent: Sh. Surender Pal, CIT DR
Section 131Section 133(6)Section 143(3)Section 254Section 263

…is Court that where a sum not earned by a person is assessed as income in his hands on his so offering the order passed by the AO accepting the same as such will be erroneous and prejudicial to the interest of the Revenue. Rampyari Devi Saraogi vs. CIT (1968) 67 ITR 84 (SC): TC 57R.202 and in Smt. Tara Devi Aggarwal Vs. CIT (SC) 107: (1973) 88 ITR 323 (SC) : TC 57R.206. [Emphasis supplied by us] Further, the Id. AO has taken the view only after due application of mind and there is no finding contrary to that in the aforesaid notice hence the initiation of the present 263 proceedings is bad in law. In this regard…

Keshav Saraf, Kolkata vs. PCIT-15, Kolkata

In the result, the appeal of the assessee is dismissed

ITA 156/KOL/2021[2015-15]Status: DisposedITAT Kolkata25 Aug 2022AY 2015-15

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 108Section 143(2)Section 143(3)Section 263

…essment proceeding, he was justified in invoking the provisions of section 263 in respect of the order passed by the AO. 10.2. In this context, reference can also be made to the decisions of Hon’ble Supreme Court in the cases of Ramapyari Devi Saraogi (1968) 67 ITR 84 (SC) and Smt. Taradevi Agarwal Vs CIT (1973) 88 ITR 323 (SC), wherein the Hon’ble Apex Court has held that lack of adequate enquiry or verification at the relevant time by the AO would constitute “prejudice to the interest of revenue” and would make such order “erroneous”. Reference in this context is invited to the decision of Delhi High Court in…

Adenium Ventures Private Limited, Mumbai vs. Pr CIT, Circle-5, Mumbai.

ITA 870/MUM/2022[2017-18]Status: DisposedITAT Mumbai25 Aug 2022AY 2017-18

Bench: Shri Kuldip Singh & Shri Om Prakash Kantassessment Year: 2017-18

For Appellant: Ms. Arati Vissanji, A.RFor Respondent: Ms. Shailaja Rai, D.R
Section 143(3)Section 14ASection 263

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “A”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER Assessment Year: 2017-18 M/s. Adenium Ventures Pr. CIT, Pvt. Ltd., Circle -5, 1st Floor, Mafatlal Centre, Room No.515, Vs. 5th Floor, Nariman Point, Mumbai – 400 021 Aayakar Bhavan, PAN: AACCB2399A Maharshi Karve Road, Mumbai - 400020 (Appellant) (Respondent) Present for: Assessee by : Ms. Arati Vissanji, A.R. Revenue by : Ms. Shailaja Rai, D.R. Date of Hearing : 11 . 08 . 2022 Date of Pronouncement : 25 . 08 . 2022 O R D E R Per : Kuldip Singh, Judicial Member:…

Anup Enterprises, Mumbai vs. The Principal CIT-19, Mumbai

In the result, ground no. 2 & 3 raised by the assessee are also dismissed

ITA 1641/MUM/2021[2011-12]Status: DisposedITAT Mumbai23 Aug 2022AY 2011-12

Bench: Shri Kuldip Singh & Shri Gagan Goyalanup Enterprises, 41, 4Th Floor, Neelkamal, Pedder Road, Mumbai-400026 Pan: Aaafa5067D ...... Appellant Vs. The Pr.Cit-19, Room No. 228, 2Nd Floor, Matru Mandir, Tardeo, Mumbai-400007 ..... Respondent Appellant By : None Respondent By : Smt. Shailja Rai, Cit-Dr Date Of Hearing : 26/05/2022 Date Of Pronouncement : 23/08/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Ld. Principal Commissioner Of Income Tax-19, Mumbai [Hereinafter Referred To As (‘Ld. Pr.Cit) Dated 22.03.2021 For The Assessment Year (Ay) 2011-12. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: NoneFor Respondent: Smt. Shailja Rai, CIT-DR
Section 142(1)Section 144Section 147Section 148Section 253Section 263Section 263(1)Section 3

…he Commissioner might think to be prejudicial to the revenue administration. The prejudice must be prejudice to the Revenue administration. 7 ITA No. 1641/Mum/2011-Anup Enterprises In the case of Smt. Tara Devi Aggarwal v. Commissioner of Income-tax [1973] 88 ITR 323 (SC) it has been held that the Commissioner has ample jurisdiction under section 263 to cancel the assessment and may initiate proceedings for assessment under the provisions of the Act against some other assessee who according to the income-tax authorities is liable for the income thereof. In Thalibai F. Jain ITO (1975) 101 ITR 1 (Kar), it was he…

ACIT 2(3) (1), Mumbai vs. M/S. Thakkr Housing Development Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2135/MUM/2021[2012-13]Status: DisposedITAT Mumbai22 Aug 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ing principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income in the wrong hands is not bar to assess the same income in the right hands and failure by the Assessing Officer to assess the income in the right hands renders the assessment order erroneous. 35. Further, we notice that both Assessing Officer as well as CIT(A) misdirected themselves by applying p…

ACIT 2(3) (1), Mumbai vs. M/S. Thakkar Apana Ghar Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2134/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Aug 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ing principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income in the wrong hands is not bar to assess the same income in the right hands and failure by the Assessing Officer to assess the income in the right hands renders the assessment order erroneous. 35. Further, we notice that both Assessing Officer as well as CIT(A) misdirected themselves by applying p…

ACIT 2(3) (1), Mumbai vs. M/S. Thakkar Apna Ghar Nirman Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2133/MUM/2021[2012-13]Status: DisposedITAT Mumbai22 Aug 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ing principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income in the wrong hands is not bar to assess the same income in the right hands and failure by the Assessing Officer to assess the income in the right hands renders the assessment order erroneous. 35. Further, we notice that both Assessing Officer as well as CIT(A) misdirected themselves by applying p…

ACIT 2(3) 1, Mumbai vs. M/S. Thakkar Grih Nirman Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2132/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Aug 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ing principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income in the wrong hands is not bar to assess the same income in the right hands and failure by the Assessing Officer to assess the income in the right hands renders the assessment order erroneous. 35. Further, we notice that both Assessing Officer as well as CIT(A) misdirected themselves by applying p…

ACIT 2(3) (1), Mumbai vs. M/S. Thakkar Housing Developement Pvt. Ltd, Mumbai

In the result all the five appeals filed by the learned assessing officer are dismissed

ITA 2131/MUM/2021[2014-15]Status: DisposedITAT Mumbai22 Aug 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Rishabh Shah, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 245D(4)

…ing principle in the decision by Hon'ble Supreme Court in the case of Malabar Industrial Co. Ltd vs. CIT, 243 ITR 83, wherein the Hon'ble Supreme Court after referring to the earlier ITA nos. 2131to 2135/Mum/2021 decision in the case of Smt. Taradevi Agrawal, 88 ITR 323 held that merely because of an assessment of income in the wrong hands is not bar to assess the same income in the right hands and failure by the Assessing Officer to assess the income in the right hands renders the assessment order erroneous. 35. Further, we notice that both Assessing Officer as well as CIT(A) misdirected themselves by applying p…

Asha Devi, Bangalore vs. The Principal Commissioner of Income Tax, Bangalore-2, Bangalore

In the result, the appeal by the assessee is dismissed

ITA 371/BANG/2022[2017-18]Status: DisposedITAT Bangalore18 Aug 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2017-18

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri Deva Rathna Kumar, CIT(DR)(ITAT)
Section 143(3)Section 263

…submitted any details in this regard during the assessment proceedings. 9. We notice that the Delhi High Court in the case of Gee Vee Enterprises v .ACIT [1975] 99 ITR 375 (Del) has held as under:- “In Tara Devi Aggarwal v. Commissioner of Income-tax [1973] 88 ITR 323 (SC) also the Income-tax Officer, Howrah, while remarking that the source of income of the assessee was income from speculation and interest on investments stated that neither the assessee was able to produce the details and vouchers of the speculative transactions made during the accounting year nor was there evidence regarding the interest recei…

Chambal Alums Private Limited, Kota vs. Pr. Commission of Income Tax-Udaipur, Udaipur

ITA 147/JPR/2022[/2017-18]Status: DisposedITAT Jaipur16 Aug 2022
For Appellant: Shri Vijay Goyal, CAFor Respondent: Shri Sanjay Dhariwal, CIT
Section 142(1)Section 143(2)Section 143(3)Section 263Section 3

…herefore. argument of the assessee is not found tenable and same is hereby rejected. 11 ITA147/JP/2022 CHAMBAL ALUMS PVT LTD. VS ACIT, CIRCLE-2, KOTA On this issue it is further stated that Hon'ble Supreme Court in the case of Rampyari Devi Saraogi Vs. CIT (67 ITR 84) has held as under: Unlike the Civil Court which is neutral to give a decision on the basis of evidence produce before it, an Assessing Officer is not only an adjudicator but is also an investigator. He can not remain passive on the face of a return which is apparently in order but calls for further query. It is his duty to ascertain the truth of t…

Neelam Medatwal, Jaipur vs. Pcti-1, Jaipur

In the result, appeal of the assessee is allowed

ITA 62/JPR/2021[2016-17]Status: DisposedITAT Jaipur16 Aug 2022AY 2016-17

Bench: Itat & The Delay Occurred May Kindly Be Condoned.

For Appellant: Shri Rajeev Sogani (C.A.) &For Respondent: Shri Sanjay Dhariwal (CIT) a
Section 142(1)Section 143(3)Section 263Section 54F

…the revenue as held in following cases: 1. Jagdish Kumar Gulati vs. CIT 269 ITR 71 (Allahabad) 2. Duggal & Co. 220 ITR 456 (Delhi) 3. K.Am Rama Swami Chettiar vs. CIT 220 ITR 657 (Mad.) 1. Hon’ble Supreme Court in the case of Tara Devi Agarwal vs. CIT [(1973) 88 ITR 323] in which Hon’ble CCourt stated that where a stereotype order is passed, which simply accepts what the assessee has said in the return and falls to make enquiries which are called for in the circumstances of the case the commissioner is justified in holding that the order is erroneous and prejudicial to the interests of the revenue. sec. 263 of th…

Sh. Dheeraj Singh Sisodiya, 005, Village Beedmandi, Nayagaon, Ramganjmandi, Kota vs. PCIT (Central), Jaipur

In the result, appeal of the assessee is allowed

ITA 132/JPR/2022[2016-17]Status: DisposedITAT Jaipur10 Aug 2022AY 2016-17
For Appellant: Shri P.C. Parwal (C.A..)For Respondent: Shri Avdhesh Kumar (CIT)
Section 143(3)Section 153ASection 263Section 271(1)(c)Section 271A

…the proposition that the taxpayer will not suffer (as he will be given due opportunity at the time of levy or non-levy of penalty), I rely upon order of Hon'ble Supreme Court in the case of Rampyari Devi Saraogi versus Commissioner of Income Tax, reported in 67 ITR 84 (Supreme Court) (3rd last paragraph thereof maybe seen for this proposition). I wish to make it clear that I am not disturbing the assessment that has already been made. I am only passing an order for, initiation / levy of penalty 5 Shri Dheeraj Singh Sisodiya as detailed above, that too based upon independent satisfaction of the assessing office…

C.B. Mubarka Charitable Trust, Mumbai vs. CIT (Exemption), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 638/MUM/2021[2016-17]Status: DisposedITAT Mumbai03 Aug 2022AY 2016-17

Bench: Shri Vikas Awasthy & Shri Amarjit Singhc.B. Murarka Charitable Vs. Cit(Exemption) Trust, B-310, Virwani 617, 6Th Floor, Piramal Industrial Estate, Chamber, Lal Baug, Parel Western Express Mumbai - 400012 Highway, Goregaon East, Mumbai – 400063 स्थायी लेखा सं./ जीआइआर सं./ Pan/Gir No: Aaatc0036C Appellant .. Respondent

For Appellant: Sanjay C. ShahFor Respondent: Sandeep Rai
Section 143(3)Section 263

…ments i.e Malabar Industrial Company Ltd. Vs. CIT(2000) 243 ITR 83 (SC), Bismillah Trading Company Vs. Intelligence Officer (2001) 248 ITR 292 (Karnataka) Venkateshkrishna Rice Company Vs. CIT (1987) 163 ITR 129 (Madras), Smt. Taradevi Aggarwal Vs. CIT (1973) 88 ITR 323 (SC), Thalibai F. Jain Vs. ITO (1975) 101 ITR 1 (Karnataka), CIT Vs. Amitabh Bachhan, 384 ITR 200 & Others decision the ld. Pr. CIT held that the A.O has passed assessment order without basic verification of issue as mentioned above in this order. Therefore, the assessment order dated 01.12.2018 was set aside to the A.O with direction to undertake…

M/S. Coretech Ventures (Bangalore) Private Limited, Bangalore vs. The Principal Commissioner of Income Tax, Bengaluru-2, Bangalore

In the result, the appeal filed by the assessee stands dismissed

ITA 746/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Jul 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2016-17 M/S. Coretech Ventures (Bangalore) Pvt. Ltd., The Principal Divyasree Chambers’ Commissioner Of Wing-A, O Shaugnessy Income Tax, Road, Bengaluru – 2, Langford Town, Vs. Bengaluru. Bangalore – 560 025. Pan: Aafcc2775E Appellant Respondent : Shri V. Chandrashekar, Assessee By Advocate : Shri V.S. Chakrapani, Cit- Revenue By Dr Date Of Hearing : 01-06-2022 Date Of Pronouncement : 29-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 30/03/2021 Passed By Ld.Pcit, Bangalore -2 U/S. 263 Of The Act For A.Y. 2016-17 On Following Grounds Of Appeal: “1. The Order Of Revision Passed By The Learned Principal Commissioner Of Income Tax, Bengaluru -2, Bengaluru, Under Section 263 Of The Act Dated 30/03/2021, In So Far As It Is Against The Appellant Is Opposed To Law, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Appellant'S Case.

For Respondent: Shri V. Chandrashekar
Section 143Section 263Section 80Section 801A

…ue in a haste. Hon’ble Supreme Court in following cases, including the decision of Malabar Industrial Co. Ltd. (supra) observed that, AO is not supposed to accept a claim in the absence of supporting materials:  Rampyari Devi Saraogi v.CIT reported in (1968) 67 ITR 84  Smt. Tara Devi Aggarwal v. CIT reported in (1973) 88 ITR 323 Hon’ble Delhi High Court in case of Duggal & Co. v. CIT reported in (1996) 220 ITR 456 and GeeVee Enterprises reported in (1975) 99ITR 375, observed that, failure of the AO to investigate into facts in the return calling for enquiries makes the order erroneous. 17. In case of lack of en…

Nekkanti Systems Private Limited, Hyderabad vs. Income Tax Officer, Ward-16(2), Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 637/HYD/2019[2014-15]Status: DisposedITAT Hyderabad27 Jul 2022AY 2014-15

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year : 2014-15 Nekkanti Systems Private Vs. Income Tax Officer, Limited, Ward – 16(2), Hyderabad. Hyderabad. Pan : Aaccn1440J. (Appellant) (Respondent) Assessment Year : 2015-16 The Deputy Vs. Nekkanti Systems Private Commissioner Of Limited, Income Tax, Hyderabad. Circle – 16(1), Pan : Aaccn1440J. Hyderabad. Assessee By: Sri S. Rama Rao. Revenue By: Sri Rajendra Kumar – Cit Dr Date Of Hearing: 18.07.2022 Date Of Pronouncement: 27.07.2022 O R D E R Per Laliet Kumar, J.M. These Are The Two Connected Appeals Filed By The Assessee & Revenue For A.Y. 2014-15 & 2015-16 Against The Orders Of Principal Commissioner Of Income Tax, Hyderabad Dt.29.03.2019 U/S 263 Of The Act & Commissioner Of Income Tax (Appeals) – 4, Hyderabad Dt.23.01.2019 U/S 143(3) Of The Income Tax Act, Respectively.

For Appellant: Sri S. Rama RaoFor Respondent: Sri Rajendra Kumar – CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 263

…IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad Before Before Shri Rama Kanta Panda, Accountant Member AND Shri Laliet Kumar, Judicial Member Assessment Year : 2014-15 Nekkanti Systems Private Vs. Income Tax Officer, Limited, Ward – 16(2), Hyderabad. Hyderabad. PAN : AACCN1440J. (Appellant) (Respondent) Assessment Year : 2015-16 The Deputy Vs. Nekkanti Systems Private Commissioner of Limited, Income Tax, Hyderabad. Circle – 16(1), PAN : AACCN1440J. Hyderabad. Assessee by: Sri S. Rama Rao. Revenue by: Sri Rajendra Kumar – CIT DR Date of hearing: 18.07.2022 Date of pronouncement: 27.07.2022 O…