Ranbaxy Laboratories Ltd. v. CIT

336 ITR 136High Court2011#183 most cited

What is Ranbaxy Laboratories Ltd. v. CIT authority for?

In reassessment proceedings under Section 147/148, the Assessing Officer can assess other income not specified in the original notice if the initial ground for reopening assessment is found to be valid. However, if the income for which the assessment was initially reopened is found not to have escaped assessment, the Assessing Officer cannot proceed to assess any other income.

398

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2012 to 2026.

Also referred to as

Ranbaxy Laboratories Ltd. v. CIT · Section 147 · Section 148 · reopening of assessment · scope of reassessment · income escaping assessment · other income assessed · initial reason for reopening · quashing reassessment · Jet Airways principle · reassessment proceedings

Also reported as

12 Taxmann.com 74200 Taxmann 242242 CTR 11760 DTR 77

Issues it is cited on

Judgments citing Ranbaxy Laboratories Ltd. v. CIT

Gorav Footwear, Agra vs. Deputy Commissioner of Income-Tax, Circle1(1)(1), Agra/CIT(A), NFAC, Delhi, Agra

The appeal stand allowed in terms of our above order

ITA 503/AGR/2024[2012-13]Status: DisposedITAT Agra18 Feb 2025AY 2012-13

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.503/Agr/2024 (िनधा"रणवष" / Assessment Year: 2012-13) Gorav Footwear Dcit Circle 1(1)(1) बनाम/ 6, Nath Complex, Agra Vs. Dhakran Crossing, Agra – 282 003 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aahfg-7549-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Deependra Mohan (Ca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Shailendra Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 18-02-2025

For Appellant: Shri Deependra Mohan (CA)- Ld.ARFor Respondent: Shri Shailendra Shrivastava – Ld. Sr. DR
Section 143(3)Section 147Section 40A

…us. 2. In the above factual background, Ld. AR has cited the decision of Hon’ble Bombay High Court in the case of CIT Vs. Jet Airways (I) Ltd. (331 ITR 236) as well as the decision of Hon’ble Delhi High Court in the case of Ranbaxy Laboratories Ltd. Vs. CIT (12 Taxmann.com 74) to plead that the law does not empower Ld. AO to make any addition if original ground of reopening fails. In this decision, it was held that though the Explanation 3 to Sec. 147 inserted by the Finance Act, 2009 w.e.f. 01.04.1989 permits the AO to assess or reassess income which has escaped assessment even if the recorded reasons have not…