How many judgments cite Ranbaxy Laboratories Ltd. v. CIT?

398 judgments on BharatTax cite Ranbaxy Laboratories Ltd. v. CIT (336 ITR 136), spanning 2012 to 2026.

Which sections of the Income Tax Act does Ranbaxy Laboratories Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 143(3), Section 68, Section 142(1), Section 151.

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

Sections most often in play

Section 147 Section 148 Section 143(3)Section 68 Section 142(1)Section 151 Section 139(1)Section 143(1)

Issues it is cited on

section 148(2)income escaping assessment reason to believe kelvinator escapement of income reopening of assessment change of opinion notice under section 148 tangible material reassessment proceedings regular assessment service of notice

Judgments citing Ranbaxy Laboratories Ltd. v. CIT

DCIT, CC-06, New Delhi vs. Naveen Infradevelopers & Engineers Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 80/DEL/2022[2012-13]Status: HeardITAT Delhi22 Jan 2024AY 2012-13

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Subhra Jyoti Chakraborty, CIT- DR

Section 147Section 148Section 68

…ance was placed on Explanation 3 to section 147 of the Act which was inserted by the Finance Act No. 2, 2009 w.e.f. 01.04.1989 and also on the decision of the Hon'ble Bombay High Court in the case of Jet Airways 331 ITR 236 and Ranbaxy Laboratories Limited 336 ITR 136 [Del]. 11. The ld. CIT(A) was convinced with the contention of the assessee and drawing support from the decision relied upon by the assessee, the ld. CIT(A) deleted the impugned addition. 12. We have given thoughtful consideration to the orders of the authorities below. In our considered view, the Assessing Officer has drawn support from Expl…

Paramjit Singh, Delhi vs. AO Ward-1, Karnal, Haryana

In the result the appeal of the assessee in ITA No

ITA 446/DEL/2022[2012-13]Status: DisposedITAT Delhi01 Dec 2023AY 2012-13

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri P.N. Barnwal, CIT-DR

Section 147Section 151Section 263

…143(3) of the Act it has been held that the respondent assessee had been able to show and establish the genuineness of and capacity to make the said investment. 10. Similar issue had arisen before this Court in Ranbaxy Laboratories Limited versus CIT, (2011) 336 ITR 136 (Delhi). In the said case, the Division Bench had also examined Explanation 3 to Section 147, which was inserted by Finance (No. 2) Act of 2009 with retrospective effect from 1st April, 1989. Reference was made to the decision of the Bombay High Court in CIT versus Jet Airways India Limited, (2011) 331 ITR 236 (Bom.) in which it has been held as…

Jay Kishore Choubey, Rairangpur vs. ACIT, Circle-1, Asansol

In the result, appeal of the assessee stands allowed

ITA 2/CTK/2023[2010-11]Status: DisposedITAT Cuttack29 Nov 2023AY 2010-11

Bench: Before S/Shri George Mathan, Judicial & Girish Agrawalassessment Year : 2010-2011 2011 Jay Jay Kishore Kishore Choubey, Choubey, Vs. Acit, Circle Acit, Circle-1, Asansol. Rairangpur Bazar, Rairangpur, Rairangpur Bazar, Rairangpur, Mayurbhanj. Pan/Gir No. Pan/Gir No.Acmpc 1759 N (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.R.Mohanty P.R.Mohanty, Adv Revenue By : Shri Charan Das, Sr. Das, Sr. Dr Date Of Hearing : 29/11 11/2023 Date Of Pronouncement : 29/11 /11/2023 O R D E R Per Bench

For Appellant: Shri P.R.MohantyFor Respondent: Shri Charan Das, Sr

Section 147Section 148

…e submission by ld AR that in view of the decision of the Hon’ble Bombay High Court in the case of Jet Airways India Pvt Ltd., [2010] 331 ITR 236 (Bom.) as also the decision of Hon’ble Delhi High Court in the case of of Ranbaxy Laboratories Ltd. vs CIT [2011] 336 ITR 136 (Del.), as no addition has been made on the basis of the reasons recorded, the assessment order as made is liable to be quashed. He also placed reliance on the decision of the Co-ordinate Bench of Jaipur Bench in the case of Shri Digamber Jain Atikshaya Keshtra vs ITO in ITA No.424/JPR/2022 for A.Y. 2010-2011 order dated 22.8.2023, wherein, the C…

Tata Chemicals Ltd, Mumbai vs. Addl Ciat 2(3), Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 120/MUM/2013[2008-09]Status: DisposedITAT Mumbai10 Nov 2023AY 2008-09

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 144C(5)Section 14ASection 43BSection 80

…ies (India) Ltd. 98 taxmann.com 90 (2018) (Calcutta-H.C.) (para 10- 11) (Refer C.1.-26, pgs 292-295) 2. Mahindra & Mahindra Ltd. 117 taxmann.com 518 (Mum. ITAT) [2020] (para 14 Pg22- 23) (Refer C.L-27, pgs 296-330) 3. Delhi High Court in Ranbaxy Laboratories (334 ITR 341) (para 4-9) (Refer C.L.-28. Pgs331-334) 4. Nalco ITA No.27 of 2006 (2022) (Orissa-H.C.) (para 18-24; Pg 6-7) (Refer C.L. 29. pgs 335-341) ITA.NO. 120/MUM/2013 (A.Y: 2008-09) Tata Chemicals Ltd 5. GlaxoSmithKline Consumer Healthcare Ltd. 64 taxmann.com 84 [2015] (Chandigarh- ITAT) (pg12-18 para 29-35) (Refer C.L. 30, pgs 342-368) 6. Rural Electrif…

Ratnashri Infrastructure Pvt. Ltd., Delhi vs. ACIT, Central Circle- 4, New Delhi

ITA 1607/DEL/2019[2010-11]Status: DisposedITAT Delhi31 Oct 2023AY 2010-11

Bench: Sh. M. Balaganesh & Sh.Anubhav Sharma

Section 131Section 133(6)Section 141(1)Section 142(1)Section 143(2)Section 148Section 68

…Micro Marbles 'Pvt Ltd vs ITO 457 ITR 569 and hon ’ble Bombay high Court in Anurag Gupta case 454 ITR 326 and further same has not been lawfully inducted vide separate/mandatory corresponding notice u/s 148 (refer delhi high court in Ranbaxy laboratories case 336 ITR 136 and Mumbai G bench of ITAT in case of Juliet industries ltd vs ITO (ITA 5452/Mum/2016 order dated 04.04.2018 and delhi C bench IT AT in case of INS Finance investment pvt ltd vs. ITO (ITA 9266/DEL/2019 order dated 26.10.2020) and further same is in nature of roving and fishing inquiries only as there is no income escaping asst element/ingredient…

Nitu Singh, Howrah vs. ITO, Ward-37(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 842/KOL/2023[2013-14]Status: DisposedITAT Kolkata12 Oct 2023AY 2013-14

Bench: Shri Rajesh Kumarassessment Year: 2013-14 Nitu Singh Ito, Ward-37(2), Kolkata 137, Chakpara Ramkrishna Colony, Ideal Vs. Club, Bhattanagar, Howrah-711203. Pan: Badps2548K (Appellant) (Respondent) Present For: Appellant By : Shri Palash Chottpadhyay, Ar Respondent By : Shri Pravash Roy, Addl. Cit-Dr. Date Of Hearing : 05.10.2023 Date Of Pronouncement : 12.10.2023 O R D E R Per Rajesh Kumar: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 30.05.2023 Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) By The National Faceless Appeal Centre (Hereinafter Referred As The ‘Cit(A)’) Relevant To A.Y 2013-14. 2. At The Outset, The Ld. Counsel For The Assessee Pointed Out A Delay Of 15 Days In Filing Of The Appeal Which Is Attributable To The Fact That The Ex Parte Order Passed By The Cit(A) Was Served On The Ex-Tax Consultant’S Email, Despite The Correct Email Mentioned In Form No.35. The Ld. Ar Submitted That The Assessee Came To Know About The Passing Of The Order By Cit(A) On 30.05.2023 Only When The Assessing Officer Issued Notice U/S 271(1)(C) Of The Act On 26.06.2023. Thereafter, The Assessee Tried Her Best To Procure The 2 Assessment Year: 2013-14 Nitu Singh Appellate Order & Hand Over To The Chartered Accountant Who Has Taken Sometime For Preparation Of Appeal Documents & Finally The Appeal Was Filed On 14.08.2023 & Thus The Delay Of 15 Days In Filing The Appeal. The Ld. Ar Submitted That The Assessee Is Not Responsible For The Reasons Attributable To The Late Filing Of Appeal Nor The Assessee Is Benefitted By Late Filing Of Appeal In Any Manner Whatsoever. The Ld. Ar, Therefore, Prayed That The Delay Of 15 Days May Kindly Be Condoned & The Appeal May Kindly Be Admitted For Adjudication.

For Appellant: Shri Palash Chottpadhyay, ARFor Respondent: Shri Pravash Roy, Addl. CIT-DR

Section 143(3)Section 147Section 148Section 148(2)Section 250Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA BENCH “SMC”, KOLKATA BEFORE SHRI RAJESH KUMAR, ACCOUNTANT MEMBER Assessment Year: 2013-14 Nitu Singh ITO, Ward-37(2), Kolkata 137, Chakpara Ramkrishna Colony, Ideal Vs. Club, Bhattanagar, Howrah-711203. PAN: BADPS2548K (Appellant) (Respondent) Present for: Appellant by : Shri Palash Chottpadhyay, AR Respondent by : Shri Pravash Roy, Addl. CIT-DR. Date of Hearing : 05.10.2023 Date of Pronouncement : 12.10.2023 O R D E R PER RAJESH KUMAR, ACCOUNTANT MEMBER: The present appeal has been preferred by the assessee against the order dated 30.05.2023 passed u/s 250 of the In…

Murlidhar Kriplani, Udaipur vs. ITO, Ward-2(3), Udaipur

In the result, the appeal of the assessee is allowed

ITA 153/JODH/2019[2010-11]Status: DisposedITAT Jodhpur03 Oct 2023AY 2010-11

Bench: Completing The Assessment Of Income Which Is Mandatory In Sh. Murlidhar Kriplani Vs. Ito Nature. The Commissioner Of Income Tax (Appeals) Also Confirmed That Where Return Of Income Filed Beyond Time As Contemplated Under Section 139, It Is Not Necessary On Part Of Ao To Issue Notice U/S 143(2) Which Is Bad In Law & Unjustified & Not Tenable As Per The Hon'Ble Rajasthan High Court Jaipur Bench In Case Of Ito Vs Kamla Devi Sharma In Db

Section 139Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 158Section 54F

…the reassessment proceedings to have been required to be taxed in the original assessment. Further reliance is placed on the following cases: 1. ACIT VS. M.K. Exim (India) Ltd., ITAT, Jaipur, 82 Taxmann.com 61. 2. Ranbaxy Laboratories Ltd. Vs. CIT (Delhi HC) 336 ITR 136 3. CIT Vs. Jet Airways (1) Ltd. (Bombay HC) 331 ITR 236 4. Travancore Cements Ltd. Vs. ACIT (Kerala HC) 305 ITR 170 Thus, the appellant prays to quash the assessment order so passed by the Assessing Officer and confirmed by the Commissioner of Income Tax (Appeals)-1, Udaipur, as the same is bad in law, unjustified, and not tenable as per the fact…

Mohan Kumar Roy, Kolkata vs. ITO, Ward 29(1), Kolkata

In the result, both the appeals filed by the assessee are allowed

ITA 104/KOL/2022[2012-13]Status: DisposedITAT Kolkata22 Sept 2023AY 2012-13

Bench: Sri Rajesh Kumar & Sonjoy Sarma

Section 143(3)Section 148Section 254Section 68

…may kindly be quashed. In support of his argument, Ld. A/R relied on the decision of Hon'ble Calcutta High Court in the case of CIT Vs. M/S Infinity Infotech Parks Ltd ITAT No.60 of 2014 in GA No.1736 of 2014 besides relying on Ranbaxy Laboratory Ltd. Vs CIT 336 ITR 136 (Del) and CIT Vs. Jet Airways Ltd 331 ITR 236 (Bom), which have been followed by the Coordinate Bench of the Tribunal in the case of Shree Prakash Chhawchharia (HUF) Vs ITO Ward-36(2) ITA No.1622/Kol/2019 A.Y. 2011-12. 9. Ld. D/R on the other hand, submitted that the issue raised by the assessee is a new issue which was not raised before the firs…

Mohan Kumar Roy, Kolkata vs. ITO, Ward 29(1), Kolkata

In the result, both the appeals filed by the assessee are allowed

ITA 103/KOL/2022[2012-13]Status: DisposedITAT Kolkata22 Sept 2023AY 2012-13

Bench: Sri Rajesh Kumar & Sonjoy Sarma

Section 143(3)Section 148Section 254Section 68

D.C.I.T., Ciecle-11(1), Kolkata vs. Homage Estate Ltd., Kolkata

In the result, the appeal of revenue is dismissed and Cross Objection of the assessee is allowed

ITA 2621/KOL/2019[2011-12]Status: DisposedITAT Kolkata22 Sept 2023AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 143(3)Section 147Section 148Section 148(2)Section 68Section 69C

…e also note that the case of the assessee is also covered by the decision of Hon’ble Bombay High Court in the case of CIT Vs. Jet Airways (I) Ltd. reported in 331 ITR 236 (Bom.) and Hon’ble Delhi High Court in the case of Ranbaxy Laboratories Ltd. reported in 336 ITR 136(Del.). Accordingly, we quash the assessment framed by the AO as invalid by allowing the Cross Objection of the assessee. Since we have allowed the Cross Objection of the assessee, the appeal of the revenue becomes infructuous and is dismissed. 6. In the result, the appeal of revenue is dismissed and Cross Objection of the assessee is allowed. Or…

M/S. Fountain Vanijya Pvt. Ltd (Now Merged With M/S. Ashiana Goods Pvt. Ltd., Kolkata vs. ITO, Ward-13(1), Kol, Kolkata

In the result, the appeal of the assessee is allowed as per terms indicated hereinabove

ITA 400/KOL/2023[2012-13]Status: DisposedITAT Kolkata12 Sept 2023AY 2012-13

Bench: Shri Sanjay Garg, J & Dr. Manish Boradi.T.A. No. 400/Kol/2023 Assessment Year: 2012-2013 M/S. Fountain Vanijya Pvt. Limited,.........Appellant (Now Merged With M/S. Ashiana Goods Pvt. Ltd.), Ganesh Complex, Nh-6, Bombay Road, Raghudevpur, Howrah-711322 [Pan: Aabcf1407E] -Vs.- Income Tax Officer,...............................Respondent Ward-13(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Sunil Surana, A.R., Appeared On Behalf Of The Assessee Shri B.K. Singh, Jcit (Sr. D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : August 03, 2023 Date Of Pronouncing The Order : September 12Th, 2023 O R D E R

Section 139(1)Section 143(1)Section 143(3)Section 144Section 147Section 148

…oceeding becomes bad in law. The decision of the Hon’ble Bombay High Court in the case of CIT –vs.- Jet Airways India Limited (331 ITR 236) has been referred to by the Hon’ble Delhi High Court in the case of Ranbaxy Laboratories Limited – vs.- CIT reported in 336 ITR 136 and held that “reassessment must be in the first place, be in respect of income escaped assessment for which the reasons were recorded and only thereafter in respect of some other items of escaped income. If, however, the income, escapement of which was the foundation for recording of reasons to believe, is not assessed or reassessed in the order…

Aman Exports International, Jaipur vs. DCIT Circle 1, Jaipur

In the result, appeal of the assessee is partly allowed

ITA 147/JPR/2023[2012-13]Status: DisposedITAT Jaipur24 Aug 2023AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Tatiwal (CA)For Respondent: Smt. Runi Pal (Addl. CIT) &

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 148Section 40A(3)

…it means he had no “reasons to believe that income has escaped assessment” and the issue of the notice becomes invalid. If so, he has no jurisdiction to assess any other income. 20 Aman Exports International vs. DCIT Ranbaxy Laboratories Ltd vs. CIT (2011) 60 DTR 77(Delhi) (High Court) Thus in view of the facts, judicial decisions stated above the additions made deserves to be deleted.” 6.2 The ld. AR of the assessee also filed an affidavit contending that the relevant document regarding the amount disputed is placed on the record in the assessment proceeding. The content of the affidavit is reproduced here…

Usha K Jolly Charitable Trust, Pune vs. Commissioner of Income-Tax, (Exemption), Pune

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

ITA 174/PUN/2022[2010-11]Status: DisposedITAT Pune22 Aug 2023AY 2010-11

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.174/Pun/2022 िनधा"रण वष" / Assessment Year : 2010-11 Usha K. Jolly Charitable Vs. Cit (Exemption), Pune. Trust, 23, Jolly Villa, Bund Garden Road, Pune- 411001. Pan : Aaatu1384R Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Ajay Kumar Kesari Date Of Hearing : 10.08.2023 Date Of Pronouncement : 22.08.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Exemption), Pune [‘The Cit (Exemption)’] Dated 30.03.2021 For The Assessment Year 2010-11. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. The Learned Cit (Exemptions) Erred In Law & On Facts In Invoking The Jurisdiction U/S 263 Of The It Act, 1961, Since Issues

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Ajay Kumar Kesari

Section 11Section 12ASection 13(1)(c)Section 143(3)Section 148Section 263

…nd prejudicial to the interests of the Revenue”, in the light of the law laid down by the Hon’ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd., 331 ITR 236 (Bom.), the Hon’ble Delhi High Court in the case of Ranbaxy Laboratories Ltd. vs. CIT, 336 ITR 136 (Delhi) and the Hon’ble Rajasthan High Court in the case of CIT vs. Shri Ram Singh, 306 ITR 343 (Rajasthan), it is not permissible for the Assessing Officer to make any other addition. Therefore, what follows from this is that the ld. CIT (Exemption) could not have exercised the jurisdiction u/s 263 in respect of item, which could not have been d…

Shri Digamber Jain Atikshaya Keshtra, Padampua vs. ITO Exemption Ward 1, Kailash Heights

In the result appeal of the assessee is partly allowed

ITA 424/JPR/2022[2010-11]Status: DisposedITAT Jaipur22 Aug 2023AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajeev sogani (C.A)&For Respondent: Ms. Monisha Choudhary (Addl.CIT)

Section 11(2)Section 147Section 148Section 151Section 24Section 253(3)

…आयकरअपीलीय अधिकरण] जयपुरन्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh]U;kf;dlnL; ,oaJhjkBksMdeys'kt;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No. 424/JPR/2022 fu/kZkj.ko"kZ@AssessmentYear :2010-11 Shri Digamber Jain Atikshaya Keshtra cuke ITO, (Exemptions), Vs. VPO Bada, Padampura, Ward-1, Jaipur. Jaipur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAATS 5225 R vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri Rajeev sogani (C.A)& Ms. Ruchika Sogani (Adv.) jkt…

M/S Sunil Chetndas Katariya, HUF, Nashik vs. Principal Commissioner of Income-Tax-1, Nashik

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

ITA 261/PUN/2022[2011-12]Status: DisposedITAT Pune21 Aug 2023AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.261/Pun/2022 िनधा"रण वष" / Assessment Year : 2011-12 M/S. Sunil Chetandas Vs. Pr.Cit-1, Nashik. Katariya, 649, Sai Villa, Lam Road, Deolali Camp, Nashik- 422401. Pan : Aaths6634R Appellant Respondent Assessee By : Shri Sanket Joshi Revenue By : Shri Ajay Kumar Kesari Date Of Hearing : 10.08.2023 Date Of Pronouncement : 21.08.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Pr. Commissioner Of Income Tax-1, Nashik [‘Pcit’] Dated 12.03.2021 For The Assessment Year 2011-12. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. The Learned Pcit Erred In Holding That The Asst. Order Passed U/S 143(3) R.W.S. 147 In The Case Of The Assessee For A.Y.2011 - 12 Was Erroneous & Prejudicial To The Interest Of Revenue & Thereby

For Appellant: Shri Sanket JoshiFor Respondent: Shri Ajay Kumar Kesari

Section 139Section 143(3)Section 147Section 148Section 263Section 269S

…nd prejudicial to the interests of the Revenue”. In the light of the law laid down by the Hon’ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd., 331 ITR 236 (Bom.), the Hon’ble Delhi High Court in the case of Ranbaxy Laboratories Ltd. vs. CIT, 336 ITR 136 (Delhi) and the Hon’ble Rajasthan High Court in the case of CIT vs. Shri Ram Singh, 306 ITR 343 (Rajasthan), it is not permissible for the Assessing Officer to make any other addition. Therefore, what follows from this is that the ld. PCIT could not have exercised the jurisdiction u/s 263 in respect of item, which could not have been disallowed i…

D. Rajaram, Rep by S. Dhandapani(Power Holder), Coimbatore vs. ITO, Intnl Taxation Ward, Coimbatore

In the result, the appeal of the assessee is allowed

ITA 233/CHNY/2023[2015-16]Status: DisposedITAT Chennai02 Aug 2023AY 2015-16

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.233/Chny/2023 िनधा"रण वष" /Assessment Year: 2015-16 Shri D. Rajaram, The Income Tax Officer, Represented By S. Dhandapani Vs. International Taxation Ward, (Power Holder), Coimbatore. Old No.21G, New No.35, Rangasamy Colony, 2Nd Street, Selvapuram, Coimbatore. [Pan: Akmpr-4391-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri S. Sridhar, Advocate अपीलाथ" क" ओर से/ Appellant By ""यथ" क" ओर से /Respondent By : Shri R. Mohan Reddy,Cit सुनवाई क" तारीख/Date Of Hearing : 01.08.2023 घोषणा क" तारीख /Date Of Pronouncement : 02.08.2023

For Respondent: Shri R. Mohan Reddy,CIT

Section 144CSection 144C(5)Section 147Section 148Section 69A

…Tractors and Farm Equipment Ltd. v. ACIT [2018] 409 ITR 369 (Mad.), wherein it is held as under: “16. The decision in the case of Jet Airways (cited supra) was referred to by the High Court of Delhi in the case of Ranbaxy Laboratories Limited v. CIT (2011] 336 ITR 136 (Delhi), wherein it was held that the Legislature could not be presumed to have intended to give blanket powers to the Assessing Officer that on assuming jurisdiction under section 147 regarding assessment or reassessment of escaped income, he would keep on making roving inquiry and thereby including different items of income not connected or rel…

Sampat Lal Lodha, Nathdwara vs. ITO, Ward-2, Rajsamand

In the result, both appeals of the assessee are allowed

ITA 2/JODH/2022[2011-12]Status: DisposedITAT Jodhpur02 Aug 2023AY 2011-12

Section 143(1)Section 147Section 68

…the ld AO are contrary each other and as such in light of decision of Hon’ble Jurisdictional High Court in th case of CIT v/s Shri Ram Singh (2008) 8 DTR 118/306 ITR 343(Raj HC), Hon’ble Delhi High Court in the case of Ranbaxy Laboratories Ltd. vs. CIT (2011) 336 ITR 136 and Hon’ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom.). iv] Further also Hon’ble ITAT Jaipur Bench in case of Bansiwala Iron & Steel Rolling Mills Vs DCIT (ITAT Jaipur) ITA No. 1388/JP/2019 dated 15/09/2021, after following the decision of Hon’ble Jurisdictional High Court and other High Courts CIT v/…

Sampat Lal Lodha, Nathdwara vs. ITO, Ward-2, Rajsamand

In the result, both appeals of the assessee are allowed

ITA 1/JODH/2022[2010-11]Status: DisposedITAT Jodhpur02 Aug 2023AY 2010-11

Section 143(1)Section 147Section 68

Shri Arnesh Kumar Shakar Ex. Mla, Hoshiarpur vs. Income Tax Officer Ward, Dasuya

In the result, appeal of the assessee ITA No

ITA 6/ASR/2021[2010-11]Status: DisposedITAT Amritsar26 Jul 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 147Section 148Section 250Section 54Section 54F

…as agitated before the ld. CIT(A) and the ld. CIT(A) has rejected this legal ground of the assessee. 5.2 The ld. AR further argued that this viewpoint is fully supported by the decisions of Hon'ble Delhi High Court in Ranbaxy Laboratories Ltd vs CIT (2011) 336 ITR 136 and of Gujrat High Court in CIT vs Mohmed Juned Dadani (2013) 214 Taxman 38 (Guj), followed by ITAT Amritsar in the case of Joginder Singh vs ITO (2015) 174 TTJ 888 (Asr). The relevant paragraph of the order is extracted here: - “19. As is evident from the discussions earlier in this order, here is a case in which the very reasons on account o…

Jt. CIT (Ods) - CC -1(4), Mumbai vs. Ultratech Cement Ltd., Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 222/MUM/2022[2014-15]Status: DisposedITAT Mumbai28 Jun 2023AY 2014-15

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Bledeputy Commissioner Of Income Tax V. M/S. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Jt. Commissioner Of Income Tax (Osd) V. M/S. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan Andheri (E), Mumbai- 400093 Old C.G.O. Bldg, (Annexe) M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) & M/S. Ultratech Cement Limited V. Dcit, Central Circle- 1(4) [Acit, Cc] Room. No 902, 9Th Floor Ahura Centre, B-Wing, 2Nd Floor Pratishtha Bhavan Mahakali Caves Road Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 Maharishi Karve Road Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

Section 143(3)Section 35D

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, HON’BLE JUDICIAL MEMBER Deputy Commissioner of Income Tax v. M/s. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9th Floor 2nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 PAN: AAACL6442L (Appellant) (Respondent) Jt. Commissioner of Income Tax (OSD) v. M/s. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9th Floor 2nd Floo…