Ranbaxy Laboratories Ltd. v. DCIT

351 ITR 23High Court2013#5338 most cited

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

An Assessing Officer cannot allege a failure to disclose material facts if they did not advert to or utilize such material during the original assessment. The reasons for reopening an assessment cannot be supplemented by subsequent affidavits or oral submissions.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2015 to 2024.

Also referred to as

Ranbaxy Laboratories Ltd v. DCIT · section 147 · true and full disclosure · material facts · reopening of assessment · reasons for reopening · affidavit · oral submissions · Assessing Officer · Delhi High Court

Also reported as

255 CTR 113

Issues it is cited on

test of enduring benefitsection 35ddsection 72asection 147(b)section 115jaasection 2(31)section 147(a)true and full disclosuresection 39section 54ecresulting companysection 115ja

Judgments citing Ranbaxy Laboratories Ltd. v. DCIT

ACIT 1(3), Mumbai vs. Tata Communications Ltd ( Foprmerly Kknown As Videsh Sanchar Nigam, Ltd), Mumbai

In the result, Department’s appeal is dismissed

ITA 3326/MUM/2009[2001-02]Status: DisposedITAT Mumbai29 Jan 2016AY 2001-02

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: Shri Dinesh Vyas, A.RFor Respondent: Shri G.M. Doss, D.R
Section 147Section 148Section 244ASection 250

…statutory document and has certain sanctity and cannot be considered to be a ordinary piece of evidence which could not have been noticed by the AO with due diligence. Ld. Sr. Counsel relied upon the following decisions: 1. Ranbaxy Laboratories Ltd. vs. DCIT (351 ITR 23) 2. 31 Infotech Ltd. vs. CIT (329 ITR 257) 8 ITA No.3417/M/2009, CO No.201/M/2012 & ITA No.3326/M/2009 M/s. Tata Communications Ltd. (formerly known as Videsh Sanchar Nigam Ltd.) 10. The Ld. Sr. Counsel referring to the observations made by the AO in the original assessment order submitted, a reading of the assessment order would reveal that the…

DCIT, New Delhi vs. M/S. Nandan Auto Tech Ltd, New Delhi

ITA 3166/DEL/2009[2000-01]Status: DisposedITAT Delhi30 Sept 2015AY 2000-01

Bench: Shri I.C. Sudhir & Shri Laxmi Prasad Sahu

For Appellant: S/Shri Ved Jain, Ashish Chadha, AshishFor Respondent: Shri R.L. Meena, Sr. DR
Section 143(3)Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH “E” NEW DELHI) BEFORE SHRI I.C. SUDHIR AND SHRI LAXMI PRASAD SAHU ITA Nos. 3166 & 3203/Del/2009 Assessment Years: 2000-01 Deputy CIT, vs. Nandan Auto Tech Ltd., Circle 13(1), (Formerly known as M/s. Garg New Delhi. Forgings and Casting Ltd.), 12A/6, Saraswati Marg, Channa Market, Karol Bagh, New Delhi. (PAN: AAACG4005A) (Appellant) (Respondent) Appellant by: S/Shri Ved Jain, Ashish Chadha, Ashish Goel, CAs & Pranjal Srivastava, Adv. Respondent by: Shri R.L. Meena, Sr. DR Date of hearing : 20 .08.2015 Date of pronouncement: 30 .09.2015 ORDER PER I.C. SUDHIR:…