Rayala Corporation (P) Ltd. v. Enforcement

2 SCR 412Reported decision1969#8275 most cited

What is Rayala Corporation (P) Ltd. v. Enforcement authority for?

The decision in Rayala Corporation (P) Ltd. v. Enforcement (1969) is doubted and disapproved by later Supreme Court judgments, particularly concerning the interpretation of repeal under the General Clauses Act.

13

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2020 to 2025.

Also referred to as

Rayala Corporation (P) Ltd v Enforcement · 1969 2 SCR 412 · Fibre Boards Pvt Ltd · implied repeal · General Clauses Act · Section 6A General Clauses Act · statutory repeal

Judgments citing Rayala Corporation (P) Ltd. v. Enforcement

Principal Commissioner of Income Tax-1 vs. Pratap Technocrats Pvt. Ltd

ITA/2/2023HC Rajasthan07 Jan 2025

Bench: INDERJEET SINGH,VINOD KUMAR BHARWANI

Commissioner of Income Tax vs. M/S Pali Textile Common Effluent Treatment Plant

ITA/5/2024HC Rajasthan24 Jul 2024

Bench: SHREE CHANDRASHEKHAR,KULDEEP MATHUR

Pr. Commissioner of Income Tax-I vs. Shri Gulab Singh Bhandari

ITA/7/2024HC Rajasthan23 Apr 2024

Bench: MANINDRA MOHAN SHRIVASTAVA,MUNNURI LAXMAN

Principal Commnr of Income Tax-1, Khurdha vs. Mamata Mohapatra

ITA/5/2024HC Orissa12 Apr 2024

Bench: DR. JUSTICE B.R.SARANGI,MR. JUSTICE GOURISHANKAR SATAPATHY

Sri. Reddy Veeranna, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(3), Bengaluru

ITA 1146/BANG/2022[2015-16]Status: DisposedITAT Bangalore30 Nov 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R

Section 132(1)Section 139Section 143(3)Section 144Section 153A

…any binding or persuasive value. 16. The Hon'ble Apex court in the case of Fibre Boards Pvt. Ltd and M/s. Shree Bhagwati Steel Rolling has doubted and disapproved its earlier decisions rendered in the case of Rayala Corporation (P) Ltd Vs Enforcement (1969) 2 SCR 412 and Kolhapur Cane Sugar Works Ltd Vs Union of India (2000) 2SCC536 and in the case of General Finance Company Vs CIT (2002) 7 SCC 1. Further, the Hon'ble Supreme Court in the case of Fibre Boards (I) Ltd, after referring to the provisions of Section 6A of the General Clauses Act held that "a repeal can be by way of an express “omission" and that ev…

Sri. Reddy Veeranna, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(3), Bengaluru

ITA 1145/BANG/2022[2010-11]Status: DisposedITAT Bangalore30 Nov 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R

Section 132(1)Section 139Section 143(3)Section 144Section 153A

…any binding or persuasive value. 16. The Hon'ble Apex court in the case of Fibre Boards Pvt. Ltd and M/s. Shree Bhagwati Steel Rolling has doubted and disapproved its earlier decisions rendered in the case of Rayala Corporation (P) Ltd Vs Enforcement (1969) 2 SCR 412 and Kolhapur Cane Sugar Works Ltd Vs Union of India (2000) 2SCC536 and in the case of General Finance Company Vs CIT (2002) 7 SCC 1. Further, the Hon'ble Supreme Court in the case of Fibre Boards (I) Ltd, after referring to the provisions of Section 6A of the General Clauses Act held that "a repeal can be by way of an express “omission" and that ev…

Sri. Reddy Veeranna, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(3), Bengaluru

ITA 1113/BANG/2022[2014-15]Status: DisposedITAT Bangalore30 Nov 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R

Section 132(1)Section 139Section 143(3)Section 144Section 153A

…any binding or persuasive value. 16. The Hon'ble Apex court in the case of Fibre Boards Pvt. Ltd and M/s. Shree Bhagwati Steel Rolling has doubted and disapproved its earlier decisions rendered in the case of Rayala Corporation (P) Ltd Vs Enforcement (1969) 2 SCR 412 and Kolhapur Cane Sugar Works Ltd Vs Union of India (2000) 2SCC536 and in the case of General Finance Company Vs CIT (2002) 7 SCC 1. Further, the Hon'ble Supreme Court in the case of Fibre Boards (I) Ltd, after referring to the provisions of Section 6A of the General Clauses Act held that "a repeal can be by way of an express “omission" and that ev…

Sri. Reddy Veeranna, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(3), Bengaluru

ITA 1112/BANG/2022[2012-13]Status: DisposedITAT Bangalore30 Nov 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R

Section 132(1)Section 139Section 143(3)Section 144Section 153A

…any binding or persuasive value. 16. The Hon'ble Apex court in the case of Fibre Boards Pvt. Ltd and M/s. Shree Bhagwati Steel Rolling has doubted and disapproved its earlier decisions rendered in the case of Rayala Corporation (P) Ltd Vs Enforcement (1969) 2 SCR 412 and Kolhapur Cane Sugar Works Ltd Vs Union of India (2000) 2SCC536 and in the case of General Finance Company Vs CIT (2002) 7 SCC 1. Further, the Hon'ble Supreme Court in the case of Fibre Boards (I) Ltd, after referring to the provisions of Section 6A of the General Clauses Act held that "a repeal can be by way of an express “omission" and that ev…

Smt. Reddy Sangeetha, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-1(3), Bengaluru

ITA 1111/BANG/2022[2015-16]Status: DisposedITAT Bangalore30 Nov 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R

Section 132(1)Section 139Section 143(3)Section 144Section 153A

…any binding or persuasive value. 16. The Hon'ble Apex court in the case of Fibre Boards Pvt. Ltd and M/s. Shree Bhagwati Steel Rolling has doubted and disapproved its earlier decisions rendered in the case of Rayala Corporation (P) Ltd Vs Enforcement (1969) 2 SCR 412 and Kolhapur Cane Sugar Works Ltd Vs Union of India (2000) 2SCC536 and in the case of General Finance Company Vs CIT (2002) 7 SCC 1. Further, the Hon'ble Supreme Court in the case of Fibre Boards (I) Ltd, after referring to the provisions of Section 6A of the General Clauses Act held that "a repeal can be by way of an express “omission" and that ev…

Sri. Krishna Diamonds, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 232/BANG/2022[2014-15]Status: DisposedITAT Bangalore13 Sept 2022AY 2014-15

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri Rohit Goutham, C.AFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)

Section 234BSection 92B

…any binding or persuasive value. 16. The Hon'ble Apex court in the case of Fibre Boards Pvt. Ltd and M/s. Shree Bhagwati Steel Rolling has doubted and disapproved its earlier decisions rendered in the case of Rayala Corporation (P) Ltd Vs Enforcement (1969) 2 SCR 412 and Kolhapur Cane Sugar Works Ltd Vs Union of India (2000) 2SCC536 and in the case of General Finance Company Vs CIT (2002) 7 SCC 1. Further, the Hon'ble Supreme Court in the case IT(TP)A No.232/Bang/2022 Page 17 of 24 of Fibre Boards (I) Ltd, after referring to the provisions of Section 6A of the General Clauses Act held that "a repeal can be by…

M/S Sobha City, Bangalore vs. Assistant Commissioner of Income Tax Circle-1(2)(2), Bangalore

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 2936/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Apr 2021AY 2014-15

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year : 2014-15

For Appellant: Shri Nageshwar Rao, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 143(3)Section 2Section 40ASection 40A(2)(b)Section 92BSection 92C

…s any binding or persuasive value. 16. The Hon'ble Apex court in the case of Fibre Boards Pvt. Ltd and M/s. Shree Bhagwati Steel Rolling has doubted and disapproved its earlier decisions rendered in the case of Rayala Corporation (P) Ltd Vs Enforcement (1969) 2 SCR 412 and Kolhapur Cane Sugar Works Ltd Vs Union of India (2000) 2SCC536 and in the case of General Finance Company Vs CIT (2002) 7 SCC 1. Further, the Hon'ble Supreme Court in the case of Fibre Boards (I) Ltd, after referring to the provisions of Section 6A of the General Clauses Act held that "a repeal can be by way of an express ITA No.2936/Bang/2018…

M/S. Cauvery Aqua Private Limited, Bengaluru vs. The Deputy Commissioner of Income Tax, Circle- 2(1)(1), Bengaluru

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 2021/BANG/2019[2015-16]Status: DisposedITAT Bangalore17 Feb 2021AY 2015-16

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2021/Bang/2019 Assessment Year: 2015-16

For Appellant: Shri Suresh Muthukrishnan, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 143(3)Section 2Section 40ASection 6Section 92BSection 92C

…s any binding or persuasive value. 16. The Hon'ble Apex court in the case of Fibre Boards Pvt. Ltd and M/s. Shree Bhagwati Steel Rolling has doubted and disapproved its earlier decisions rendered in the case of Rayala Corporation (P) Ltd Vs Enforcement (1969) 2 SCR 412 and Kolhapur Cane Sugar Works Ltd Vs Union of India (2000) 2SCC536 and in the case of General Finance Company Vs CIT (2002) 7 SCC 1. Further, the Hon'ble Supreme Court in the case of Fibre Boards (I) Ltd, after referring to the provisions of Section 6A of the General Clauses Act held that "a repeal can be by way of an express “omission" and that ev…

Firmenich Aromatics (India) P.Ltd, Mumbai vs. ACIT Cir 4(2), Mumbai

In the result this ground of appeal is allowed

ITA 348/MUM/2014[2009-10]Status: DisposedITAT Mumbai15 Jul 2020AY 2009-10

Bench: Shri Pawan Singh & Shri S. Rifaur Rahman(Virtual Hearing In Virtual Court No.2)

For Respondent: Shri Bomi Daruwala with

Section 143(3)Section 144Section 144C(13)Section 144C(5)Section 254(1)Section 92C

…ny binding or persuasive value. 16. The Hon'ble Apex court in the case of Fibre Boards Pvt. Ltd and M/s. Shree Bhagwati Steel Rolling has doubted and disapproved its earlier decisions rendered in the case of Rayala Corporation (P) Ltd Vs Enforcement (1969) 2 SCR 412 and Kolhapur Cane Sugar Works Ltd Vs Union of India (2000) 2SCC536 and in the case of General Finance Company Vs CIT (2002) 7 SCC 1. Further, the Hon'ble Supreme Court in the case of Fibre Boards (I) Ltd, after referring to the provisions of Section 6A of the General Clauses Act held that "a repeal can be by way 15 Firemenich Aromatics (India) P…

Rayala Corporation (P) Ltd. v. Enforcement (2 SCR 412) — Cited in 13 Judgments | BharatTax