How many judgments cite Raymond Woolens Mills Ltd. v. ITO and Other?

25 judgments on BharatTax cite Raymond Woolens Mills Ltd. v. ITO and Other (241 ITR 856), spanning 2015 to 2026.

Which sections of the Income Tax Act does Raymond Woolens Mills Ltd. v. ITO and Other come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 144, Section 69A, Section 132, Section 142(1).

Raymond Woolens Mills Ltd. v. ITO and Other

241 ITR 856High Court2000#4648 most cited

What is Raymond Woolens Mills Ltd. v. ITO and Other authority for?

Information obtained during the assessment proceedings of a subsequent assessment year can be used to reopen a completed assessment. A mere change of opinion by the Assessing Officer is not sufficient grounds to reopen a case.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2015 to 2026.

Also referred to as

Raymond Woolens Mills Ltd v ITO · Revathy C.P. Equipments Ltd v DCIT · 241 ITR 856 · reopening assessment · subsequent year information · change of opinion · material facts · income escaping assessment

Sections most often in play

Section 147 Section 148 Section 144 Section 69A Section 132 Section 142(1)Section 144B Section 151

Issues it is cited on

within four years full and true disclosure material facts necessary for assessment mere change of opinion change of opinion kelvinator tangible material live link income escaping assessment escapement of income reason to believe liable to tax

Judgments citing Raymond Woolens Mills Ltd. v. ITO and Other

Natharam Panaji Choudhary, Pune vs. I.T.O. Ward 8(1), Pune

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1826/PUN/2024[2016-17]Status: DisposedITAT Pune21 Jan 2026AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Bharat Kumar (Virtually)For Respondent: Shri Amol Khairnar

Section 132Section 142(1)Section 147Section 148Section 69A

…ention that information obtained in assessment proceedings of subsequent year, can also be utilized for reopening of the completing assessment refer Raymond Woolens Mills Ltd. vs. ITO and Other 236 ITR 34 (SC) and Revathy C.P. Equipment Ltd. vs. DCIT AND ors. 241 ITR 856 (Mad). 4.3.4 In the interest of natural justice, the Assessing officer has given several opportunities of hearing have been provided to the appellant to submit explanation / evidence. In the present proceedings also, the appellant has not filed any evidence for the nature and sources of the cash deposits made during the financial year under consi…

Natharam Panaji Choudhary, Pune vs. I.T.O. Ward 8(1), Pune

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1823/PUN/2024[2015-16]Status: DisposedITAT Pune21 Jan 2026AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Bharat Kumar (Virtually)For Respondent: Shri Amol Khairnar

Section 132Section 142(1)Section 147Section 148Section 69A

Kajal Batra, Delhi vs. ACIT, Circle-52(1), Delhi

In the result, the appeal of the assessee stands dismissed as above

ITA 2419/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 151Section 68Section 69A

…ons and facts of the case there is no question of change of opinion as upheld by the jurisprudence as under- 1. A.L.A. Firm Vs. CIT(Mad) 102 ITR 622 2. Ess Kay Engineering Co. (P) Ltd. Vs CIT(SC) 247 ITR 818 3. Revathy C.P. Equipments Ltd. Vs DCIT& Ors. (Mad) 241 ITR 856 4. EMAIndia Ltd. Vs ACIT(All) 30 DTR 82 h. It is worthwhile to mention that the argument of change of opinion comes to rescue of assessee only when Assessing Officer has taken one of permissible views at the time of original proceedings. A wrong application of law cannot be held as permissible view and that can always be changed for appreciating…

Mack Star Marketing Private Limited, Mumbai vs. Deputy Commissioner of Income Tax 2(2)(1), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 4994/MUM/2024[2013-14]Status: DisposedITAT Mumbai21 Jan 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mr. Yash VarmaniFor Respondent: Mr. R.R. Makwana, Sr. DR

Section 144BSection 147

…tained in assessment proceedings of subsequent assessment year can also be utilized for reopening of the completed assessment (Raymond Woolen Mills Ltd. v. ITO & Others 236 ITR 34 (SC) and Revathy Cp Equipment Ltd. vs Deputy Commissioner of Income-tax and Ors.241 ITR 856 (Mad.) 8.2 Further, the Ld. counsel of the assessee has referred to inquiries made by the Assessing Officer in original assessment proceeding on the issue of examination of share capital and security premium. The Assessing Officer had issued a notice under section 142(1) of the Act on 09/08/2011 asking the assessee to furnish details of increase…

M/S Man Diesel & Turbo India Ltd., Maharashtra vs. DCIT, New Delhi

In the result, assessee’s appeal is hereby dismissed

ITA 4295/DEL/2015[2003-04]Status: DisposedITAT Delhi20 Aug 2024AY 2003-04

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singha.Y. 2003-04

Section 143(3)Section 147Section 148Section 250

…was arrived at during the course of the original assessment proceedings, therefore, there is no question of change of opinion. Relaince is placed on Ess Kay Engineering Co. (P) Ltd. vs. CIT (SC) 247 ITR 818, Revathy C.P. Equipments Ltd. vs. DCIT & Ors. (Mad) 241 ITR 856 and EMA India Ltd. vs. ACIT (All) 30 DTR 82 5.1.6 In the case of M/s Consolidated Photo & Finvest Ltd. vs. ACIT 2006 (151 Taxman 41 Del). Hon'ble Delhi High Court has held that even if the assessing officer gathered a reason to believe from the very same records as had been subject matter of completed assessment proceedings, still notice u/s 148…

DCIT 13(1)(2), Mumbai vs. Pebble Bay Developers P.Ltd, Mumbai

In the result, appeal of the In the result, appeal of the Revenue is allowed for statistical purposes, is allowed for statistical purposes, whereas the application of the assessee under rule 27 is ...

ITA 5744/MUM/2017[2008-09]Status: DisposedITAT Mumbai21 Oct 2022AY 2008-09

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2008-09 Dy. Commissioner Of Income- M/S Pebble Bay Developers Tax-13(1)(2), Pvt. Ltd., 2Nd Floor, Room No. 218, Vs. Raheja Chambers, Linking Aayakar Bhavan, M.K. Road, Road, Main Avenue Santacruz Mumbai-400020. (West), Mumbai-400054. Pan No. Aaccg 1645 E Appellant Respondent Revenue By : Ms. Vranda Matkari, Dr Assessee By : Mr. Nishit Gandhi, Ar Date Of Hearing : 26/08/2022 Date Of Pronouncement : 21/10/2022

For Appellant: Mr. Nishit Gandhi, ARFor Respondent: Ms. Vranda Matkari, DR

Section 143(1)Section 148Section 69C

…nt - refer Raymond Woolens Mills Ltd. vs. ITO and other 236 ITR refer Raymond Woolens Mills Ltd. vs. ITO and other 236 ITR refer Raymond Woolens Mills Ltd. vs. ITO and other 236 ITR 34 (SC) and Revathy 34 (SC) and Revathy C.P. Equipment Ltd. vs. DCIT and Ors. 241 ITR 856 C.P. Equipment Ltd. vs. DCIT and Ors. 241 ITR 856 (Mad). 4.9. It is further noted that the reasons recorded were furnished to the further noted that the reasons recorded were furnished to the further noted that the reasons recorded were furnished to the appellant on 29.12.2015. The assessment order has been passed on appellant on 29.12.2015. The…

ACIT Central Circle 2(1), Chennai vs. Cavinkare Pvt. Ltd., Chennai

Appeal stand allowed

ITA 1076/CHNY/2018[2008-09]Status: DisposedITAT Chennai19 Oct 2022AY 2008-09

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Banusekar (C.A) – Ld. ARFor Respondent: Shri ARV Sreeenivasan (Addl. CIT) –Ld. DR

Section 143(3)Section 147Section 148Section 149Section 151Section 36(1)(iii)

…to make re-assessment, which decision is squarely applicable to the facts and circumstances of this case. 2.5. Having regard to the decision rendered by the Jurisdictional Hon'ble High Court of Madras in the case of Revathy C P Equipment Ltd., Vs DCIT [2000] 241 ITR 856 (Madras), wherein it has been held that information found during the subsequent assessment year/s can be a reason for re-opening the assessment for an earlier year u/s.147 of the IT Act, ought to have upheld the decision of the AO to re-open the assessment for the AY 2008-09 in the assessee's case. 3. For these grounds and any other ground includ…

ITO 1(2)(3), Mumbai vs. M Pallonji Enerprises P. Ltd, Mumbai

In the result, the appeal of the In the result, the appeal of the Revenue is dismissed whereas dismissed whereas cross objection of the assessee is allowed

ITA 1907/MUM/2017[2009-10]Status: DisposedITAT Mumbai13 Oct 2022AY 2009-10

Bench: Shri Amit Shukla () & Shri Om Prakash Kant () Assessment Year: 2009-10 Ito-1(2)(3), M/S M Pallonji Enterprises Pvt. Ltd., R. No. 527, 5Th Floor, Aayakar 46/A, Cawasji Patel Street, Fort, Bhavan, M.K. Road, Vs. Mumbai-400020. Mumbai-400020. Pan No. Aafcm 3357 A Appellant Respondent

For Appellant: Dr. K. Shivaram, Sr. Adv. &For Respondent: Mr. T. Shankar, CIT-DR

Section 68

…6 ITR (Raymond Woolen Mills Ltd. v. ITO & Others 236 ITR 34 34 34 (SC) (SC) (SC) and and and Revathy Revathy Revathy Cp Cp Cp Equipment Equipment Equipment Ltd. Ltd. Ltd. vs vs vs Deputy Deputy Deputy Commissioner of Income Commissioner of Income-tax and Ors. 241 ITR 856 (Mad.) tax and Ors. 241 ITR 856 (Mad.) 8.2 Further, the Ld. counsel Ld. counsel of the assessee has referred to ssee has referred to inquiries made by the Assessing Officer in original assessment inquiries made by the Assessing Officer in original assessment inquiries made by the Assessing Officer in original assessment proceeding on the issue o…

Shri Amit Mangilal Jain, Mumbai vs. ACIT, - 33(1), Mumbai

In the result, the appeals filed by the assessee are dismissed and the appeals filed by the revenue are allowed for statistical purposes

ITA 3331/MUM/2019[2009-10]Status: HeardITAT Mumbai24 Aug 2022AY 2009-10

Bench: Shri Pramod Kumar & Shri Pavan Kumar Gadaleita No. 3331 & 3332/Mum/2019 (A.Ys: 2009-10 & 2010-11) Shri Amit Mangilal Jain Vs. Acit – 33(1) 2Nd Floor, Arkade House, 103, 1St Floor, Atmaram Sawnt Marg, Eastern House, Kandivali (E), Nariman Point, Mumbai – 400101. Mumbai – 400021. Pan/Gir No. : Aabpj0925G Appellant .. Respondent

For Appellant: Shri Naresh JainFor Respondent: Shri Krishna Kumar.DR

Section 131Section 143(2)Section 143(3)Section 147Section 148Section 153C

…ention that information obtained in assessment proceedings of subsequent year, can also be utilized for reopening of the completing assessment refer Raymond Woolens Mills Ltd. vs. ITO and Other 236 ITR 34 (SC) and Revathy C.P. Equipment Ltd. vs. DCIT AND ors. 241 ITR 856 (Mad). ITA Nos. 3331, 3332, 4158 & 4159/Mum/2019 Shri Amit Mangilal Jain., Mumbai. 3.6 In the present case, however, there is information obtained by conducting search action in Bhoomi Group. Information was that the assessee's name was found as one of the investor in the Bridge Land in Kandivali and this information was tangible based on which…

M/S. Satyam Realtors P. Ltd., Mumbai vs. Dy CIT CC-5(4)Dy CIT CC-5(4), Mumbai

In the result, appeal by the assessee stands partly allowed

ITA 552/MUM/2021[2013-14]Status: DisposedITAT Mumbai25 Mar 2022AY 2013-14

Bench: Shri Shamim Yahya

Section 147Section 148Section 234B

…ntion that information obtained in assessment proceedings of subsequent year, can also be utilized for reopening of the completing assessment -refer Raymond Woolens Mills Ltd. vs. ITO and Other 236 ITR 34 (SC) and Revathy C.P. Equipment Ltd. vs. DCIT AND ors. 241 ITR 856 (Mad). It is further noted that the reasons recorded were furnished to the appellant on 28.09.2018 no objection was filed against the reopening till after the assessing officer issued final show cause notice dated 24-11-2018 when assessment was getting barred 4 by limitation on 31.12.2018. In the light of these facts and discussions earlier, I…

Nitan Chhatwal, Mumbai vs. DCIT CC -5(4), Mumbai

In the result, the appeal of the assessee in ITA

ITA 6422/MUM/2019[2011-12]Status: DisposedITAT Mumbai25 Oct 2021AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shri Ravish Sood, Jm

For Appellant: Shri Rahul RamanFor Respondent: Shri Mani Jain

Section 132Section 143(3)Section 147Section 148Section 148(2)Section 14A

…ention that information obtained in assessment proceedings of subsequent year, can also be utilized for reopening of the completing assessment -refer Raymond Woolens Mills Ltd. vs. ITO and Other 236 ITR 34 (SC) and Revathy C.P/Equipment Ltd. vs. DCIT AND ors. 241 ITR 856 (Mad). 4.11. It is further noted that the reasons recorded were furnished to the appellant on 28.09.2018 no objection was filed against the reopening till after the assessing officer issued final show cause notice dated 18.12.2018 when assessment was getting barred by limitation on 31,12,2018. In the light of these facts and discussions earlier,…

DCIT-CC-5(4), Mumbai vs. Shri Nitan Chhatwal, Mumbai

In the result, the appeal of the assessee in ITA

ITA 6351/MUM/2019[2011-12]Status: DisposedITAT Mumbai25 Oct 2021AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shri Ravish Sood, Jm

For Appellant: Shri Rahul RamanFor Respondent: Shri Mani Jain

Section 132Section 143(3)Section 147Section 148Section 148(2)Section 14A

Sterling Jewels Pvt. Ltd., Mumbai vs. ACIT 5(3)(2), Mumbai

In the result, appeal filed by the assessee for AY 2009-10 is dismissed

ITA 6154/MUM/2016[2009-10]Status: DisposedITAT Mumbai03 Oct 2019AY 2009-10

Bench: Shri G. Manjunatha & Shri Ram Lal Negiita No.6154, 6155, 6156, 6157 & 6158/Mum/2016 (Assessment Years: 2009-10, 2010-11, 2011-12, 2012-13 & 2013-14) Sterling Jewels Pvt.Ltd. Vs. Acit-5(3)(2) 208, A-Z Industrial Estate 460, Aaykar Bhawan Ganpatrao Kadam Marg M.K.Road, Churchgate Lower Parel (W) Mumbai-400 020 Mumbai-400 013 Pan/Gir No.Aajcs3316D (Appellant) .. (Respondent)

Section 143(1)Section 143(3)Section 147Section 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL “G”, BENCH MUMBAI BEFORE SHRI G. MANJUNATHA, ACCOUNTANT MEMBER & SHRI RAM LAL NEGI, JUDICIAL MEMBER ITA No.6154, 6155, 6156, 6157 & 6158/Mum/2016 (Assessment Years: 2009-10, 2010-11, 2011-12, 2012-13 & 2013-14) Sterling Jewels Pvt.Ltd. Vs. ACIT-5(3)(2) 208, A-Z Industrial Estate 460, Aaykar Bhawan Ganpatrao Kadam Marg M.K.Road, Churchgate Lower Parel (W) Mumbai-400 020 Mumbai-400 013 PAN/GIR No.AAJCS3316D (Appellant) .. (Respondent) Assessee by K.A.Vaidyalingan Revenue by V.Vinod Kumar Date of Hearing 03/10/2019 Date of Pronouncement 03/10/2019 आदेश / O R D E R आदेश आ…

ITO, New Delhi vs. M/S. Superior Films (P) Ltd., New Delhi

Appeal are dismissed; accordingly, Revenue’s appeal is

ITA 4938/DEL/2012[2004-05]Status: DisposedITAT Delhi31 Jul 2019AY 2004-05

Bench: Shri Bhavnesh Saini & Shri Anadee Nath Misshra

For Appellant: Shri Gurjit Batra and Shri S.M. Mathur, CAFor Respondent: Shri N.K. Bansal, Sr. Dr

Section 143(3)Section 147Section 148

…during the course of the original assessment proceedings there is no question of change of opinion:- i) A.L.A. Firm Vs CIT (Mad) 102 ITR 622 ii) Ess Kay Engineering Co. (P) Ltd. Vs CIT (SC) 247 ITR 818 iii) Revathy C.P. Equipments Ltd. Vs DCIT & Ors. (Mad) 241 ITR 856 iv) EMA India Ltd. Vs ACIT (AH) 30 DTR 82 3. 3. It was held in following judgement that change of opinion comes to rescue of 3. 3. assessee only when Assessing Officer has taken one of permissible views at the time of original proceedings and that a wrong application of law cannot be held as permissible view and that can always be changed for ap…

Tanaya Gems & Jewellery Exports Ltd, Mumbai vs. DCIT 5(3)(2), Mumbai

Accordingly confirm the addition. The ground is dismissed

ITA 3196/MUM/2017[2007-08]Status: DisposedITAT Mumbai24 Jun 2019AY 2007-08

Bench: Hon’Ble Sh. Sandeep Gosain, Jm & Hon’Ble Sh. G. Manjunatha, Am आयकरअपीलसं./ I.T.A. No. 3196/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2007-08)

For Appellant: NoneFor Respondent: Shri D. G. Pansari, DR

Section 143(3)Section 234Section 234ASection 271Section 271(1)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE HON’BLE SH. SANDEEP GOSAIN, JM & HON’BLE SH. G. MANJUNATHA, AM आयकरअपीलसं./ I.T.A. No. 3196/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2007-08) DCIT-5(3)(2), M/s Tanaya Gems & Jewellery Mumbai, Exports Ltd. बिधम/ 5th floor, 52 Marble Arch, Dr. Pin- Vs. G. D. Deshmukh Marg, Peddar Road, Mumbai-400 026 स्थायीलेखासं./जीआइआरसं./ PAN No. AACCT5863H (अपीलाथी/Appellant) (प्रत्यथी / : Respondent) अपीलाथीकीओरसे/ Appellant by : None प्रत्यथीकीओरसे/Respondentby : Shri D. G. Pansari, DR सुनवाईकीतारीख/ : 02.04.2019 Date of Hearing घोषणाकीतारीख / : 24.06.2019 Date o…

Assistant Commissioner of Income Tax 23(1), Mumbai vs. Calvin Properties, Mumbai

ITA 6561/MUM/2017[2011-12]Status: DisposedITAT Mumbai03 Apr 2019AY 2011-12

Bench: Hon’Ble Sh. Sandeep Gosain, Jm & Hon’Ble Sh. N. K. Pradhan, Am आयकरअपीलसं./ I.T.A. No. 6561, 6562 & 6564/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2011-12, 2012-13 & 2013-14)

For Appellant: Shri Abi Rama KarthikeyanFor Respondent: Shri Rajiv Khandelwal, AR

Section 143(1)Section 148Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE HON’BLE SH. SANDEEP GOSAIN, JM & HON’BLE SH. N. K. PRADHAN, AM आयकरअपीलसं./ I.T.A. No. 6561, 6562 & 6564/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2011-12, 2012-13 & 2013-14) M/s Calvin Properties, ACIT Cir 23(1) R. No. 113, 1st floor, 14, Gitanjali, Plot No. 234, बिधम/ Patkarwadi, S. V. Road, Matru Mandit, Tardeo Vs. Bandra (west), Road, Mumbai-400 007 Mumbai-400 050 स्थायीलेखासं./जीआइआरसं./ PAN No. AAGFC2218L (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant : Shri Abi Rama Karthikeyan, DR by प्रत्यथीकीओरसे/Respondentby : Shri…

Ramya Steel Syndicate, Vijayawada vs. ITO, Ward-1(2), Vijayawada

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

ITA 526/VIZ/2017[2008-09]Status: DisposedITAT Visakhapatnam26 Sept 2018AY 2008-09

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.526 /Viz/2017 (धििाारण िर्ा/ Assessment Year: 2008-2009) M/S Ramya Steel Syndicate Vs. Ito, Ward-1(2) Plot No.21A & 21B Vijayawada Iron Complex Bhavanipuram Vijayawada [Pan :Aacfr7326L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri K.C.Das, DR

Section 143(3)Section 148

…of change of opinion in such circumstances. The above decision was held in the following cases: (i) L.A. Firm Vs. CIT (Med) 102 ITR 622. (ii) Ess Kay Engineering Co. (P) Ltd. Vs. CIT (SC) 247 ITR 516. (iii) Revathy C.P. Equipments Ltd. Vs. DC!T & Ors, (Mad) 241 ITR 856. (iv) EMA India Ltd. Vs. ACIT (AU) 30 DTR 82. 5.2.2. Appellant cannot rake up issue of reopening once assesses participated in the reassessment proceedings after receipt of order passed by Assessing Officer rejecting his objections towards reopening. This view was held in the case of Sushil Kumar Jalan Vs ITO in I.T.A. No.34/Gau/2011 by Hon’ble G…

The Dy. CIT, Circle - 2(1), Vijayawada vs. Sri C.D.S.Prakasa Rao, L/H. C.D.V. Subba Rao, Vijayawada

In the result, appeal of the revenue is allowed for statistical purpose

ITA 44/VIZ/2013[2006-07]Status: DisposedITAT Visakhapatnam04 Jul 2018AY 2006-07

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.44/Viz/2013 (धििाारण िर्ा/Assessment Year:2006-07) Dy.Cit, Circle-2(1) Vs. C.D.V. Subba Rao Vijayawada Lr Of Late C.D.S. Prakasa Rao Prop.Prakash Arts, [Pan :Adapc2488D] Museum Road Governorpet Vijayawada [Pan : Adkpc7450P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलार्थी की ओर से/ Appellant By : Shri R.S.Aravindakshan, Dr प्रत्यार्थी की ओर से/ Respondent By : Shri G.V.N.Hari, Ar

For Appellant: Shri R.S.Aravindakshan, DRFor Respondent: Shri G.V.N.Hari, AR

Section 143(3)Section 147Section 148Section 436oSection 43B

…urse of original assessment proceedings. c. Reliance is placed on the following judicial pronouncements. (i) ALA Firm vs CIT (Mds) 102 ITR 622 Ess Kay Engineering Co. (P) Ltd vs CIT (SC) 247 ITR 818 (ii) (iii) Revathy C.P. Equipments Ltd. Vs. DCIT & Ors (Mad) 241 ITR 856 (W) EMA India Ltd. Vs ACIT(All) 30 DTR 82 d. The Ld. CIT(A) ought to have not struck down the reassessment proceedings as it transpires from the record that the liability of service tax is not allowable u/s436of the Act and on this tangible material available on record only, the AO formed a belief that income chargeable to tax has escaped assessm…

DCIT, Chennai vs. Florind Shoes (P) Ltd., Chennai

In the result, the appeal of the Revenue is allowed for statistical purpose

ITA 820/CHNY/2014[2003-04]Status: DisposedITAT Chennai12 May 2017AY 2003-04

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.265 & 820/Mds/2014 "नधा+रण वष+ /Assessment Year: 2003-04

For Respondent: 13.03.2017

Section 143(3)Section 147Section 148

…of the original assessment proceedings, there is no question of change of opinion, as held by several courts, like - • A.L.A. Firm Vs CIT 102 ITR 622 (Mad), • Ess Kay Engineering Co (P) Ltd. Vs CIT 247 ITR 818 (SC) • Revathy C.P. Equipments Ltd. Vs DCLT & Ors 241 ITR 856 (Mad) • EMA India Ltd. Vs ACIT 3ODTR 82 (All) Change of opinion comes to rescue of assessee only when Assessing Officer has taken one of permissible views at the time of original proceedings. A wrong application of law cannot be held as permissible view and that can always be changed for appreciating law, as held by Kolkata bench of ITAT in the…

Floring Shoes P Ltd., Chennai vs. DCIT, Chennai

In the result, the appeal of the Revenue is allowed for statistical purpose

ITA 265/CHNY/2014[2003-04]Status: DisposedITAT Chennai12 May 2017AY 2003-04

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.265 & 820/Mds/2014 "नधा+रण वष+ /Assessment Year: 2003-04

For Respondent: 13.03.2017

Section 143(3)Section 147Section 148