Reckitt Colman of India Ltd. v. ACIT

252 ITR 550High Court2001#6028 most cited

What is Reckitt Colman of India Ltd. v. ACIT authority for?

Documents previously accepted as correct can still be considered incriminating if circumstances suggest otherwise, especially when earlier conclusions were based on suppressed or misrepresented facts. This distinction is crucial between a mere change of opinion and a change of opinion based on fresh facts.

19

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2020 to 2025.

Also referred to as

Reckitt Colman of India Ltd. v. ACIT · 252 ITR 550 · incriminating documents · change of opinion · fresh facts · suppression of facts · misrepresentation of facts · Hayden's rule of mischief · voidable order

Sections most often in play

Section 143(3)Section 153ASection 36(1)(va)Section 132Section 132(1)Section 132(3)Section 132(4)Section 139

Issues it is cited on

section 132(3)section 2(45)section 271aabsection 22mere change of opinionsection 271aasection 132(1)section 270section 271asection 127commercial expediencychange of opinion

Judgments citing Reckitt Colman of India Ltd. v. ACIT

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

ITA 815/JPR/2025[2019-20]Status: DisposedITAT Jaipur23 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

…as correct, will not prevent such material or entry from being incriminating, if the circumstances suggest otherwise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550 (Cal). There is a distinction between a mere change of opinion and a change of opinion based on fresh facts. The latter would imply that the earlier conclusions of the AO were misled by placing evidence on suppression or misrepresentation of material facts. An order passed by the AO relying upon such make belief documents, which were later found…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

…as correct, will not prevent such material or entry from being incriminating, if the circumstances suggest otherwise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550 (Cal). There is a distinction between a mere change of opinion and a change of opinion based on fresh facts. The latter would imply that the earlier conclusions of the AO were misled by placing evidence on suppression or misrepresentation of material facts. An order passed by the AO relying upon such make belief documents, Professional Automotiv…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1, JAIPUR

ITA 809/JPR/2025[2013-14]Status: DisposedITAT Jaipur23 Jul 2025AY 2013-14
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

…correct, will not prevent such material or entry\nfrom being incriminating, if the circumstances suggest otherwise. The Hayden's\nrule of mischief has been judicially accepted and applied by Calcutta High Court\nin Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550 (Cal).\n\nThere is a distinction between a mere change of opinion and a change of opinion\nbased on fresh facts. The latter would imply that the earlier conclusions of the AO\nwere misled by placing evidence on suppression or misrepresentation of material\nfacts. An order passed by the AO relying upon such make belief documents,\nsuppressed or mi…

RAJESH PRODUCTS,TONK ,RAJASTHAN vs. ACIT, JAIPUR

Appeal is dismissed

ITA 626/JPR/2023[2016-17]Status: DisposedITAT Jaipur18 Jul 2024AY 2016-17
For Appellant: Shri Mahesh Jain, CA (Th. V.C)For Respondent: Shri Bhanwar Singh Ratnu, (CIT-DR)
Section 132(1)Section 132(4)Section 142(1)Section 143(2)Section 143(3)

…ccepted as correct, will not prevent such material or entry from being incriminating, the circumstances suggest otherwise. The Haydens rule of mischief has been judicially accepted and applied by Calcutta High Court in Reclatt Colman of India Ltd. ACIT (20011 252 ITR 550 (Cal) There is a distinction between a more change of opinion and a change of opinion base on fresh facts. The latter would imply that the earlier conclusions of the AD were misled by placing evidence on suppression or misrepresentation of material facts. An order passed by the AO relying upon such make belief documents, suppressed misrepresented…

ACIT, C.C. -4, JAIPUR vs. MAVERICK COMMODITY BROKERS PVT. LTD., JAIPUR

In the result appeals of the revenue are dismissed

ITA 27/JPR/2020[2014-15]Status: DisposedITAT Jaipur26 Sept 2022AY 2014-15
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the use of information collected in a survey in case of connected person carried along with search in other person for the…

ACIT,CC-4, JAIPUR vs. SHRI RAMESH KUMAR MANTRI, JAIPUR

In the result appeals of the revenue are dismissed and the cross

ITA 165/JPR/2020[2011-12]Status: DisposedITAT Jaipur26 Sept 2022AY 2011-12

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the CO No. 15 & 16/JP2020 & others ACIT vs. Sh. Ramesh Kumar Mantri use of information collected in a survey in case of c…

ACIT,CC-4, JAIPUR vs. SHRI RAMESH KUMAR MANTRI, JAIPUR

In the result appeals of the revenue are dismissed and the cross

ITA 164/JPR/2020[2010-11]Status: DisposedITAT Jaipur26 Sept 2022AY 2010-11

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the CO No. 15 & 16/JP2020 & others ACIT vs. Sh. Ramesh Kumar Mantri use of information collected in a survey in case of c…

ACIT, CC-4, , JAIPUR vs. SHRI ANSHUL JAIN, JAIPUR

In the result appeals of the revenue are dismissed

ITA 163/JPR/2020[2014-15]Status: DisposedITAT Jaipur26 Sept 2022AY 2014-15
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the use of information collected in a survey in case of connected person carried along with search in other person for the…

ACIT, CC-4, JAIPUR vs. SHRI MUKESH JAIN, JAIPUR

In the result appeals of the revenue are dismissed and the cross

ITA 162/JPR/2020[2011-12]Status: DisposedITAT Jaipur26 Sept 2022AY 2011-12

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the CO No. 15 & 16/JP2020 & others ACIT vs. Sh. Ramesh Kumar Mantri use of information collected in a survey in case of c…

ACIT, CC-4, JAIPUR vs. SHRI MUKESH JAIN, JAIPUR

In the result appeals of the revenue are dismissed and the cross

ITA 161/JPR/2020[2010-11]Status: DisposedITAT Jaipur26 Sept 2022AY 2010-11

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the CO No. 15 & 16/JP2020 & others ACIT vs. Sh. Ramesh Kumar Mantri use of information collected in a survey in case of c…

ACIT, CC-4, JAIPUR vs. SMT. SANGEETA MANTRI, JAIPUR

In the result appeals of the revenue are dismissed and the cross

ITA 160/JPR/2020[2011-12]Status: DisposedITAT Jaipur26 Sept 2022AY 2011-12

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the CO No. 15 & 16/JP2020 & others ACIT vs. Sh. Ramesh Kumar Mantri use of information collected in a survey in case of c…

ACIT, CC-4, JAIPUR vs. SMT. ASHA JAIN, JAIPUR

In the result appeals of the revenue are dismissed and the cross

ITA 159/JPR/2020[2011-12]Status: DisposedITAT Jaipur26 Sept 2022AY 2011-12

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the CO No. 15 & 16/JP2020 & others ACIT vs. Sh. Ramesh Kumar Mantri use of information collected in a survey in case of c…

ACIT, CC-4, JAIPUR vs. SMT. SUNITA AGARWAL, JAIPUR

In the result appeals of the revenue are dismissed

ITA 158/JPR/2020[2015-16]Status: DisposedITAT Jaipur26 Sept 2022AY 2015-16
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the use of information collected in a survey in case of connected person carried along with search in other person for the…

ACIT, CC-4, JAIPUR vs. SMT. SUNITA AGARWAL, JAIPUR

In the result appeals of the revenue are dismissed

ITA 157/JPR/2020[2014-15]Status: DisposedITAT Jaipur26 Sept 2022AY 2014-15
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the use of information collected in a survey in case of connected person carried along with search in other person for the…

ACIT, CC-4, JAIPUR vs. SMT. SUNITA AGARWAL, JAIPUR

In the result appeals of the revenue are dismissed and the cross

ITA 156/JPR/2020[2011-12]Status: DisposedITAT Jaipur26 Sept 2022AY 2011-12

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the CO No. 15 & 16/JP2020 & others ACIT vs. Sh. Ramesh Kumar Mantri use of information collected in a survey in case of c…

ACIT, CC-4, JAIPUR vs. SHRI MUKUT BEHARI AGARWAL, JAIPUR

In the result appeals of the revenue are dismissed

ITA 155/JPR/2020[2015-16]Status: DisposedITAT Jaipur26 Sept 2022AY 2015-16
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the use of information collected in a survey in case of connected person carried along with search in other person for the…

ACIT, CC-4, JAIPUR vs. SHRI MUKUT BEHARI AGARWAL, JAIPUR

In the result appeals of the revenue are dismissed and the cross

ITA 153/JPR/2020[2011-12]Status: DisposedITAT Jaipur26 Sept 2022AY 2011-12

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the CO No. 15 & 16/JP2020 & others ACIT vs. Sh. Ramesh Kumar Mantri use of information collected in a survey in case of c…

ACIT, CC-4, JAIPUR vs. SHRI MUKUT BEHARI AGARWAL, JAIPUR

In the result appeals of the revenue are dismissed and the cross

ITA 152/JPR/2020[2010-11]Status: DisposedITAT Jaipur26 Sept 2022AY 2010-11

…s correct, will not prevent such material or entry from being incriminating, if the circumstances suggest other wise. The Hayden's rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550(Cal). The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Aji S Kumar 93 Taxman.com 294(SC), the court in the context of section158BB has upheld the CO No. 15 & 16/JP2020 & others ACIT vs. Sh. Ramesh Kumar Mantri use of information collected in a survey in case of c…

DCIT, CENTRAL CIRCLE - 2(1), KOLKATA, KOLKATA vs. M/S. BHAVYA MERCHANDISE PVT. LTD., , KOLKATA

In the result, appeals by the revenue are dismissed and cross-objections by the assessee are allowed

ITA 2148/KOL/2017[2011-12]Status: DisposedITAT Kolkata18 Mar 2020AY 2011-12
For Appellant: Mr. R.P. Agarwal, Advocate &For Respondent: Mr. Imokaba Jamir, CIT DR
Section 132Section 143(2)Section 143(3)Section 153ASection 68Section 69C

…as correct, will not prevent such material or entry from being incriminating, if the circumstances suggest otherwise. The Hayden’s rule of mischief has been judicially accepted and applied by Calcutta High Court in Reckitt Colman of India Ltd. vs. ACIT (2001) 252 ITR 550 (Cal). 21. The incriminating material can be from the search or even from subsequent surveys or any other enquiries. Recently in CIT Chennai vs Ajit S Kumar 93 Taxman.com294(SC), the court in the context of section 158BB has upheld the use of information collected in a survey in case of connected person carried along with search in other person…

Reckitt Colman of India Ltd. v. ACIT (252 ITR 550) — Cited in 19 Judgments | BharatTax