Revenue, CIT v. Ahmedabad Manufacturing and Calico Printing Co. Ltd. 1976 CTR (Gui) 214

106 ITR 159High Court1977#9287 most cited

What is Revenue, CIT v. Ahmedabad Manufacturing and Calico Printing Co. Ltd. 1976 CTR (Gui) 214 authority for?

A reassessment proceeding is without jurisdiction if the Assessing Officer finds the grounds mentioned in the reassessment notice to be incorrect.

11

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2018 to 2025.

Also referred to as

CIT v. Ahmedabad Manufacturing and Calico Printing Co. Ltd. · reassessment · jurisdiction · grounds in notice · section 148 · section 147 · section 151

Issues it is cited on

section 148(1)borrowed satisfactionsundry creditorssection 151section 139(1)reassessment proceedingssection 139section 148section 147section 14nfac

Judgments citing Revenue, CIT v. Ahmedabad Manufacturing and Calico Printing Co. Ltd. 1976 CTR (Gui) 214

Income Tax Officer, Mohali Punjab vs. Taj Land Developefrs and Promoters Private Limited, Sector Mohali Punjab

In the result, appeal is dismissed

ITA 606/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh22 Sept 2025AY 2011-12

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 1Section 139Section 147Section 148Section 151

…milar view has been taken by the Rajasthan High Court in Addl. CIT vs. Ganeshilal Lal Chand (1984) 43 CTR (Rai) 120 : (1985) 154 ITR 274 (Raj)., On behalf of the Revenue, CIT vs. Ahmedabad Manufacturing and Calico Printing Co. Ltd. 1976 CTR (Gui) 214 : (1977) 106 ITR 159 (Gui), a decision of the Gujarat High Court was cited. On a consideration of the matter, we are of the view that in view of the aforesaid Supreme Court decisions, the view taken by the Rajasthan High Court is correct and the view taken by the Gujarat High Court is not correct. Accordingly, we dissent from the view taken by the Gujarat High Court…

Smt. Bharti Singh, Amritsar vs. Assistant Commissioner of Income Tax Circle-3, Amritsar

Appeals of the appellant are disposed of in the terms indicated as above

ITA 226/ASR/2023[2011-12]Status: DisposedITAT Amritsar21 Sept 2023AY 2011-12

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

For Appellant: Sh. Tarun Bansal, Adv. &
Section 139(1)Section 147Section 148Section 148(1)Section 151

…ilar view has been taken by the Rajasthan High Court in Addl. CIT vs. Ganeshilal Lal Chand (1984) 43 CTR (Rai) 120 : (1985) 154 ITR 274 (Raj). , On behalf of the Revenue, CIT vs. Ahmedabad Manufacturing and Calico Printing Co. Ltd. 1976 CTR (Gui) 214 : (1977) 106 ITR 159 (Gui), a decision of the Gujarat High Court was cited. On a consideration of the matter, we are of the view that in view of the aforesaid Supreme Court decisions, the view taken by the Rajasthan High Court is correct and the view taken by the Gujarat High Court is not correct. Accordingly, we dissent from the view taken by the Gujarat High Court…

Smt. Bharti Singh, Amritsar vs. Assistant Commissioner of Income Tax Circle-3, Amritsar

Appeals of the appellant are disposed of in the terms indicated as above

ITA 222/ASR/2023[2013-14]Status: DisposedITAT Amritsar21 Sept 2023AY 2013-14

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

For Appellant: Sh. Tarun Bansal, Adv. &
Section 139(1)Section 147Section 148Section 148(1)Section 151

…ilar view has been taken by the Rajasthan High Court in Addl. CIT vs. Ganeshilal Lal Chand (1984) 43 CTR (Rai) 120 : (1985) 154 ITR 274 (Raj). , On behalf of the Revenue, CIT vs. Ahmedabad Manufacturing and Calico Printing Co. Ltd. 1976 CTR (Gui) 214 : (1977) 106 ITR 159 (Gui), a decision of the Gujarat High Court was cited. On a consideration of the matter, we are of the view that in view of the aforesaid Supreme Court decisions, the view taken by the Rajasthan High Court is correct and the view taken by the Gujarat High Court is not correct. Accordingly, we dissent from the view taken by the Gujarat High Court…

Smt. Bharti Singh, Amritsar vs. Assistant Commissioner of Income Tax Circle-3, Amritsar

Appeals of the appellant are disposed of in the terms indicated as above

ITA 221/ASR/2023[2012-13]Status: DisposedITAT Amritsar21 Sept 2023AY 2012-13

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

For Appellant: Sh. Tarun Bansal, Adv. &
Section 139(1)Section 147Section 148Section 148(1)Section 151

…ilar view has been taken by the Rajasthan High Court in Addl. CIT vs. Ganeshilal Lal Chand (1984) 43 CTR (Rai) 120 : (1985) 154 ITR 274 (Raj). , On behalf of the Revenue, CIT vs. Ahmedabad Manufacturing and Calico Printing Co. Ltd. 1976 CTR (Gui) 214 : (1977) 106 ITR 159 (Gui), a decision of the Gujarat High Court was cited. On a consideration of the matter, we are of the view that in view of the aforesaid Supreme Court decisions, the view taken by the Rajasthan High Court is correct and the view taken by the Gujarat High Court is not correct. Accordingly, we dissent from the view taken by the Gujarat High Court…

Preeti Bajaj, Ludhiana vs. Dy Commissioner of Income Tax, Ludhiana

In the result, both the captioned appeals of the assessees are hereby allowed

ITA 172/CHANDI/2017[2001-02]Status: DisposedITAT Chandigarh24 Jan 2019AY 2001-02

Bench: The Itat On 08.08.2017 Which Led To The Disposal Of The Appeals For Non- Representation Was On Account Of The Bonafide Belief That The Itas 171 & 172/Chd/2017 Page 2 Of 5

For Appellant: Shri Saarbjit Garg, CAFor Respondent: Shri Manjit Singh, Sr.DR
Section 147Section 254(2)

…R 11 and Bankipur Club Ltd. v. CIT [1971] 82 ITR 831. Similar view has been taken by the Rajasthan High Court in Addl. CIT v. Ganeshilal Lal Chand [1985] 154 ITR 274. On behalf of the Revenue, CIT v. Ahmedabad Manufacturing and Calico Printing Co. Ltd. [1977] 106 ITR 159, a decision of the Gujarat High Court was cited. On a consideration of the matter, we are of the view that in view of the aforesaid Supreme Court decisions, the view taken by the Rajasthan High Court is correct and the view taken by the Gujarat High ITAs 171 & 172/CHD/2017 Page 4 of 5 Court is not, correct. Accordingly, we dissent from the vie…

Nirmal Bajaj, Ludhiana vs. Dy Commissioner of Income Tax, Ludhiana

In the result, both the captioned appeals of the assessees are hereby allowed

ITA 171/CHANDI/2017[2001-02]Status: DisposedITAT Chandigarh24 Jan 2019AY 2001-02

Bench: The Itat On 08.08.2017 Which Led To The Disposal Of The Appeals For Non- Representation Was On Account Of The Bonafide Belief That The Itas 171 & 172/Chd/2017 Page 2 Of 5

For Appellant: Shri Saarbjit Garg, CAFor Respondent: Shri Manjit Singh, Sr.DR
Section 147Section 254(2)

…R 11 and Bankipur Club Ltd. v. CIT [1971] 82 ITR 831. Similar view has been taken by the Rajasthan High Court in Addl. CIT v. Ganeshilal Lal Chand [1985] 154 ITR 274. On behalf of the Revenue, CIT v. Ahmedabad Manufacturing and Calico Printing Co. Ltd. [1977] 106 ITR 159, a decision of the Gujarat High Court was cited. On a consideration of the matter, we are of the view that in view of the aforesaid Supreme Court decisions, the view taken by the Rajasthan High Court is correct and the view taken by the Gujarat High ITAs 171 & 172/CHD/2017 Page 4 of 5 Court is not, correct. Accordingly, we dissent from the vie…

Shri Gaurav Joshi, Jalandhar vs. Income Tax Oficer Ward-1(5), Jalandhar

In the result, the appeal of the assessee is allowed

ITA 274/ASR/2018[2010-11]Status: DisposedITAT Amritsar16 Jan 2019AY 2010-11

Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.274/Asr./2018 : Asstt. Year : 2010-11 Sh. Gaurav Joshi, Vs Income Tax Officer, C/O Sh. Ashray Sarna, Adv., B- Ward-1(5), 18, Vakil Building, Model Jalandhar Town Road, Jalandhar (Appellant) (Respondent) Pan No. Amjpj3603P Assessee By : Sh. Ashray Sarna, Ca. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 10.01.2019 Date Of Pronouncement : 16.01.2019

For Appellant: Sh. Ashray Sarna, CAFor Respondent: Sh. Bhawani Shankar, DR
Section 143(3)Section 147Section 148Section 69

…ilar view has been taken by the Rajasthan High Court in Addl. CIT vs. Ganeshilal Lal Chand (1984) 43 CTR (Rai) 120 : (1985) 154 ITR 274 (Raj). , On behalf of the Revenue, CIT vs. Ahmedabad Manufacturing and Calico Printing Co. Ltd. 1976 CTR (Gui) 214 : (1977) 106 ITR 159 (Gui), a decision of the Gujarat High Court was cited. On a consideration of the matter, we are of the view that in view of the aforesaid Supreme Court decisions, the view taken by the Rajasthan High Court is correct and the view taken by the Gujarat High Court is not correct. Accordingly, we dissent from the view taken by the Gujarat High Court…

Smt. L Sudha Bala, L/R of Late Sri L.Narsa Reddy, Guntur vs. The DCIT, Special Range Guntur, Guntur

In the result, the appeals of the assessee are dismissed

ITA 261/VIZ/2012[1985-86]Status: DisposedITAT Visakhapatnam07 Dec 2018AY 1985-86

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.260 & 261/Viz/2012 (धििाारण िर्ा/ Assessment Years :1984-85 & 1985-86 Respectively) L.Sudha Bala Vs. Dy.Commissioner Of L/R Of Late Sri L Narasa Reddy Income Tax Prop.Sri Venkateswara Agro Chemicals Special Range Industries Guntur 2-14-101, Syamala Nagar 2Nd Lane, Guntur [Pan : Acgpl2351P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri C.Subrahmanyam, ARFor Respondent: Smt. Suman Malik, DR
Section 143(3)Section 147Section 148Section 40A(3)

…asad (1996) 133 CTR 410 (MP) : (1996) 219 ITR 441 (MP); and (viii) CIT vs. Bihar Cotton Mills Ltd. (1986) 160 ITR 275 (Pat): (1986) 54 CTR 53 (Pat). 5.6. The Gujarat High Court, in the case of CIT vs. Ahmedabad Mfg. Calico Printing Co. LW., reported in (1977) 106 ITR 159 (Guj), has expressed the view that even when it is held that the ground on which reassessment initiated was found to be not surviving, the reassessment could still be completed in respect of other items of escapement of income found subsequently during the course of proceedings under section 147. The Honourable Gujarat High court in another case…

Smt. L Sudha Bala, L/R of Late Sri L.Narsa Reddy, Guntur vs. The DCIT, Special Range Guntur, Guntur

In the result, the appeals of the assessee are dismissed

ITA 260/VIZ/2012[1984-85]Status: DisposedITAT Visakhapatnam07 Dec 2018AY 1984-85

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.260 & 261/Viz/2012 (धििाारण िर्ा/ Assessment Years :1984-85 & 1985-86 Respectively) L.Sudha Bala Vs. Dy.Commissioner Of L/R Of Late Sri L Narasa Reddy Income Tax Prop.Sri Venkateswara Agro Chemicals Special Range Industries Guntur 2-14-101, Syamala Nagar 2Nd Lane, Guntur [Pan : Acgpl2351P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri C.Subrahmanyam, ARFor Respondent: Smt. Suman Malik, DR
Section 143(3)Section 147Section 148Section 40A(3)

…asad (1996) 133 CTR 410 (MP) : (1996) 219 ITR 441 (MP); and (viii) CIT vs. Bihar Cotton Mills Ltd. (1986) 160 ITR 275 (Pat): (1986) 54 CTR 53 (Pat). 5.6. The Gujarat High Court, in the case of CIT vs. Ahmedabad Mfg. Calico Printing Co. LW., reported in (1977) 106 ITR 159 (Guj), has expressed the view that even when it is held that the ground on which reassessment initiated was found to be not surviving, the reassessment could still be completed in respect of other items of escapement of income found subsequently during the course of proceedings under section 147. The Honourable Gujarat High court in another case…

Nirmal Bajaj, Ludhiana vs. DCIT, Ludhiana

ITA 1243/CHANDI/2010[2001-02]Status: DisposedITAT Chandigarh09 Jul 2018AY 2001-02
Section 147

…attention to the impugned order of the Assessing officer to show that neither the assessee was confronted with any such evidence of any ITA Nos. 1242 & 1243/Chd/2010- Preeti Bajaj & Nirmal Bajaj, Ludhiana 4 Manufacturing and Calico Printing Co. Ltd. [1977] 106 ITR 159, a decision of the Gujarat High Court was cited. On a consideration of the matter, we are of the view that in view of the aforesaid Supreme Court decisions, the view taken by the Rajasthan High Court is correct and the view taken by the Gujarat High Court is not, correct. Accordingly, we dissent from the view taken by the Gujarat High Court and i…

Preet Bajaj, Ludhiana vs. DCIT, Ludhiana

ITA 1242/CHANDI/2010[2001-02]Status: DisposedITAT Chandigarh09 Jul 2018AY 2001-02
Section 147

…attention to the impugned order of the Assessing officer to show that neither the assessee was confronted with any such evidence of any ITA Nos. 1242 & 1243/Chd/2010- Preeti Bajaj & Nirmal Bajaj, Ludhiana 4 Manufacturing and Calico Printing Co. Ltd. [1977] 106 ITR 159, a decision of the Gujarat High Court was cited. On a consideration of the matter, we are of the view that in view of the aforesaid Supreme Court decisions, the view taken by the Rajasthan High Court is correct and the view taken by the Gujarat High Court is not, correct. Accordingly, we dissent from the view taken by the Gujarat High Court and i…

Revenue, CIT v. Ahmedabad Manufacturing and Calico Printing Co. Ltd. 1976 CTR (Gui) 214 (106 ITR 159) — Cited in 11 Judgments | BharatTax