Saheli Synthetics (P) Ltd. v. CIT

302 ITR 126High Court2008#5255 most cited

What is Saheli Synthetics (P) Ltd. v. CIT authority for?

An Assessing Officer cannot enhance income beyond what was originally assessed when giving effect to a set-aside order, unless specifically directed by the appellate authority. The powers of an appellate authority are confined to the subject matter of the appeal.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2025.

Also referred to as

Saheli Synthetics v. CIT · assessment order · set aside · AO enhancement · section 251 · appellate powers · subject matter of appeal

Sections most often in play

Section 43BSection 132Section 143(3)Section 147Section 148Section 14ASection 153ASection 251(2)

Issues it is cited on

section 80lasection 251(2)extension of limitationdeduction u/s 80iaeligible businessrule of consistencysection 260asection 251section 80iasection 80isection 40(a)(ia)section 149

Judgments citing Saheli Synthetics (P) Ltd. v. CIT

Madhucon Projects Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-2(1), Hyderabad

In the result, appeal filed by the assessee is partly allowed

ITA 762/HYD/2020[2014-15]Status: DisposedITAT Hyderabad04 Feb 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

…n, he has relied upon the decision of the Hon'ble Supreme Court in the case of CIT vs. Shapoorji Pallonji Mistry reported in (1962) 44 ITR 891 (S.C) as well as the decision of the Hon'ble Gujarat High Court in the case of Saheli Synthetics (P) Ltd reported in 302 ITR 126. Thus, the learned AR has submitted that the enhancement made by the learned CIT (A) is not sustainable and liable to be deleted. 11. On the other hand, the learned DR has submitted that the learned CIT (A) has pointed out the arithmetic mistake in the calculation made by the Assessing Officer and accordingly directed the Assessing Officer to co…

Madhucon Projects Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-2(1), Hyderabad

In the result, appeal filed by the assessee is partly allowed

ITA 761/HYD/2020[2013-14]Status: DisposedITAT Hyderabad04 Feb 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

…n, he has relied upon the decision of the Hon'ble Supreme Court in the case of CIT vs. Shapoorji Pallonji Mistry reported in (1962) 44 ITR 891 (S.C) as well as the decision of the Hon'ble Gujarat High Court in the case of Saheli Synthetics (P) Ltd reported in 302 ITR 126. Thus, the learned AR has submitted that the enhancement made by the learned CIT (A) is not sustainable and liable to be deleted. 11. On the other hand, the learned DR has submitted that the learned CIT (A) has pointed out the arithmetic mistake in the calculation made by the Assessing Officer and accordingly directed the Assessing Officer to co…

ACIT Central Circle-2(1), Hyderabad vs. Madhucon Projects Limited, Hyderabad

In the result, appeal filed by the assessee is partly allowed

ITA 723/HYD/2020[2013-14]Status: DisposedITAT Hyderabad04 Feb 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

…n, he has relied upon the decision of the Hon'ble Supreme Court in the case of CIT vs. Shapoorji Pallonji Mistry reported in (1962) 44 ITR 891 (S.C) as well as the decision of the Hon'ble Gujarat High Court in the case of Saheli Synthetics (P) Ltd reported in 302 ITR 126. Thus, the learned AR has submitted that the enhancement made by the learned CIT (A) is not sustainable and liable to be deleted. 11. On the other hand, the learned DR has submitted that the learned CIT (A) has pointed out the arithmetic mistake in the calculation made by the Assessing Officer and accordingly directed the Assessing Officer to co…

Asst. Commissioner of Income Tax, Central Circle-2(1), Hyderabad vs. Madhucon Projects Limited, Hyderabad

In the result, appeal filed by the assessee is partly allowed

ITA 13/HYD/2020[2010-11]Status: DisposedITAT Hyderabad04 Feb 2025AY 2010-11

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

…n, he has relied upon the decision of the Hon'ble Supreme Court in the case of CIT vs. Shapoorji Pallonji Mistry reported in (1962) 44 ITR 891 (S.C) as well as the decision of the Hon'ble Gujarat High Court in the case of Saheli Synthetics (P) Ltd reported in 302 ITR 126. Thus, the learned AR has submitted that the enhancement made by the learned CIT (A) is not sustainable and liable to be deleted. 11. On the other hand, the learned DR has submitted that the learned CIT (A) has pointed out the arithmetic mistake in the calculation made by the Assessing Officer and accordingly directed the Assessing Officer to co…

Asst. Commissioner of Income Tax, Central Circle-2(1), Hyderabad vs. Madhucon Projects Limited, Hyderabad

In the result, appeal filed by the assessee is partly allowed

ITA 12/HYD/2020[2009-10]Status: DisposedITAT Hyderabad04 Feb 2025AY 2009-10

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

…n, he has relied upon the decision of the Hon'ble Supreme Court in the case of CIT vs. Shapoorji Pallonji Mistry reported in (1962) 44 ITR 891 (S.C) as well as the decision of the Hon'ble Gujarat High Court in the case of Saheli Synthetics (P) Ltd reported in 302 ITR 126. Thus, the learned AR has submitted that the enhancement made by the learned CIT (A) is not sustainable and liable to be deleted. 11. On the other hand, the learned DR has submitted that the learned CIT (A) has pointed out the arithmetic mistake in the calculation made by the Assessing Officer and accordingly directed the Assessing Officer to co…

Madhucon Projects Limited, Hyderabad vs. DCIT, Central Circle-3, Hyd, Hyderabad

In the result, appeal filed by the assessee is partly allowed

ITA 1328/HYD/2017[2008-09]Status: DisposedITAT Hyderabad04 Feb 2025AY 2008-09

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, CIT(DR)
Section 143(3)Section 153A

…n, he has relied upon the decision of the Hon'ble Supreme Court in the case of CIT vs. Shapoorji Pallonji Mistry reported in (1962) 44 ITR 891 (S.C) as well as the decision of the Hon'ble Gujarat High Court in the case of Saheli Synthetics (P) Ltd reported in 302 ITR 126. Thus, the learned AR has submitted that the enhancement made by the learned CIT (A) is not sustainable and liable to be deleted. 11. On the other hand, the learned DR has submitted that the learned CIT (A) has pointed out the arithmetic mistake in the calculation made by the Assessing Officer and accordingly directed the Assessing Officer to co…

Shri Shri Sushil Kumar Agrawal, Korba, Korba(Cg) vs. The Joint Commissioner of Income Tax, Range Korba, Korba(Cg)

In the result, appeal of the assesee in ITA No

ITA 94/BIL/2017[2011-12]Status: DisposedITAT Raipur27 Mar 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 93 & 94/Rpr/2017 "नधा"रण वष" / Assessment Years: 2010-11 & 2011-12 Shri Sushil Kumar Agrawal, Prop. Of M/S. Shrikishan & Co., T.P Nagar, Korba (C.G.) Pan : Acgpa4350B .......अपीलाथ"/Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Korba (C.G.) ……""यथ" / Respondent

For Appellant: Shri Y.K Mishra, AdvocateFor Respondent: Shri Choudhary N.C Roy, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 234BSection 40Section 68

…ools Pvt. Ltd. Vs. CIT (1999) 238 ITR 268 (Del.) 66 Shri Sushil Kumar Agrawal Vs. Joint Commissioner of Income Tax, Range, Korba ITA Nos. 93 & 94 /RPR/2017 (iii) C. Anitha Vs. CIT (2017) 88 Taxmann.com 53 (Mad.) (iv) Saheli Synthetics P. Ltd. Vs. CIT (2008) 302 ITR 126 (Guj.) 61. Per contra, the Ld. DR relied on the orders of the CIT(Appeals). It was submitted by the Ld. DR that as the assessee was validly put to notice about the enhancement of his gross profit, therefore, it was incorrect on his part to claim that the addition to the said effect had been made without validly putting him to notice. 62. We hav…

Shri Shri Sushil Kumar Agrawal, Korba, Korba(Cg) vs. The Joint Commissioner of Income Tax, Range Korba, Korba(Cg)

In the result, appeal of the assesee in ITA No

ITA 93/BIL/2017[2010-11]Status: DisposedITAT Raipur27 Mar 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 93 & 94/Rpr/2017 "नधा"रण वष" / Assessment Years: 2010-11 & 2011-12 Shri Sushil Kumar Agrawal, Prop. Of M/S. Shrikishan & Co., T.P Nagar, Korba (C.G.) Pan : Acgpa4350B .......अपीलाथ"/Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Korba (C.G.) ……""यथ" / Respondent

For Appellant: Shri Y.K Mishra, AdvocateFor Respondent: Shri Choudhary N.C Roy, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 234BSection 40Section 68

…ools Pvt. Ltd. Vs. CIT (1999) 238 ITR 268 (Del.) 66 Shri Sushil Kumar Agrawal Vs. Joint Commissioner of Income Tax, Range, Korba ITA Nos. 93 & 94 /RPR/2017 (iii) C. Anitha Vs. CIT (2017) 88 Taxmann.com 53 (Mad.) (iv) Saheli Synthetics P. Ltd. Vs. CIT (2008) 302 ITR 126 (Guj.) 61. Per contra, the Ld. DR relied on the orders of the CIT(Appeals). It was submitted by the Ld. DR that as the assessee was validly put to notice about the enhancement of his gross profit, therefore, it was incorrect on his part to claim that the addition to the said effect had been made without validly putting him to notice. 62. We hav…

M/S. Ibm India Private Limited, Bangalore vs. Joint Commissioner of Income Tax, Special Range-4, Bangalore

In the result, appeal filed by the assessee stands partly allowed

ITA 2588/BANG/2019[2006-07]Status: DisposedITAT Bangalore30 Dec 2022AY 2006-07

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Percy Pardiwala, Sr

…efore the Tribunal and that the AO cannot ask questions on the issues which were not subject matter of such appeal. 4.3 He also relied on the decision of Hon’ble Gujarat High Court in the case of Saheli Synthetics Pvt Ltd v. Commissioner of Income- tax 12008] 302 ITR 126 (GUJ), wherein the Hon'ble High Court held as under: "Similarly even where an assessment is set aside simpliciter, without any enhancement proposal. it is always in the context of the appeal against the order of assessment and cannot be read to mean that the appellate authority granted powers to the Assessing Officer in relation to items of asses…

M/S. Vikshara Trading & Investment Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-4(1)(4), Ahmedabad

In the result, appeal filed by the assessee is partly allowed

ITA 652/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad13 Apr 2022AY 2007-08

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kamble

For Appellant: SubmissionFor Respondent: Shri Shaurya S. Shukla, D.R
Section 143(3)Section 36(1)(iii)Section 41(1)

…be strictly followed. The following case laws are relevant. • Surat Electricity Co., Gujarat High Court regarding power of scope of remand, 337 ITR 271, enclosed at page No. 54 & 55. • Saheli Synthetics, Gujarat High Court regarding power of scope of remand, 302 ITR 126, enclosed at page no. 56 to 59. 5. Attention is also drawn to Gujarat High Court in Torrent Leasing and Finance, enclosed at page 22 to 29, relevant para 6, page 7 of the judgment and page 28 of paper book. 6. The loans and advances given at Rs.4,83,96,470/-, grouping at page 34 and sub grouping is at page 35 to 37. 7. Even as per letter dated 2…

M/S. Birla Corporation Ltd., Unit Satna Cement Works, Satna vs. ITO (It & Tp), Bhopal

In the result, Assessee’s appeals

ITA 34/IND/2020[2011-12]Status: DisposedITAT Indore28 Jan 2022AY 2011-12

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing

Section 143(3)Section 5(2)(b)

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE BEFORE SHRI MAHAVIR PRASAD, JUDICIAL MEMBER AND SHRI MANISH BORAD, ACCOUNTANT MEMBER VIRTUAL HEARING ITA No.33 & 34/Ind/2020 Assessment Years: 2010-11 & 2011-12 Birla Corporation Ltd. Satna PANNo.AABCB2075J : Appellant V/s ITO (IT & TP), Bhopal : Respondent Appellant by Shri S.K. Tulsiyan, AR Respondent by Shri Amit Soni, Sr. DR Date of Hearing 14.12.2021 Date of Pronouncement 31 .01.2022 O R D E R PER MANISH BORAD, A.M.: The above captioned appeals filed at the instance of the assessee are directed against…

M/S. Birla Corporation Ltd., Unit Satna Cement Works, Satna vs. ITO (It & Tp), Bhopal

In the result, Assessee’s appeals

ITA 33/IND/2020[2010-11]Status: HeardITAT Indore28 Jan 2022AY 2010-11

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing

Section 143(3)Section 5(2)(b)

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE BEFORE SHRI MAHAVIR PRASAD, JUDICIAL MEMBER AND SHRI MANISH BORAD, ACCOUNTANT MEMBER VIRTUAL HEARING ITA No.33 & 34/Ind/2020 Assessment Years: 2010-11 & 2011-12 Birla Corporation Ltd. Satna PANNo.AABCB2075J : Appellant V/s ITO (IT & TP), Bhopal : Respondent Appellant by Shri S.K. Tulsiyan, AR Respondent by Shri Amit Soni, Sr. DR Date of Hearing 14.12.2021 Date of Pronouncement 31 .01.2022 O R D E R PER MANISH BORAD, A.M.: The above captioned appeals filed at the instance of the assessee are directed against…

Neptune Securities Pvt.Ltd., Ahmedabad vs. ITO, Ward-1(3)(4), Ahmedabad

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

ITA 738/AHD/2018[2007-08]Status: DisposedITAT Ahmedabad30 Jul 2020AY 2007-08
For Appellant: Shri Tushar Hemani, with Shri P.B. Parmar, A.RsFor Respondent: Shri Deelip Kumar, Sr. D.R
Section 234Section 271

…t and guidance from the judgement of Hon’ble Gujarat High Court in the case of the CIT versus server electricity company Ltd reported in 337 ITR 271 wherein it was held as under: The Gujarat High Court, in the case of Saheli Synthetics (P.) Ltd. v. CIT [2008] 302 ITR 126, held that the set aside of assessment made by the appellate authority was always in accordance with the directions given by the appellate authority for making a fresh assessment. But, the most material part of the provision [of section 251] was the opening portion which stipulates 'in an appeal against an order of assessment'. In other words, th…

Chandulal A.Shah(HUF), Surat vs. The ITO, Ward-3(3)(1), Surat

In the result, the appeal of the assessee, Ind for A

ITA 83/SRT/2017[2000-01]Status: DisposedITAT Surat04 May 2020AY 2000-01

Bench: Shri Sandeep Gosain & Shri O.P.Meenaआ.अ.सं././././I.T.A Nos.83 & 84/Srt/2017 िनधा"रणवष"/Assessment Years: 2000-01 & 2004-05 1.Chandulal Amrutlal Shah (Huf), V. Income Tax Officer, Bunglow No.74, Saifee Society, Ward-3(3)(1), Surat. L.H. Road, Surat-395 006. [Pan: Aaahc 8116 R] 2.Chandulal Amrutlal Shah, V. Income Tax Officer, Bunglow No.74, Saifee Society, Ward-3(3)(1), Surat. L.H. Road, Surat-395 006. [Pan: Adaps 5844 F] अपीलाथ" / Appellant ""थ"/Respondent

Section 147Section 148

…t order. Therefore, it was submitted that in set-aside order of Tribunal the AO cannot enhance the income originally assessed by him, in the light of ratio laid down by the Hon’ble Gujarat High Court in the case of Saheli Synthetics (P) Ltd. v. CIT [2008] 302 ITR 126 (Gujarat) , Hon`ble Supreme Court in the case of Mcorp Global (P) Ltd. v. CIT [2009] 309 ITR 434 (SC) Fidelity Shares And Securities Ltd. v. DCIT [Tax Appeal No. 187 of 2001 dated 13.06.2016 of Hon’ble Gujarat Chandulal A Shah (HUF) v. ITO, Ward-3(3)(1),Surat/ITA. 83 & 84/SRT/2017/A.Y.2000-01 & 2004-05 Page 13 of 15 High Court] (PB-15 to 23).…

M/S Ad2Pro Media Solutions Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax (International Taxation) Circle-1(1), Bangalore

In the result, all the 14 appeals filed by the assessee are allowed

ITA 490/BANG/2019[2011-12]Status: DisposedITAT Bangalore20 Mar 2020AY 2011-12

Bench: Shri A.K.Garodia & Shri P.K.Gadale(Ita Nos.490 To 503(Bang)/2019) (Assessment Years: 2011-12 To 2017-18) M/S Ad2Pro Media Solutions Pvt.Ltd., No.10, 2Nd Floor, Bannerghatta Road, J.P.Nagar-Iii Phase, Bangalore-560078 Appellant Vs The Deputy Commissioner Of Income Tax, (International Taxation) Circle-1(1), Bmtc Building, Koramangala, Bangalore-560095 Respondent

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Vandana Sagar, CIT-DR
Section 201Section 201(1)Section 9

…Section 251 of the Act and issues show-cause notice. The failure to issue show cause notice is fatal. 5.4 The Appellant places reliance on the following decisions of various courts in support of its contentions: (i) Saheli Synthetics (P.) Ltd. vs CIT [2008] 302 ITR 126 (Gujarat); (ii) CIT v. Rai Bahadur Hardutroy Motilal Chamaria [1967] 66 ITR 443; (iii) CIT v. Shapoorji Pallonji Mistry [1962] 44 ITR 891 (SC); 5.5 With regard to the opinion of the CIT A that the payments are of composite nature and liable to be treated as Royalty, the Appellant submits that Learned CIT(A) artificially divided the agreement en…

The ACIT, Circle-5, Ahmedabad vs. M/S. Rajesh Malleables Ltd., Ahmedabad

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

ITA 802/AHD/2016[2003-04]Status: DisposedITAT Ahmedabad20 Jan 2020AY 2003-04

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Appellant: Shri L.P. Jain, Sr.DRFor Respondent: Shri Anil Kshatriya
Section 36(1)(iii)Section 68

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ C ” BENCH, AHMEDABAD BEFORE SHRI MAHAVIR PRASAD, JUDICIAL MEMBER And SHRI WASEEM AHMED, ACCOUNTANT MEMBER आयकर अपील सं./ITA No. 802/Ahd/2016 ("नधा"रण वष"/Assessment Year: 2003-04 ) The DCIT बनाम/ M/s.Rajesh Malleables Ltd. Circle-3(1) C/o. Anuj Mehta Vs. Ahmedabad Nandanvan Opp. Shapath-IV, Nr. Karnavati Club SG High Way Ahmedabad-380 051 "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AABCR 0270 K .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant by : Shri L.P. Jain, Sr.DR ""यथ" क" ओर से/Respondent by: Shr…

Curewel (India) Ltd vs. Income Tax Officer

ITA/259/2018HC Delhi28 Nov 2019

Bench: The Ao In The Set Aside Proceedings?” 2. We Have Heard Learned Counsels & Proceed To Answer The Aforesaid Questions. The Assessing Officer Passed The Assessment Order In Respect Of The Assessment Year 2002-03 Under Section 144 Of The Income Tax Act On

Section 143(3)Section 144Section 254

…remand proceedings and that too in second round of remand by the Tribunal.” 6. The Tribunal went on to answer the question raised by it against the assessee by placing reliance on a decision of the Gujarat High Court in Sehet Synthetics P. Ltd. v. CIT, 302 ITR 126. 7. The submission of learned counsel for the appellant is that a perusal of the order of remand dated 10.03.2011 would show that the ITAT had completely set aside the assessment order on a fundamental premise, namely, on finding the approach of the lower authorities - which included the Assessing Officer, to be “highly unjustified and regr…

Vatika Ltd., New Delhi vs. DCIT, New Delhi

ITA 1512/DEL/2014[2008-09]Status: DisposedITAT Delhi14 Aug 2019AY 2008-09

Bench: Smt Beena A Pillai & Shri Prashant Maharishi

For Appellant: Shri C.S. Aggarwal, Sr. AdvFor Respondent: Smt Naina Soin Kapil, Sr. DR
Section 195Section 250Section 251(1)(a)Section 251(2)Section 271Section 40a

…He therefore submitted that the only option available with the assessing officer is to verify the claim and to allow the same. He further relied upon the decision of the honourable Gujarat High Court in case of Saheli synthetics private limited vs CIT (2008) 302 ITR 126. He therefore submitted that the power of the learned assessing officer are limited and the learned AO does not have any further power to process a new source of income. He therefore submitted that in the instant case the learned assessing officer should not have made the disallowance. In nutshell, the only option available with the learned asses…

M/S Chitrakala Investment Trade & Business Finance Ltd., Manipal vs. DCIT, Udupi

In the result, the appeals filed by all the assessees are dismissed

ITA 1324/BANG/2012[1996-97]Status: DisposedITAT Bangalore01 May 2017AY 1996-97

Bench: Shri Inturi Rama Rao & Shri Sudhanshu Srivastava1. 2. 3. 1. M/S.Mangala Investments Ltd. Syndicate House, Manipal-576 104. Pan: Aaacm 8838 R 2. M/S.Sea Rock Investments Ltd., Syndicate House, Manipal-576104. Pan:Aaccs 4700 N 3. M/S.Chitrakala Investments Trade & Business Finance Ltd. Syndicate House, Manipal-576104. Pan: Aaacc 7246 H ... Appellant Vs. Deputy Commissioner Of Income-Tax, Circle-1, Udupi. ... Respondent Assessees By : Ms. Prathibha, Advocate. Respondent : Dr.Shakir Hussain, Cit(A) Date Of Hearing : 30/01/2017 Date Of Pronouncement : 01/05/2017 O R D E R Per Inturi Rama Rao, Am : These Are Appeals Filed By Three Assessees Against Identical Orders Of The Cit(A), Mysore, For The Assessment Year 1996-97. Ita Nos.1322 To 1324/Bang/2012 Page 2 Of 14 2. Since In All These Appeals Common Issues Are Involved, We Propose To Dispose Of The Same Vide This Consolidated Order For The Sake Of Convenience.

For Respondent: Dr.Shakir Hussain, CIT(A)
Section 2(47)

…IN THE INCOME TAX APPELLATE TRIBUNAL CIRCUIT BENCH AT MANGALURU BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER 1. 2. 3. 1. M/s.Mangala Investments Ltd. Syndicate House, Manipal-576 104. PAN: AAACM 8838 R 2. M/s.Sea Rock Investments Ltd., Syndicate House, Manipal-576104. PAN:AACCS 4700 N 3. M/s.Chitrakala Investments Trade & Business Finance Ltd. Syndicate House, Manipal-576104. PAN: AAACC 7246 H ... Appellant Vs. Deputy Commissioner of Income-tax, Circle-1, Udupi. ... Respondent Assessees by : Ms. Prathibha, Advocate. Respondent : Dr.Shakir Hussain, CIT(A) Date of…

M/S Sea Rock Investments Ltd., Manipal vs. DCIT, Udupi

In the result, the appeals filed by all the assessees are dismissed

ITA 1323/BANG/2012[1996-97]Status: DisposedITAT Bangalore01 May 2017AY 1996-97

Bench: Shri Inturi Rama Rao & Shri Sudhanshu Srivastava1. 2. 3. 1. M/S.Mangala Investments Ltd. Syndicate House, Manipal-576 104. Pan: Aaacm 8838 R 2. M/S.Sea Rock Investments Ltd., Syndicate House, Manipal-576104. Pan:Aaccs 4700 N 3. M/S.Chitrakala Investments Trade & Business Finance Ltd. Syndicate House, Manipal-576104. Pan: Aaacc 7246 H ... Appellant Vs. Deputy Commissioner Of Income-Tax, Circle-1, Udupi. ... Respondent Assessees By : Ms. Prathibha, Advocate. Respondent : Dr.Shakir Hussain, Cit(A) Date Of Hearing : 30/01/2017 Date Of Pronouncement : 01/05/2017 O R D E R Per Inturi Rama Rao, Am : These Are Appeals Filed By Three Assessees Against Identical Orders Of The Cit(A), Mysore, For The Assessment Year 1996-97. Ita Nos.1322 To 1324/Bang/2012 Page 2 Of 14 2. Since In All These Appeals Common Issues Are Involved, We Propose To Dispose Of The Same Vide This Consolidated Order For The Sake Of Convenience.

For Respondent: Dr.Shakir Hussain, CIT(A)
Section 2(47)

…IN THE INCOME TAX APPELLATE TRIBUNAL CIRCUIT BENCH AT MANGALURU BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER 1. 2. 3. 1. M/s.Mangala Investments Ltd. Syndicate House, Manipal-576 104. PAN: AAACM 8838 R 2. M/s.Sea Rock Investments Ltd., Syndicate House, Manipal-576104. PAN:AACCS 4700 N 3. M/s.Chitrakala Investments Trade & Business Finance Ltd. Syndicate House, Manipal-576104. PAN: AAACC 7246 H ... Appellant Vs. Deputy Commissioner of Income-tax, Circle-1, Udupi. ... Respondent Assessees by : Ms. Prathibha, Advocate. Respondent : Dr.Shakir Hussain, CIT(A) Date of…

Saheli Synthetics (P) Ltd. v. CIT (302 ITR 126) — Cited in 22 Judgments | BharatTax