How many judgments cite Sardar Kehar Singh v. CIT?

29 judgments on BharatTax cite Sardar Kehar Singh v. CIT (195 ITR 769), spanning 2016 to 2025.

Which sections of the Income Tax Act does Sardar Kehar Singh v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 1961, Section 10A(a), Section 10B(1), Section 10B(e), Section 11.

Sardar Kehar Singh v. CIT

195 ITR 769High Court1992#4086 most cited

What is Sardar Kehar Singh v. CIT authority for?

The rule of consistency in tax proceedings, an exception to the principle that each assessment year is a separate unit, is well-recognized and should not be ignored.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

Sardar Kehar Singh v CIT · 195 ITR 769 · rule of consistency · tax proceedings · assessment year · Radhasoami Satsang v CIT · section 143(3) · section 142

Also reported as

92 CTR 88

Sections most often in play

Section 143(3)Section 1961 Section 10A(a)Section 10B(1)Section 10B(e)Section 11 Section 12 Section 131 of the Income Tax Act

Issues it is cited on

rule of consistency section 10(38)short term capital gain section 142 section 27 previous year transfer section 11 section 142(1)section 143(2)section 144 company

Judgments citing Sardar Kehar Singh v. CIT

OCEANIC MARKETING AGENCIES INDIA LTD ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -2(2), MUMBAI

In the result ITA No. 4542/Mum/2025 is dismissed as\nwithdrawn and ITA No

ITA 4777/MUM/2025[2008-09]Status: DisposedITAT Mumbai18 Nov 2025AY 2008-09

…Rule of consistency cannot he ignored in tax proceedings.\nThis rule is an exception to the above rule, and has been well\nrecognized in various judicial rulings cited below:\n1. Radhasoami Satsang vs. CIT/1991/193 ITR 321 (SC)\n2. Sardar Kehar Singh CIT/1991/195 ITR 769 (Raj.)\n3. CIT vs. Neo Poly Pack (P) Ltd. (2000/245 ITR 492 (Delhi)\n4. CIT vs. Belpahar Refractrorles Ltd., [1981/128/ITR 610(Ori)\n5. M.A. Namazie Endowment vs. CIT / 1988/174 ITR 58 (Mad)\n6. CIT vs. Shree Nirmal Commercial Ltd./1994/213 ITR 361\n(Bom) (FB)\n7. Turaben Ramanbhal Patel & Anr. Vs. ITO [1995] 215 ITR\n323 (Guj)\n8. Dhansiram Agar…

M/S. OCEANIC MARKETING AGENCIES INDIA LTD.,,DELHI vs. THE DY. COMMISSIONER OF INCOME TAX, (OSD), CIRCLE 2(2), MUMBAI

In the result ITA No. 4542/Mum/2025 is dismissed as\nwithdrawn and ITA No

ITA 4542/MUM/2025[2008-09]Status: DisposedITAT Mumbai18 Nov 2025AY 2008-09

…Rule of consistency cannot he ignored in tax proceedings. This rule is an exception to the above rule, and has been well recognized in various judicial rulings cited below:\n\n1. Radhasoami Satsang vs. CIT/1991/193 ITR 321 (SC)\n2. Sardar Kehar Singh CIT/1991/195 ITR 769 (Raj.)\n3. CIT vs. Neo Poly Pack (P) Ltd. (2000/245 ITR 492 (Delhi)\n4. CIT vs. Belpahar Refractrorles Ltd., [1981/128/ITR 610(Ori)\n5. M.A. Namazie Endowment vs. CIT / 1988/174 ITR 58 (Mad)\n6. CIT vs. Shree Nirmal Commercial Ltd./1994/213 ITR 361\n(Bom) (FB)\n7. Turaben Ramanbhal Patel & Anr. Vs. ITO [1995] 215 ITR\n323 (Guj)\n8. Dhansiram Agar…

DCIT,CENTRAL CIRCLE-1, GUWAHATI vs. SATISH JALAN, SHILLONG

Appeal of the Revenue is allowed for statistical purposes

ITA 62/GTY/2025[2017-18]Status: DisposedITAT Guwahati17 Nov 2025AY 2017-18

Bench: Hon'Ble Itat. 3. There Are Currently More Than 300 Time Barred Assessment & 200 Penalty Cases Are Pending In This Office. Due To Shortage Of Manpower It Was Delayed In The Filing Of Appeal Before Hon'Ble Itat.

Section 131Section 250Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL GUWAHATI BENCH, GUWAHATI (VIRTUAL HEARING AT KOLKATA) SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER I.T.A. No. 62/GTY/2025 Assessment Year: 2017-18 DCIT, Central Circle-1, Aayakar Bhawan, Christian Basti, GS Road, Assam – 781005 .....................…...……………....Appellant vs. Satish Jalan, Howeel Road, Lalban, Shillong - 793004 [PAN: ADCPJ0750D] ...…..…................................. Respondent Appearances by: Assessee represented by : S.P. Bhati, FCA Department represented by : Kausik Ray, JCIT Date of concluding the hearing : 04.11.2025 Da…

GOYAL VEGOILS LIMITED ,KASAR ,KOTA vs. DCIT , CIRCLE -2, KOTA

In the result ground no. 2 & 3 raised by the assessee

ITA 243/JPR/2024[2012-13]Status: DisposedITAT Jaipur27 Aug 2024AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Rajendra Sisodia, CAFor Respondent: Sh. Anoop Singh, Addl. CIT

Section 143(3)Section 147Section 148Section 250

…he position to be changed in a subsequent year. Though the principle of res- judicata is not applicable in the income- tax matter, but findings of earlier years on the same matter are relevant as per the ratio laid down in (a)Sardar Kehar Singh Vs. CIT [1992] 195 ITR 769 (Raj), (b) Taraben Ramanbhai Patel Vs. ITO [1995] 215 ITR 323(Guj ) and (c )CIT Vs. Hindusthan Motors Ltd. [1991] 192 ITR 619 (Cal ). (d) Hon’ble Apex Court in Parashuram Pottery Works Co. Ltd. Vs. ITO [1977] 106 ITR 1 (SC) 3.5 In a very recent decision, ITAT, Mumbai in the case of Jitendra Udaylal Jain vs. National Faceless Assessment Centre (NF…

GOODYEAR INDIA LTD.,FARIDABAD vs. DCIT, CIRCLE-10(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 346/DEL/2022[2017-18]Status: DisposedITAT Delhi26 Jul 2024AY 2017-18

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vivek Verma CIT (DR ) and Sh. Kanv Bali, Sr. DR

Section 143(3)Section 144BSection 144CSection 92B

…ITR 321 (Supreme Court) II. Commissioner of Income Tax vs Kotrika Ramaswamy Chetty 64 ITR 388 (Andhra Pradesh High Court) III. DhansiramAgarwalla vs Commissioner Of Income Tax 217 ITR 4 (Gauhati High Court) IV. Sardar Kehar Singh v Commissioner of Income Tax 195 ITR 769 (Rajasthan High Court) V. The Panel is not convinced as any change in facts and circumstances of the case militates against the doctrine of consistency. The law in this regard was explained by the Hon'ble Supreme Court in Radhasoami Satsang, thus: "9. We are aware of the fact that, strictly speaking, res judicata does not apply to proceedings.…

GOODYEAR INDIA LTD,FARIDABAD vs. ACIT, CIRCLE-10(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 1451/DEL/2022[2018-19]Status: DisposedITAT Delhi26 Jul 2024AY 2018-19

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vivek Verma CIT (DR ) and Sh. Kanv Bali, Sr. DR

Section 143(3)Section 144BSection 144CSection 92B

RAJ AUTO WHEELS (P) LTD.,JAIPUR vs. ACIT, AJMER

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

ITA 929/JPR/2016[2009-10]Status: DisposedITAT Jaipur09 Nov 2022AY 2009-10

For Appellant: Shri Mahendra Gargieya, AdvocawteFor Respondent: Shri P.R. Meena, C IT-DR

Section 133(6)Section 143(3)Section 145(3)

…of res judicata do not apply to Income Tax proceeding yet however, unless there is a change in the facts and circumstances, the view taken earlier should normally be taken consistently. For this kindly refer Sardar Kehar Singh v/s CIT (1991) 92 CTR 88/(1992) 195 ITR 769 (Raj), and a recent decision in CIT v/s Excel Industries Ltd. (2013) 358 ITR 295 (SC). RAJ AUTO WHEELS (P) LTD. VS ACIT, CIRCLE-1, AJMER It is a judicially accepted principle that when the facts are same, a uniform view should be adopted for the subsequent years in the income tax proceedings unless there is a material change in the facts, which…

M/S RAJ AUTO WHEELS P .LTD.,AJMER vs. JCIT, RANGE-1, AJMER

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

ITA 397/JPR/2015[2011-12]Status: DisposedITAT Jaipur09 Nov 2022AY 2011-12

For Appellant: Shri Mahendra Gargieya, AdvocawteFor Respondent: Shri P.R. Meena, C IT-DR

Section 131Section 145(3)Section 194ASection 40

…of res judicata do not apply to Income Tax proceeding yet however, unless there is a change in the facts and circumstances, the view taken earlier should normally be taken consistently. For this kindly refer Sardar Kehar Singh v/s CIT (1991) 92 CTR 88/(1992) 195 ITR 769 (Raj), and a recent decision in CIT v/s Excel Industries Ltd. (2013) 358 ITR 295 (SC). It is a judicially accepted principle that when the facts are same, a uniform view should be adopted for the subsequent years in the income tax proceedings unless there is a material change in the facts, which has not been established by the AO. Kindly refer Ra…

M/S RAJ AUTO WHEELS P LTD.,AJMER vs. ACIT, CIRCLE-1, AJMER

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

ITA 396/JPR/2015[2010-11]Status: DisposedITAT Jaipur09 Nov 2022AY 2010-11

For Appellant: Shri Mahendra Gargieya, AdvocawteFor Respondent: Shri P.R. Meena, C IT-DR

…nd that is why, he alleged deferment of sale in other years. 4.3 Rule of consistency cannot be violated. Please refer case laws cited in ITAT w/s Pg 24 Pr. 2 of A.Y. 2011-12 in ITA No. 397/JP/15, Kindly refer SardarKehar Singh v/s CIT (1991) 92 CTR 88/(1992) 195 ITR 769 (Raj), and a recent decision in CIT v/s Excel Industries Ltd. (2013) 358 ITR 295 (SC). 5. Though the lower authorities alleged that on making inquiries form the RTO with reference to the subjected advances of the customers, it was found that no sales were registered in the name of such customers (AO Pg. 9-10). However, it was for the simple reas…

M/S ALLEN CAREER INSTITUTE,JAIPUR vs. INCOME TAX OFFICER, WARD-2-1, KOTA

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

ITA 617/JPR/2018[2013-14]Status: DisposedITAT Jaipur04 Aug 2022AY 2013-14

For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri A.S. Nehra, Addl. CIT

Section 143(3)Section 234ASection 244ASection 37(1)

…n appeal before the High Court but without any success. That being so, the Revenue could not be allowed to flip-flop on the issue further.” 9 ITA NO. 617/JP/2018 - ALLEN CAREER INSTITUTE, ITO, WARD 2(1), KOTA 8.3 Sardar Kehar Singh v/s CIT (1991) 92 CTR 88/195 ITR 769 (Raj) 8.4 Although specific submissions were made before the ld. CIT(A) and his attention was drawn to this fact yet however, he completely remained silent. 9. Covered by Settlement Commission Order: Pertinently, a search was carried out in the case of assessee group and in relation thereto, the matter was taken to the Hon’ble Income Tax Settle…

ALLEN CAREER INSTITUTE,KOTA vs. JCIT, JAIPUR

In the result, the Grounds No

ITA 54/JPR/2017[2012-12]Status: DisposedITAT Jaipur04 Aug 2022AY 2012-12

For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri A.S. Nehra, Addl. CIT

Section 143(3)Section 234ASection 244ASection 36Section 36(1)(iii)Section 37(1)

…matter any further but in respect of some AYs the matter was taken up in appeal before the High Court but without any success. That being so, the Revenue could not be allowed to flip-flop on the issue further.” 8.3 Sardar Kehar Singh v/s CIT (1991) 92 CTR 88/195 ITR 769 (Raj) 8.4 Although specific submissions were made before the ld. CIT(A) and his attention was drawn to this fact yet however, he completely remained silent. 9. Covered by Settlement Commission Order: Pertinently, a search was carried out in the case of assessee group and in relation thereto, the matter was taken to the Hon’ble Income Tax Settleme…

ALLEN CAREER INSTITUTE,JAIPUR vs. JCIT, KOTA

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

ITA 620/JPR/2016[2011-12]Status: DisposedITAT Jaipur04 Aug 2022AY 2011-12

For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri A.S. Nehra, Addl. CIT

Section 143(3)Section 36Section 36(1)(iii)Section 37(1)

…tter was taken up in appeal before the High Court but without any success. That being so, the Revenue could not be allowed to flip-flop on the issue further.” 35 ALLEEN CAREER INSTITUTE VS JCIT, RANGE-2, KOTA 8.3 Sardar Kehar Singh v/s CIT (1991) 92 CTR 88/195 ITR 769 (Raj) 8.4 Although specific submissions were made before the ld. CIT(A) and his attention was drawn to this fact yet however, he completely remained silent. 9.1 Settlement Commission: The issue involved is otherwise also covered. A search was carried out in the case of assessee group and the matter reached to the Hon’ble Income Tax Settlement Com…

ALLEN CAREER INSTITUTE,JAIPUR vs. JCIT, KOTA

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

ITA 246/JPR/2015[2010-11]Status: DisposedITAT Jaipur04 Aug 2022AY 2010-11

For Appellant: Shri Mahendra Gargieya, Advocate &For Respondent: Shri A.S. Nehra, Addl. CIT

Section 143(3)Section 234ASection 244ASection 36(1)(iii)

…matter any further but in respect of some AYs the matter was taken up in appeal before the High Court but without any success. That being so, the Revenue could not be allowed to flip-flop on the issue further.” 8.3 Sardar Kehar Singh v/s CIT (1991) 92 CTR 88/195 ITR 769 (Raj) 8.4 Although specific submissions were made before the ld. CIT(A) and his attention was drawn to this fact yet however, he completely remained silent. 9.1 Settlement Commission: The issue involved is otherwise also covered. A search was carried out in the case of assessee group and the matter reached to the Hon’ble Income Tax Settlement Com…

SHRI ARVINDBHAI LALLUBHAI LAKHANKIYA,,SURAT vs. THE ACIT, CIRCLE-9,, SURAT

ITA 962/AHD/2016[2006-07]Status: DisposedITAT Surat12 Oct 2020AY 2006-07

Bench: Shri Pawan Singh, Hon'Ble & Shri Arjun Lal Saini, Hon'Ble(Virtual Court Virtual Hearing) आ.अ.सं./I.T.A No.962/Ahd/2016; "नधा"रणवष"/Assessment Year: 2006-07 Shri Arvindbhai Lallubhai V Asst. Commissioner Of Lakhankiya, B-78, Hans Society, S Income Tax, Circle-9, Surat. Varchha Road, Surat. . [Pan: Aadpl 3819 P] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Ashwin Parekh – Ar राज"वक"ओरसे /Revenue By Mrs. Anupama Singla – Sr.Dr

Section 131Section 133ASection 143(1)Section 143(3)Section 147Section 50C(3)

…The reopening is not valid on the basis of report of the valuer / DVO. The assessee in his objection also relied on the following decisions  Bomaby High Court in CIT Vs TulsidassKalichand (122 ITR 458 Bom),  Rajasthan High Court in SardarKehar Singh Vs CIT (195 ITR 769 Raj),  Calcutta High Court in Reliance Jute Industries Ltd Vs ITO ( 150 ITR 643 Cal) and  Decision of Tribunal in ACIT Vs BalkishanPoddar (ITA No. 3412/Ahd/2008). 7. The objection of assessee was not accepted and the objection of the assessee was disposed off by AO on 27.01.2014. After disposal of the objection, the ld.AO proceeded to make the…

SHANTA SALSES CORPORATION,JAIPUR vs. ITO, JAIPUR

In the result, appeal of the assessee is allowed

ITA 231/JPR/2017[2010-11]Status: DisposedITAT Jaipur11 Mar 2020AY 2010-11

For Appellant: Sh. Manish Agarwal (FCA)For Respondent: Smt. Runi Pal (JCIT)

Section 143(3)Section 145(3)

…ion of Rs.70 lacs is completely imaginary and deserves to be deleted. In support, reliance was placed on the decision in case of Income Tax Officer Vs. Chohtan Construction Co. 84 TTJ 693 (Jodh) and Sardar Kehar Singh Vs. Commissioner of Income Tax and Others 195 ITR 769 (Raj). In view of above, it was submitted that trading addition confirmed by ld. CIT(A) at Rs.70 lacs deserves to be deleted. 30. The ld DR is heard who has submitted that the AO has discussed in detail in the assessment order the discrepancies /defects in the books of account of the assessee and had come to a conclusion that production of clay…

DCIT CC 3(4) CE RG 3, MUMBAI vs. SAMIR NARAIN BHOJWANI, MUMBAI

In the result, the appeal filed by the revenue is hereby ordered to be dismissed

ITA 1124/MUM/2017[2012-13]Status: DisposedITAT Mumbai19 Jul 2019AY 2012-13

For Appellant: Shri Yogesh A. Thar/ ChaitanyaFor Respondent: Shri Laxmi Vora Prasad Gude

Section 143(1)Section 143(2)

….7.3 Radhasoami Satsang V CIT (193 ITR 321) (SC) 2.7.4 CIT Vs. ARJ Securities Printes (264 ITR 276) (Del) 2.7.5 CIT V Godavari Corporation Ltd. (156 ITR 835)(MP) 2.7.6 CIT V Bhilai Engg. Corporation Pvt. Ltd. (133 ITR 687)(MP) 2.7.7 Sardar Kehar Singh V. CIT (195 ITR 769) 2.8 . You will appreciate that in the case of Shambhu Investment it was nobody's case that in the earlier years similar income was charged to tax 'Income from Business'. The factual position in my case is different from the case before the Court in Shambhu investment. 7.13. T have also considered the above notes which had been filed before the A…

ACIT CC 3(4) CEN RG 3, MUMBAI vs. SAMIR NARIAN BHOJWANI, MUMBAI

In the result, appeal filed by the revenue is hereby dismissed and the cross-objection filed by the assessee is hereby ordered to be dismissed

ITA 331/MUM/2015[2009-10]Status: DisposedITAT Mumbai12 Oct 2018AY 2009-10

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.331/Mum/2015 (निर्धारण वर्ा / Assessment Year: 2009-10) बिधम/ Acit-Cc-3(4) Central Shri Samir Narain Bhojwani 1St Floor, Samir Complex, St. Range-3 Vs. Andrews Road, Opp, Holy Room No. 401, 4Th Floor, Family Hospital, Bandra Aayakar Bhavan, Mumbai- (W), Mumbai-400050. 400020. Co. No.134/Mum/2016 (Arising Out Of Ita. No. 331/Mum/2015) (निर्धारण वर्ा / Assessment Year: 2009-10) बिधम/ Shri Samir Narain Bhojwani Acit-Cc-24 & 26 1St Floor, Samir Complex, St. Room No. 401, 4Th Floor, Vs. Andrews Road, Opp, Holy Aayakar Bhavan, Mumbai- Family Hospital, Bandra 400020. (W), Mumbai-400050. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. :Aabpb9150H (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) आयकर अपील सं/ I.T.A. No.6807/Mum/2014 (निर्धारण वर्ा / Assessment Year: 2010-11) बिधम/ Acit Cc-24 & 26 Central Shri Samir Narain Bhojwani 1St Floor, Samir Complex, St. Range-5 Vs. Andrews Road, Opp. Holy Room No.404, 4Th Floor Family Hospital, Bandra Aayakar Bhavan, Mumbai- (W), Mumbai-400050. 400020. Co. No.41/Mum/2016 (Arising Out Of Ita. No. 6153/Mum/2014) (निर्धारण वर्ा / Assessment Year: 2009-10) बिधम/ Shri Samir Narain Bhojwani Acit Cc-24 & 26 Central 1St Floor, Samir Complex, St. Range-5 Vs. Andrews Road, Opp. Holy Room No.404, 4Th Floor Family Hospital, Bandra Aayakar Bhavan, Mumbai-

For Appellant: Shri Yogesh TharFor Respondent: Shri R. Manjunatha

Section 132Section 139(1)Section 143(2)Section 153A

M/S KANDOI POWDERS MFG. CO. PVT. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

In the result, appeal of the assessee is allowed

ITA 417/JPR/2018[2014-15]Status: DisposedITAT Jaipur08 Jun 2018AY 2014-15

For Appellant: Shri S.L. Poddar (Adv)For Respondent: Smt. Seema Meena (JCIT)

Section 143(3)Section 40A(2)(b)

…g in a subsequent year ignoring without material the conclusion arrived at earlier would be vitiated in law. Similarly the Hon’ble Rajasthan High Court in the case of Sardar ITA 417/JP/2018_ 4 M/s Kandoi Powders Mfg. Co. P. Ltd. Vs DCIT Kehar Singh Vs CIT 195 ITR 769 (Raj) has also viewed that where no fresh facts were available before the authority giving the later decision, the authority was not entitled to unsettle the earlier finding. The Hon’ble Rajasthan High Court in the case of CIT Vs Kusum Bader 185 ITR 70 (Raj) has also held that where the authority giving the earlier decision had taken into con…

GALAXY IMPEX,JAIPUR vs. DCIT, JAIPUR

In the result, the disallowance made

ITA 529/JPR/2016[2012-13]Status: DisposedITAT Jaipur28 Feb 2017AY 2012-13

For Appellant: Shri Mahendra Gargieya (Advocate)For Respondent: Shri Prithivi Raj Meena (Add. CIT)

Section 145(3)

…of res judicata do not apply to Income Tax proceeding yet however, unless there is a change in the facts and circumstances, the view taken earlier should normally be taken consistently. For this kindly refer Sardar Kehar Singh v/s CIT (1991) 92 CTR 88(1992) 195 ITR 769 (Raj.), and a recent decision in CIT v/s Excel Industries Ltd. (2013) 358 ITR 295 (SC). It is a judicially accepted principle that when the facts are same, a uniform view should be adopted for the subsequent years in the income tax proceedings unless there is a material change in the facts, which has not be established by the AO. Kindly refer…

CONCORD ENVIRO SYSTEMS (P ) LTD,MUMBAI vs. ACIT CC 10, MUMBAI

In the result, the appeal filed by the assessee company in ITA N0

ITA 3917/MUM/2013[2009-10]Status: DisposedITAT Mumbai24 Jun 2016AY 2009-10

Bench: Shri Sanjay Garg & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.3917/Mum/2013 ("नधा"रण वष" / Assessment Year : 2009-10) Concord Enviro Systems (Pvt) Acit -10, बनाम/ Ltd., 101, Hdil Tower, Aayakar Bhavan, V. Anant Kanekar Marg, Annex. M.K. Marg, Bandra East, Mumbai – 400 020. Mumbai-400051 "थायी लेखा सं./Pan : Aaacc8962C (अपीलाथ" /Appellant) .. (""यथ" / Respondent)

For Respondent: Dr. S. Pandian,DR

Section 132Section 143(3)Section 40A(2)(b)

…t was submitted that the salary paid including the commission on turnover to the Directors should be allowed. The assessee company relied on the following judicial pronouncements:- 1. CIT v. Sridev Enterprises, 192 ITR 165 (Kar.) 2. Sardar Kehar Singh v. CIT 195 ITR 769(Raj.) 3. Pukhraj Rikhabdass v. CWT, 203 ITR 770 (Raj) 4. Shyam Sunder Gupta v. CIT 232 ITR 135 (M.P) 5. Parshuram Pottery Works Co. Ltd. v. ITO(1977) 106 ITR 1(SC) ITA 3917/Mum/2013 8 5.2 With respect to the disallowance of Rs. 1,79,324/- being the total travelling expenses, the assessee company submitted that the A.O. ignored that the entire…

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