SedcoForexInternational Drill. Inc. v. CIT

10 SCC 165Reported decision2000#507 most cited

What is SedcoForexInternational Drill. Inc. v. CIT authority for?

Tax law applicable is that in force during the relevant assessment year, unless explicitly provided otherwise. An Explanation, even for 'removal of doubts', is not retrospective if it alters the law or has a specific prospective effective date, thus not affecting earlier assessment years.

186

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2025.

Also referred to as

SedcoForexInternational Drill. Inc. v. CIT · 10 SCC 165 · assessment year · law in force · retrospective amendment · clarificatory explanation · Section 9(1)(ii) · removal of doubts · prospective application of law · statutory interpretation tax law · amendment effect on earlier years

Sections most often in play

Section 14ASection 143(3)Section 8DSection 115JBSection 36(1)(vii)Section 36(1)(viia)Section 250Section 263

Issues it is cited on

section 9(1)(ii)section 80absection 73clarificatory amendmentresulting companytransferor companyretrospective amendmentsection 9(1)section 115jaddtstrategic investmentdisallowance under section 14a

Judgments citing SedcoForexInternational Drill. Inc. v. CIT

ACIT, MUMBAI vs. K RAHEJA CORPORATE SERVICES PRIVATE LIMITED, MUMBAI

In the result, appeal filed by the revenue is hereby dismissed

ITA 5350/MUM/2025[2015-16]Status: DisposedITAT Mumbai31 Oct 2025AY 2015-16
Section 115JSection 143(3)Section 14ASection 250

…retrospective, even where such language is used, if it alters or\nchanges the law as it earlier stood. This was stated in Sedco Forex International Drill.\nInc. vs. CIT (2005) 12 SCC 717 as follows;\n17. As was affirmed by this Court in Goslino Mario [(2000) 10 SCC 165/ a cardinal\nprinciple of the tax law is that the law to be applied is that which is in force in the\nrelevant assessment year unless otherwise provided expressly or by necessary\nimplication. (See also Reliance Jute and Industries Ltd. v. CIT [(1980) 1 SCC 139/) An\nExplanation to a statutory provision may fulfil the purpose of clearing up an amb…

ACIT, MUMBAI vs. K RAHEJA CORPORATE SERVICES PRIVATE LIMITED, MUMBAI

In the result, appeal filed by the revenue is hereby dismissed

ITA 5349/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Hemanshu Joshi, SR DR
Section 115JSection 143(2)Section 143(3)Section 14ASection 250

…be retrospective, even where such language is used, if it alters or changes the law as it earlier stood. This was stated in Sedco Forex International Drill. Inc. vs. CIT (2005) 12 SCC 717 as follows; 17. As was affirmed by this Court in Goslino Mario [(2000) 10 SCC 165/ a cardinal principle of the tax law is that the law to be applied is that which is in force in the (Assessment Years: 2014-15 & 2015-16) relevant assessment year unless otherwise provided expressly or by necessary implication. (See also Reliance Jute and Industries Ltd. v. CIT [(1980) 1 SCC 139/) An Explanation to a statutory provision may fulfi…

PR. COMMISSIONER OF INCOME TAX, DELHI 1 vs. M/S AMADEUS INDIA PVT. LTD.

Appeal is dismissed being covered

ITA/511/2025HC Delhi10 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 14Section 14ASection 260A

…applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand.” 11. The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312] . These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a Signed By:PRAMOD KUMAR VATS Signing Date:15.10.2025 12:58:54 Signature Not Verified ITA 511/2025…

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI vs. AMBATTUR CLOTHING PRIVATE LIMITED, TIRUVALLUR

In the result, the appeal filed by Revenue is dismissed

ITA 1663/CHNY/2025[2011-12]Status: DisposedITAT Chennai29 Aug 2025AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1663/Chny/2025 िनधा"रण वष"/Assessment Year: 2011-12 The Assistant Commissioner Of Vs. Ambattur Clothing Private Limited, Income Tax, 86/E2, Industrial Estate, Corporate Circle 1(1), Ambattur Industrial Estate S.O., Chennai. Ambattur, Thiruvallur 600 058. [Pan:Aaaca4127D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Rajakumar, Addl. Cit ""थ" की ओर से/Respondent By : Shri Vinay Jain, Ca सुनवाई की तारीख/ Date Of Hearing : 26.08.2025 घोषणा की तारीख /Date Of Pronouncement : 29.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 31.12.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals)-16, Chennai For The Assessment Year 2011-12. 2. We Find That This Appeal Is Filed With A Delay Of 67 Days. The Appellant-Revenue Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Revenue Are Bonafide, Which 2

For Appellant: Shri N. Rajakumar, Addl. CITFor Respondent: Shri Vinay Jain, CA
Section 14A

…ation applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand." 11. The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312] . These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. 12. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referre…

PR. COMMISSIONER OF INCOME TAX-1, DELHI vs. ACB (INDIA) POWER LTD.

ITA/331/2025HC Delhi22 Aug 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 14A

…s it earlier stood. This was stated in SedcoForex International Drill. Inc. v. CIT [2005] 279 ITR 310 (SC) (2005) 12 SCC 717 as follows (page 318 of 279 ITR) : '17. As was affirmed by this court in CIT v. Goslino Mario [2000] 241 ITR 312 (SC) ; (2000) 10 SCC 165 a cardinal principle of the tax law is that the law to be applied is that which is in force in the relevant assessment year unless otherwise provided expressly or by necessary implication. (See also Reliance Jute and Industries Ltd. v. CIT [1979] 120 ITR 921 (SC) ; (1980) 1 SCC 139)). An Explanation to a statutory provision may fulfil the…

PR. COMMISSIONER OF INCOME TAX-1, DELHI vs. ACB (INDIA) POWER LTD.

ITA - 331 / 2025HC Delhi22 Aug 2025
Section 14A

…s it earlier stood. This was stated in SedcoForex International Drill. Inc. v. CIT [2005] 279 ITR 310 (SC) (2005) 12 SCC 717 as follows (page 318 of 279 ITR) : '17. As was affirmed by this court in CIT v. Goslino Mario [2000] 241 ITR 312 (SC) ; (2000) 10 SCC 165 a cardinal principle of the tax law is that the law to be applied is that which is in force in the relevant assessment year unless otherwise provided expressly or by necessary implication. (See also Reliance Jute and Industries Ltd. v. CIT [1979] 120 ITR 921 (SC) ; (1980) 1 SCC 139)). An Explanation to a statutory provision may fulfil the…

ZODIAC VENTURES LIMITED,MUMBAI vs. INCOME TAX OFFICER- 11 (3) (1), MUMBAI

The appeal of the assessee is allowed

ITA 4135/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Aug 2025AY 2017-18

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri S. C. Tiwari, AR
Section 143(1)Section 14ASection 199Section 250

…assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand. " 6 ITA 4135/Mum/2025 Zodiac Ventures Ltd. 11. The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312] . These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. 12. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referre…

INDUS VALLEY PROPERTIES PRIVATE LIMITED,KABRA EXCELCIOR vs. INCOME TAX OFFICER WARD 3(1)(4) BANGALORE, BANGALORE,

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

ITA 81/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Jun 2025AY 2017-18

Bench: Shri Prashant Maharishiassessment Year : 2017-18

For Appellant: Shri Siddesh Nagaraj Gaddi, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 14Section 143(3)Section 14A

…lanation applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand.' The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : [2000] 241 ITR 312 (SC)] . These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. ITA No.81/Bang/2025. Page 10 of 19 In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Sect…

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. RAMCO INDUSTRIES LIMITED, CHENNAI

Appeals of the revenue are dismissed

ITA 2901/CHNY/2024[2013-14]Status: DisposedITAT Chennai07 Apr 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकरअपीलसं./I.T.A.No.2900 & 2901/Chny/2024 (निर्धारण वर्ष / Assessment Year: 2011-12 & 2013-14)

Section 115JSection 143(3)Section 14ASection 263

…ion applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand. " 11. The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165: (2000) 241 ITR 312]. These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. 12. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referred…

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. RAMCO INDUSTRIES LIMITED, CHENNAI

Appeals of the revenue are dismissed

ITA 2900/CHNY/2024[2011]Status: DisposedITAT Chennai07 Apr 2025

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Mr.V.Justin, CITFor Respondent: Mr. S.Muralidhar, FCA &
Section 115JSection 143(3)Section 144Section 14ASection 263

…tion applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand. " 11. The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312] . These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. 12. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referre…

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. RAMCO INDUSTRIES LIMITED, MADURAI

Appeals of the revenue stand dismissed

ITA 2884/CHNY/2024[2020]Status: DisposedITAT Chennai24 Feb 2025

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita Nos.2883 & 2884/Chny/2024. (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021) The Assistant Commissioner Of Vs. Ramco Industries Limited, Income Tax, 47, Psk Nagar, Corporate Circle, Rajapalayam 626 108. Madurai [Pan Aaacr 5284J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Muralidhar & Shri J. Prabhakar, F.C.As. ""यथ" क" ओर से /Respondent By : Shri. R. Bhoopathi, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 06.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 24.02.2025 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. S. Muralidhar and Shri JFor Respondent: Shri. R. Bhoopathi, Addl. CIT
Section 115JSection 143(3)Section 14A

…tion applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand. " 11. The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312] . These decisions are thus authorities for the proposition that the 1983 Explanation expressly years. 12. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referred to by us as the 1999 Explanation). Section 5 of the Bill expressly stated that with…

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. RAMCO INDUSTRIES LIMITED, RAJAPALAYAM

Appeals of the revenue stand dismissed

ITA 2883/CHNY/2024[2018]Status: DisposedITAT Chennai24 Feb 2025

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita Nos.2883 & 2884/Chny/2024. (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021) The Assistant Commissioner Of Vs. Ramco Industries Limited, Income Tax, 47, Psk Nagar, Corporate Circle, Rajapalayam 626 108. Madurai [Pan Aaacr 5284J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Muralidhar & Shri J. Prabhakar, F.C.As. ""यथ" क" ओर से /Respondent By : Shri. R. Bhoopathi, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 06.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 24.02.2025 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. S. Muralidhar and Shri JFor Respondent: Shri. R. Bhoopathi, Addl. CIT
Section 115JSection 143(3)Section 14A

…tion applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand. " 11. The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312] . These decisions are thus authorities for the proposition that the 1983 Explanation expressly years. 12. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referred to by us as the 1999 Explanation). Section 5 of the Bill expressly stated that with…

MUTHU THEVAR NAGARAJAN,DINDIGUL vs. ITO, WARD-1., DINDIGUL

Appeals of the revenue stand dismissed

ITA 2083/CHNY/2024[2018-19]Status: DisposedITAT Chennai24 Feb 2025AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita Nos.2883 & 2884/Chny/2024. (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021) The Assistant Commissioner Of Vs. Ramco Industries Limited, Income Tax, 47, Psk Nagar, Corporate Circle, Rajapalayam 626 108. Madurai [Pan Aaacr 5284J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Muralidhar & Shri J. Prabhakar, F.C.As. ""यथ" क" ओर से /Respondent By : Shri. R. Bhoopathi, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 06.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 24.02.2025 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. S. Muralidhar and Shri JFor Respondent: Shri. R. Bhoopathi, Addl. CIT
Section 115JSection 143(3)Section 14A

…tion applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand. " 11. The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312] . These decisions are thus authorities for the proposition that the 1983 Explanation expressly years. 12. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referred to by us as the 1999 Explanation). Section 5 of the Bill expressly stated that with…

JAGDISH KUMAR ARORA,BHAWANIMANDI vs. DCIT, CENTRAL CIRCLE- KOTA, KOTA

In the result, the appeal of the assessee is allowed

ITA 1195/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Feb 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 115BSection 143(3)Section 145(3)Section 234ASection 69

…en where such language is used, if it alters or changes the law as it earlier stood. This was stated in Sedco Forex International Drill. Inc. v. CIT, (2005) 12 SCC 717 as follows: 43 Jagdish Kumar Arora As was affirmed by this Court in Goslino Mario [(2000) 10 SCC 165] a cardinal principle of the tax law is that the law to be applied is that which is in force in the relevant assessment year unless otherwise provided expressly or by necessary implication. (See also Reliance Jute and Industries Ltd. v. CIT [(1980) 1 SCC 139].)An Explanation to a statutory provision may fulfil the purpose of clearing up an ambigui…

M/S JSW INFRASTRUTURE LIMITED,MUMBAI vs. DCIT CIRCLE-5(2)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 6015/MUM/2024[2018-19]Status: DisposedITAT Mumbai23 Jan 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 M/S Jsw Infrastructure Ltd., Dy. Cit, Circle 5(2)(1), Jsw Centre Bandra Kurla Complex, Aayakar Bhavan, Maharishi Karve Bandra (East), Vs. Road, New Marine Lines, Churchgate, Mumbai-400051. Mumbai-400020. Pan No. Aabcj 6721 D Appellant Respondent

For Appellant: Ms. Vinita NaraFor Respondent: 02/01/2025
Section 14ASection 14A(2)

…. The reasoning of the Gauhati High Court was expressly affirmed by e reasoning of the Gauhati High Court was expressly affirmed by e reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR [(2000) 10 SCC 165 : (2000) 241 ITR 312] . These decisions are thus authorities for the proposition that t 312] . These decisions are thus authorities for the proposition that the 312] . These decisions are thus authorities for the proposition that t 1983 Explanation expressly introduced with effect from a particular date 1983 Exp…

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

ITA 303/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

…planation applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand.’ The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312]. These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referred to…

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

ITA 302/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

…planation applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand.’ The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312]. These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referred to…

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

ITA 199/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

…planation applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand.’ The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312]. These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referred to…

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

ITA 198/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

…planation applicable to the cases of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand.’ The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312]. These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referred to…

RAJAPALAYAM MILLS LTD.,,VIRUDHUNAGAR vs. DCIT, CORPORATE CIRCLE,, MADURAI

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

ITA 1251/CHNY/2024[2017-18]Status: DisposedITAT Chennai14 Aug 2024AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1251/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 Rajapalayam Mills Limited, Vs. The Deputy Commissioner Of Post Box No. 1, Rajapalayam Mills Income Tax, Premises, P.A.C. Ramasamy Raja Corporate Circle, Salai, Rajapalayam, Madurai. Virudhunagar 626 117. [Pan: Aaacr8897F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Muralidhar, F.C.A. ""थ" की ओर से/Respondent By : Shri R. Clement Ramesh Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 12.08.2024 घोषणा की तारीख /Date Of Pronouncement : 14.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal By The Assessee Is Directed Against The Order Dated 30.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax, Madurai Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2017-18. 2. The Assessee Raised 9 Grounds Amongst Which The Only Issue Emanates For Our Consideration Is Whether The Ld. Pcit Is Justified In Directing The Assessing Officer For Working Out Disallowance Under Section 2

For Appellant: Shri S. Muralidhar, F.C.AFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 142(1)Section 14ASection 2Section 263

…es of the present assessees. This fortuitous circumstance cannot take away the vested rights of the assessees at hand." 8 I.T.A. No.1251/Chny/24 11. The reasoning of the Gauhati High Court was expressly affirmed by this Court in CIT v. Goslino Mario [(2000) 10 SCC 165 : (2000) 241 ITR 312] . These decisions are thus authorities for the proposition that the 1983 Explanation expressly introduced with effect from a particular date would not effect the earlier assessment years. 12. In this state of the law, on 27-2-1999 the Finance Bill, 1999 substituted the Explanation to Section 9(1)(ii) (or what has been referre…

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SedcoForexInternational Drill. Inc. v. CIT (10 SCC 165) — Cited in 186 Judgments | BharatTax