Sir Shadilal Sugar and General Mills Ltd. v. CIT

168 ITR 705Supreme Court of India1987#1327 most cited

What is Sir Shadilal Sugar and General Mills Ltd. v. CIT authority for?

An assessee's agreement to an addition or voluntary disclosure of income does not automatically establish concealment for levying penalty under Section 271(1)(c). While such agreement may arise from various reasons like avoiding litigation, the assessee must still discharge the burden of proving that the addition was not due to concealment.

86

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2001 to 2026.

Also referred to as

Sir Shadilal Sugar and General Mills Ltd. v. CIT · 168 ITR 705 · penalty under section 271(1)(c) · voluntary surrender of income · agreement to addition · concealment of income · furnishing inaccurate particulars · burden of proof · avoidance of litigation · deletion of penalty

Sections most often in play

Section 143(3)Section 271(1)(c)Section 153ASection 274Section 132Section 271AABSection 276CSection 132A

Issues it is cited on

penalty under section 271aabsection 276csection 276non-compete feesurrender of incomesection 271aabdeletion of penaltyfull and true disclosuresection 273section 271aafurnishing inaccurate particularsfurnishing inaccurate particulars of income

Judgments citing Sir Shadilal Sugar and General Mills Ltd. v. CIT

LAXMICHAND AND COMPANY,GWALIOR vs. DCIT/ACIT 1(1), GWL, GWALIOR

In the result, assessee’s appeal is allowed

ITA 313/AGR/2025[201718]Status: DisposedITAT Agra15 Jan 2026

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2017-18

Section 143(3)Section 145(3)Section 250Section 270ASection 44A

…ciples of natural justice and condition and procedure prescribed under the statue 5. That while sustaining the impugned addition, Ld CIT(Appeals), NFAC, Delhi has erred in law in ignoring the fact as well law Supreme Court in case of Sir Shadilal Sugar Mills (168 ITR 705) held that there may be a hundred and one reasons for not protesting and agreeing to an addition but that does not follow to the conclusion that the amount agreed to be added was concealed income. Indeed, there may be numerous reasons with the tax payer for not approaching the first appellate authority for justice, for example the following: a. T…

DCIT, CENTRAL CIRCLE-3(2), , MUMBAI vs. M/S VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

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

ITA 890/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Sept 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

…is distinction, holding that advances or payments noted on paper slips do not attract the provision. 53. It is also well settled that voluntary disclosure cannot, by itself, justify penalty. The Supreme Court in Sir Shadilal Sugar & General Mills Ltd. v. CIT (168 ITR 705) held that an assessee’s agreement to an addition does not prove concealment; there may be many reasons for such an agreement, including avoidance of litigation or commercial expediency. This principle has been reiterated in CIT v. M. Pachamuthu (295 ITR 502), CIT v. Rajiv Garg (313 ITR 256), and by the Bombay High Court in CIT v. Haji Gaffar Haj…

DCIT, CENTRAL CIRCLE-3(2), , MUMBAI vs. M/S VIRAJ PROFILES PRIVATE LIMITED, , MUMBAI

In the result, all the appeals filed by the Revenue are\ndismissed

ITA 889/MUM/2025[2013-14]Status: DisposedITAT Mumbai29 Sept 2025AY 2013-14
Section 143(3)Section 153ASection 271(1)(c)Section 271ASection 37Section 69ASection 69C

…istinction, holding that advances or payments noted on\npaper slips do not attract the provision.\n53. It is also well settled that voluntary disclosure cannot, by\nitself, justify penalty. The Supreme Court in Sir Shadilal\nSugar & General Mills Ltd. v. CIT (168 ITR 705) held that an\nassessee's agreement to an addition does not prove\nconcealment; there may be many reasons for such an\nagreement, including avoidance of litigation or commercial\nexpediency. This principle has been reiterated in CIT v. M.\nPachamuthu (295 ITR 502), CIT v. Rajiv Garg (313 ITR 256),\nand by the Bombay High Court in CIT v. Haji Gaff…

DCIT, CENTRAL CIRCLE-3(2), MUMBAI vs. M/S VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

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

ITA 888/MUM/2025[2011-12]Status: DisposedITAT Mumbai29 Sept 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

…is distinction, holding that advances or payments noted on paper slips do not attract the provision. 53. It is also well settled that voluntary disclosure cannot, by itself, justify penalty. The Supreme Court in Sir Shadilal Sugar & General Mills Ltd. v. CIT (168 ITR 705) held that an assessee’s agreement to an addition does not prove concealment; there may be many reasons for such an agreement, including avoidance of litigation or commercial expediency. This principle has been reiterated in CIT v. M. Pachamuthu (295 ITR 502), CIT v. Rajiv Garg (313 ITR 256), and by the Bombay High Court in CIT v. Haji Gaffar Haj…

DCIT, CENTRAL CIRCLE-3(2), , MUMBAI vs. VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are\ndismissed

ITA 872/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Sept 2025AY 2017-18
Section 143(3)Section 153ASection 271(1)(c)Section 271ASection 37Section 69ASection 69C

…tinction, holding that advances or payments noted on\npaper slips do not attract the provision.\n\n53. It is also well settled that voluntary disclosure cannot, by\nitself, justify penalty. The Supreme Court in Sir Shadilal\nSugar & General Mills Ltd. v. CIT (168 ITR 705) held that an\nassessee's agreement to an addition does not prove\nconcealment; there may be many reasons for such an\nagreement, including avoidance of litigation or commercial\nexpediency. This principle has been reiterated in CIT v. M.\nPachamuthu (295 ITR 502), CIT v. Rajiv Garg (313 ITR 256),\nand by the Bombay High Court in CIT v. Haji Gaff…

DCIT, CENTRAL CIRCLE-3(2), MUMBAI vs. VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

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

ITA 871/MUM/2025[2015-16]Status: DisposedITAT Mumbai29 Sept 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

…is distinction, holding that advances or payments noted on paper slips do not attract the provision. 53. It is also well settled that voluntary disclosure cannot, by itself, justify penalty. The Supreme Court in Sir Shadilal Sugar & General Mills Ltd. v. CIT (168 ITR 705) held that an assessee’s agreement to an addition does not prove concealment; there may be many reasons for such an agreement, including avoidance of litigation or commercial expediency. This principle has been reiterated in CIT v. M. Pachamuthu (295 ITR 502), CIT v. Rajiv Garg (313 ITR 256), and by the Bombay High Court in CIT v. Haji Gaffar Haj…

DCIT, CIRCLE 22(2), NEW DELHI, NEW DELHI vs. SAHIL VACHANI, DELHI

Appeal of the Revenue stands dismissed

ITA 2604/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Jun 2025AY 2016-17

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy& Shriavdhesh Kumar Mishraआअसं.2604/िद"ी/2023(िन.व. 2016-17)

For Appellant: S/Shri Anuj Garg & Narpat Singh, Sr.DRFor Respondent: S/Shri Rohan Khare & Priyam
Section 271(1)(c)Section 54F

…ssessing Officer is not obliged to intimate the assessee that Explanation 1 to section 271(1)(c) is proposed to be applied. The scheme of the provisions does not provide for such a 21 requirement either directly or inferentially. In Sir Shadilal's case [1987] 168 ITR 705, what the Supreme Court observed was that there may be several reasons for which the assessee may have offered an amount for addition, but that itself is not sufficient to infer concealment. It has not laid down as a rule of general application that whenever such is the case, penalty cannot be imposed. On the contrary, in such cases also the asse…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, AURANAGBAD., AURANGABAD. vs. SHREEHARI ASSOCIATES PVT LTD, AURANGABAD.

The appeals of the REVENUE are ALLOWED

ITA 410/PUN/2024[2019-20]Status: DisposedITAT Pune26 Nov 2024AY 2019-20

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamore

For Appellant: Mr CH Naniwadekar & Kiran Sanmane [‘Ld. AR’]For Respondent: Mr Ajaykumar Kesari & Arvind Desai [‘Ld. DR’]
Section 131Section 132Section 143(3)Section 153ASection 250Section 253(2)Section 271(1)(c)Section 36(1)(va)

…jettison. 7. To drive home the Revenue’s contention the Ld. DR Mr Desai at the very kickoff challenged the validity of impugned orders passed which solitarily founded its decision by placing reliance on ‘Sir Shadilal Sugar & General Mills Ltd. Vs CIT’ [1987, 168 ITR 705 (SC)]. In view of the Revenue the ratio therein is inapplicable to the facts and circumstances of present cases. It is the twofold submission of the Ld. DR that; firstly, the addition on account of unexplained sub-contracting expenditure made in the respective years were exclusively based on seized documents/material unearthed during the search.…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, AURANGABAD, AURANGABAD vs. SHREEHARI ASSOCIATES PVT LTD, AURANGABAD

The appeals of the REVENUE are ALLOWED

ITA 408/PUN/2024[2014-15]Status: DisposedITAT Pune26 Nov 2024AY 2014-15

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamore

For Appellant: Mr CH Naniwadekar & Kiran Sanmane [‘Ld. AR’]For Respondent: Mr Ajaykumar Kesari & Arvind Desai [‘Ld. DR’]
Section 131Section 132Section 143(3)Section 153ASection 250Section 253(2)Section 271(1)(c)Section 36(1)(va)

…jettison. 7. To drive home the Revenue’s contention the Ld. DR Mr Desai at the very kickoff challenged the validity of impugned orders passed which solitarily founded its decision by placing reliance on ‘Sir Shadilal Sugar & General Mills Ltd. Vs CIT’ [1987, 168 ITR 705 (SC)]. In view of the Revenue the ratio therein is inapplicable to the facts and circumstances of present cases. It is the twofold submission of the Ld. DR that; firstly, the addition on account of unexplained sub-contracting expenditure made in the respective years were exclusively based on seized documents/material unearthed during the search.…

DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, AURANGABAD, AURANGABAD. vs. SHREEHARI ASSOCIATES PRIVATE LIMITED, AURANGABAD

The appeals of the REVENUE are ALLOWED

ITA 407/PUN/2024[2013-14]Status: DisposedITAT Pune26 Nov 2024AY 2013-14

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamore

For Appellant: Mr CH Naniwadekar & Kiran Sanmane [‘Ld. AR’]For Respondent: Mr Ajaykumar Kesari & Arvind Desai [‘Ld. DR’]
Section 131Section 132Section 143(3)Section 153ASection 250Section 253(2)Section 271(1)(c)Section 36(1)(va)

…jettison. 7. To drive home the Revenue’s contention the Ld. DR Mr Desai at the very kickoff challenged the validity of impugned orders passed which solitarily founded its decision by placing reliance on ‘Sir Shadilal Sugar & General Mills Ltd. Vs CIT’ [1987, 168 ITR 705 (SC)]. In view of the Revenue the ratio therein is inapplicable to the facts and circumstances of present cases. It is the twofold submission of the Ld. DR that; firstly, the addition on account of unexplained sub-contracting expenditure made in the respective years were exclusively based on seized documents/material unearthed during the search.…

MAN EQUIPMENT CO. P.LTD,MUMBAI vs. DCIT CEN CIR 37, MUMBAI

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

ITA 5144/MUM/2015[2008-09]Status: DisposedITAT Mumbai25 Nov 2024AY 2008-09

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhrim/S. Man Equipment Co. V/S. Dcit, Central Circle-37 Pvt. Ltd. बनाम Mumbai 69, Svp Road, Dongri, Mumbai-400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacm9716E Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: NoneFor Respondent: Shri. B. Laxmi Kanth
Section 132Section 132(4)Section 143(3)Section 153ASection 250Section 271(1)Section 271(1)(c)Section 276C

…IN THE INCOME-TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SMT. RENU JAUHRI, ACCOUNTANT MEMBER M/s. Man Equipment Co. v/s. DCIT, Central Circle-37 Pvt. Ltd. बनाम Mumbai 69, SVP Road, Dongri, Mumbai-400009 स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AAACM9716E Appellant/अपीलार्थी .. Respondent/प्रतिवादी Appellant by : None Respondent by : Shri. B. Laxmi Kanth Date of Hearing 28.10.2024 Date of Pronouncement 25.11.2024 आदेश / O R D E R PER RENU JAUHRI [A.M.] :- This appeal is filed by the assessee against the order of the Learned Commissioner of Income-tax (Appeals)…

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHPAUR vs. RBL BANK LTD, KOLHAPUR

In the result, the appeal of the Revenue is dismissed

ITA 657/PUN/2024[2014-15]Status: DisposedITAT Pune30 Sept 2024AY 2014-15

Bench: SATBEER SINGH GODARA, JUDICIAL MEMBER, AND DR.DIPAK P. RIPOTE (Accountant Member)

Section 139(1)Section 143(2)Section 250Section 271Section 271(1)(c)

…।आयकर अपीलीय अिधकरण ”बी” "ायपीठ पुणेम"। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B” :: PUNE BEFORE SATBEER SINGH GODARA, JUDICIAL MEMBER, AND DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No.657/PUN/2024 िनधा"रण वष" / Assessment Year: 2014-15 The Assistant V RBL Bank Ltd., Commissioner of Income s 179 E Mahaveer, Tax,Kolhapur. E Ward Shri Shahu Market Yard, Maharashtra – 416005. PAN: AABCT3335M Appellant/ Revenue Respondent / Assessee Assessee by Shri S. Sriram & Shri Samyak Lohade Revenue by Shri Ajay Kumar Keshri Date of hearing 17/09/2024 Date of pronouncement 30/09/2024 आदेश/ ORDER PER D…

IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

ITA 1054/BANG/2024[2020-21]Status: DisposedITAT Bangalore27 Sept 2024AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 250Section 270ASection 270A(7)Section 270A(8)Section 40Section 43

…an appeal against the quantum / original Assessment order or not. The case laws on which reliance has been placed by the Ld. AO in its Assessment Order are mentioned hereunder: a. KP Madhusudhanan Vs CIT b. CIT vs KP Madhusudhanan c. Sir Shadilal's Case 1987 168 ITR 705 d. CIT vs K. Srinivasan vi. All these cases laws / judgements have been considered carefully and this Appellate authority is in the view that the case laws mentioned by the Assessing Officer in its Penalty Order are found to be correct and has relevance with the case findings in case of the appellant assessee. vii. Thus, it is seen that, the AO h…

SURESH CHAND BANSAL,HARYANA vs. ACIT, CENTRAL CIRCLE-16 , DELHI

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

ITA 3666/DEL/2023[2014-15]Status: DisposedITAT Delhi26 Jun 2024AY 2014-15

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

Section 153ASection 271(1)(c)Section 274

…ained by the Supreme Court in K.P. Madhusudan v. CIT [20011 251 ITR 99/118 Taxman 324, wherein the Court held- "Learned Counsel for the assessee then drew our attention to the judgement of this Court in Sir Shadilal Sugar and General Mills Ltd. v. CIT [1987] 168 ITR 705. He submitted that the assessee had agreed to the additions to his Income referred to hereinabove to buy peace and it did not follow therefrom that the amount that was agreed to he added was concealed income. That it did not follow that the amount agreed to be added was concealed income is undoubtedly what was laid down by this Court in the case…

AMIT BANSAL,HARYANA vs. ACIT, CENTRAL CIRCLE-16, DELHI

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

ITA 3665/DEL/2023[2015-16]Status: DisposedITAT Delhi26 Jun 2024AY 2015-16

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

Section 153ASection 271(1)(c)Section 274

…ained by the Supreme Court in K.P. Madhusudan v. CIT [20011 251 ITR 99/118 Taxman 324, wherein the Court held- "Learned Counsel for the assessee then drew our attention to the judgement of this Court in Sir Shadilal Sugar and General Mills Ltd. v. CIT [1987] 168 ITR 705. He submitted that the assessee had agreed to the additions to his Income referred to hereinabove to buy peace and it did not follow therefrom that the amount that was agreed to he added was concealed income. That it did not follow that the amount agreed to be added was concealed income is undoubtedly what was laid down by this Court in the case…

AMIT BANSAL,HARYANA vs. ACIT CENTRAL CIRCLE-16, DELHI

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

ITA 3664/DEL/2023[2014-15]Status: DisposedITAT Delhi26 Jun 2024AY 2014-15

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

Section 153ASection 271(1)(c)Section 274

…ained by the Supreme Court in K.P. Madhusudan v. CIT [20011 251 ITR 99/118 Taxman 324, wherein the Court held- "Learned Counsel for the assessee then drew our attention to the judgement of this Court in Sir Shadilal Sugar and General Mills Ltd. v. CIT [1987] 168 ITR 705. He submitted that the assessee had agreed to the additions to his Income referred to hereinabove to buy peace and it did not follow therefrom that the amount that was agreed to he added was concealed income. That it did not follow that the amount agreed to be added was concealed income is undoubtedly what was laid down by this Court in the case…

ACIT CIRCLE-59(1), NEW DELHI vs. ATEEQ AHMED, NEW DELHI

In the result, the appeal of the Revenue for A

ITA 5096/DEL/2019[2014-15]Status: DisposedITAT Delhi29 Apr 2024AY 2014-15

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 5095 & 5096/Del/2019 (Assessment Year : 2013-14 & 2014-15) Acit Vs. Sh. Ateeq Ahmed Circle-59(1), 306/7, Iiird Floor, Delhi Aditya Complex, Community Centre, Preet Vihar, New Delhi Pan : Aeipa7958R (Appellant) (Respondent)

Section 143(3)Section 271Section 271(1)(c)Section 36(1)(iii)Section 80Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘A’ : NEW DELHI) BEFORE SH. G.S.PANNU, HON’BLE VICE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No. 5095 & 5096/Del/2019 (Assessment Year : 2013-14 & 2014-15) ACIT Vs. Sh. Ateeq Ahmed Circle-59(1), 306/7, IIIrd Floor, Delhi Aditya Complex, Community Centre, Preet Vihar, New Delhi PAN : AEIPA7958R (APPELLANT) (RESPONDENT) Assessee by Sh. Majeedullah, CA Revenue by Sh. Kanv Bali, Sr. DR & Shri Vivek Vardhan, Sr. DR Date of hearing: 08.03.2024 Date of Pronouncement: 29.04.2024 ORDER PER ANUBHAV SHARMA, JM: These appeals have been preferred b…

ACIT CIRCLE-59(1), NEW DELHI vs. ATEEQ AHMED, NEW DELHI

In the result, the appeal of the Revenue for A

ITA 5095/DEL/2019[2013-14]Status: DisposedITAT Delhi29 Apr 2024AY 2013-14

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 5095 & 5096/Del/2019 (Assessment Year : 2013-14 & 2014-15) Acit Vs. Sh. Ateeq Ahmed Circle-59(1), 306/7, Iiird Floor, Delhi Aditya Complex, Community Centre, Preet Vihar, New Delhi Pan : Aeipa7958R (Appellant) (Respondent)

Section 143(3)Section 271Section 271(1)(c)Section 36(1)(iii)Section 80Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘A’ : NEW DELHI) BEFORE SH. G.S.PANNU, HON’BLE VICE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No. 5095 & 5096/Del/2019 (Assessment Year : 2013-14 & 2014-15) ACIT Vs. Sh. Ateeq Ahmed Circle-59(1), 306/7, IIIrd Floor, Delhi Aditya Complex, Community Centre, Preet Vihar, New Delhi PAN : AEIPA7958R (APPELLANT) (RESPONDENT) Assessee by Sh. Majeedullah, CA Revenue by Sh. Kanv Bali, Sr. DR & Shri Vivek Vardhan, Sr. DR Date of hearing: 08.03.2024 Date of Pronouncement: 29.04.2024 ORDER PER ANUBHAV SHARMA, JM: These appeals have been preferred b…

AJMER INDUSTRIES LLP,NAYA BAZAR AJMER vs. DCIT CENTRAL CIRCLE AJMER, JAIPUR ROAD AJMER

In the result, three appeals of the assessee are allowed

ITA 760/JPR/2023[2018-19]Status: DisposedITAT Jaipur09 Feb 2024AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. C. M. Agarwal (CA)For Respondent: Sh. Ajay Malik (CIT)
Section 132Section 153ASection 271ASection 274

…ven on merits. Reliance in this regard is placed on the following decisions: Hon’ble High Court of Madya Pradesh in the case of CIT Vs Suresh Chand Mittal 241ITR124 (2000)MP Supreme Court Judgement in Sir Shadilal Sugar and General Mills Ltd. Vs. CIT, [1987]168 ITR 705 Hon’ble ITAT Delhi Bench in the case of M.G.Contractors Pvt.Ltd. Vs DCIT, Central Circle-1, Faridabad in ITA Nos 7034 to 7038/Del/2014 Hon’ble High Court of Gujarat in the case of Cheldas Khushaldas Patel And Ors. vs Commissioner Of Income-Tax 1992, 196 ITR 200 Guj held as under: “ 7. The Commissioner, in the case of the firm, refused to waiv…

PREM PRAKASH AGARWAL,NAYA BAZAR AJMER vs. DCIT CENTRAL CIRCLE AJMER, JAIPUR ROAD AJMER

In the result, three appeals of the assessee are allowed

ITA 759/JPR/2023[2019-20]Status: DisposedITAT Jaipur09 Feb 2024AY 2019-20

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. C. M. Agarwal (CA)For Respondent: Sh. Ajay Malik (CIT)
Section 132Section 153ASection 271ASection 274

…ven on merits. Reliance in this regard is placed on the following decisions: Hon’ble High Court of Madya Pradesh in the case of CIT Vs Suresh Chand Mittal 241ITR124 (2000)MP Supreme Court Judgement in Sir Shadilal Sugar and General Mills Ltd. Vs. CIT, [1987]168 ITR 705 Hon’ble ITAT Delhi Bench in the case of M.G.Contractors Pvt.Ltd. Vs DCIT, Central Circle-1, Faridabad in ITA Nos 7034 to 7038/Del/2014 Hon’ble High Court of Gujarat in the case of Cheldas Khushaldas Patel And Ors. vs Commissioner Of Income-Tax 1992, 196 ITR 200 Guj held as under: “ 7. The Commissioner, in the case of the firm, refused to waiv…

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