CLAN LABORATORIES PVT. LTD.,CHENNAI vs. DCIT, CORPORATE WARD-1(2), CHENNAI
ITA 2303/CHNY/2024[2015-16]Status: DisposedITAT Chennai11 Aug 2025AY 2015-16
For Appellant: Mr. N.Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 148Section 148ASection 149
…roceedings under section 148A are “stayed by an order or injunction of any court”. 97. A legal fiction is a supposition of law that a thing or event exists even though, in reality, it does not exist. (Gajraj Singh v. State Transport Appellate Tribunal [(1997) 1 SCC 650.] ) The word “deemed” is used to treat a thing or event as something, which otherwise it may not have been, with all the attendant consequences. (CIT v. Calcutta Stock Exchange Association Ltd. [(1959) 36 ITR 222 (SC); 1959 SCC OnLine SC 126.]; Smt. Sudha Rani Garg v. Jagdish Kumar [(2004) 8 SCC 329.] ) The effect of a legal fiction is that “a posi…