State of Tamil Nadu v. Arulmurugan and Company

51 STC 381High Court1982#2350 most cited

What is State of Tamil Nadu v. Arulmurugan and Company authority for?

A tax appeal is a rehearing of the entire assessment, granting appellate authorities the same functions as assessing authorities. The appellate authority can initiate further investigations and enhance the assessment, even if the assessee's appeal sought a reduction.

49

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

State of Tamil Nadu v. Arulmurugan and Company · Arulmurugan · 51 STC 381 · appellate authority powers · scope of tax appeal · rehearing of assessment · enhancement by appellate authority · sections 147 · 142(1) · 148 · 144

Sections most often in play

Section 147Section 142(1)Section 148Section 153ASection 68Section 144Section 263Section 69

Issues it is cited on

section 31(3)section 36(l)(vii)peak credit theorysection 36(2)(v)section 124(3)(a)section 41(4)section 43b(f)section 124(3)section 124section 36(l)section 113section 36(1)(viii)

Judgments citing State of Tamil Nadu v. Arulmurugan and Company

SOLO STEEL TECH,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

ITA 316/RJT/2024[2013-14]Status: DisposedITAT Rajkot01 Jul 2025AY 2013-14
Section 143(3)Section 153ASection 40A

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

INTERNATIONAL COMMISSION ON IRRIGATION AND DRAINAGE EMPLOYEES PROVIDENT FUND (ICID PF TRUST),NEW DELHI vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

In the result, both appeals of the assessee are allowed as above

ITA 4204/DEL/2024[2014-15]Status: DisposedITAT Delhi20 Jun 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 10Section 10(21)Section 10(25)(ii)Section 11Section 12ASection 143(1)Section 154

…sts of the country at large the taxpayer ought to have to deal with as the basis on which he is to be taxed." 32. In a recent Full Bench decision of this court dated November 2, 1982, in T.C.(R) Nos. 78 of 1980 (State of Tamil Nadu v. Arulmurugan & Co. [1982] 51 STC 381), it was held that the appellate authorities perform precisely the same functions as the assessing authority. The Full Bench expressed the view that a tax appeal is a rehearing of the entire assessment and it cannot be equated to adversary proceedings in appeal in civil cases. The following passage (at page 392), from the judgment of the Full Benc…

INTERNATIONAL COMMISSION ON IRRIGATION AND DRAINAGE EMPLOYEES PROVIDENT FUND (ICID PF TRUST),NEW DELHI vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

In the result, both appeals of the assessee are allowed as above

ITA 4203/DEL/2024[2015-16]Status: DisposedITAT Delhi20 Jun 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 10Section 10(21)Section 10(25)(ii)Section 11Section 12ASection 143(1)Section 154

…sts of the country at large the taxpayer ought to have to deal with as the basis on which he is to be taxed." 32. In a recent Full Bench decision of this court dated November 2, 1982, in T.C.(R) Nos. 78 of 1980 (State of Tamil Nadu v. Arulmurugan & Co. [1982] 51 STC 381), it was held that the appellate authorities perform precisely the same functions as the assessing authority. The Full Bench expressed the view that a tax appeal is a rehearing of the entire assessment and it cannot be equated to adversary proceedings in appeal in civil cases. The following passage (at page 392), from the judgment of the Full Benc…

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

ITA 46/RJT/2023[2013-14]Status: DisposedITAT Rajkot19 Jun 2025AY 2013-14

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

ITA 44/RJT/2023[2006-07]Status: DisposedITAT Rajkot19 Jun 2025AY 2006-07

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

ITA 135/RJT/2023[2008-09]Status: DisposedITAT Rajkot19 Jun 2025AY 2008-09

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

ITA 134/RJT/2023[2007-08]Status: DisposedITAT Rajkot19 Jun 2025AY 2007-08

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

In the result, appeals filed by the Revenue, in ITA No

ITA 32/RJT/2019[2010-11]Status: DisposedITAT Rajkot19 Jun 2025AY 2010-11
Section 132Section 142(1)Section 143(2)Section 153ASection 271(1)(c)

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

ITA 31/RJT/2019[2009-10]Status: DisposedITAT Rajkot19 Jun 2025AY 2009-10

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, RAJKOT

ITA 16/RJT/2019[2010-11]Status: DisposedITAT Rajkot19 Jun 2025AY 2010-11

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

THE DY. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT vs. BHARATKUMAR ISHWARBHAI BHATIYA,, RAJKOT

ITA 49/RJT/2018[2013-14]Status: DisposedITAT Rajkot19 Jun 2025AY 2013-14

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

BHARATKUMAR ISHWARBHAI BHATIYA,,RAJKOT vs. ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT

ITA 4/RJT/2018[2013-14]Status: DisposedITAT Rajkot19 Jun 2025AY 2013-14

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

SHRI BHARATKUMAR ISHWARBHAI BHATIYA,RAJKOT-GUJARAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT

ITA 171/RJT/2015[2006-07]Status: DisposedITAT Rajkot19 Jun 2025AY 2006-07

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

PARAS RAMESHCHANDRA DOSHI,RAJKOT vs. THE PCIT - 1, RAJKOT , RAJKOT

ITA 280/RJT/2024[2013-14]Status: DisposedITAT Rajkot11 Jun 2025AY 2013-14
Section 115BSection 132Section 133ASection 139(1)Section 143(2)Section 147Section 148Section 263Section 69A

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

THE DEPUTY COMMR. OF INCOME TAX, CEN. CIR.1,, RAJKOT vs. JAYESH HARAKHJI PATEL,, RAJKOT

ITA 76/RJT/2018[2006-07]Status: DisposedITAT Rajkot28 Mar 2025AY 2006-07

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.59/Rjt/2018 &

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Punglia, CIT.DR
Section 139(1)Section 142(1)Section 143Section 143(2)Section 147Section 148

…ITA Nos. 59 & 76/RJT/2018 (Jayesh Harakhji Patel & IT(SS)A Nos. 86 to 89 & 97 to 99/Rjt/2018 (Ravi V. Hirani) IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आयकर अपील सं./ITA No.59/RJT/2018 & ITA No. 76/Rjt/2018 (निर्धारण वर्ष / Assessment Year: (2006-07) (Hybrid Hearing) Shri Jayesh Harakhji Patel Vs. The ACIT C/o. SADP & Co., Chartered Accountants, B. B. House, 5- Collegewadi, Near Kathiyawad Gymkhana, Rajkot-360001 Central Circle-1, Rajkot & Deputy Commissioner of Shri Jayesh Harakhji Income Tax Patel Central…

INCOME TAX OFFICER , VIJAYAPUR vs. VIKRAM DALICHAND BANDARI , VIJAYAPUR

In the result the appeal filed by the revenue is dismissed

ITA 1390/BANG/2024[2014-15]Status: DisposedITAT Bangalore05 Mar 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear:2014-15

For Appellant: Sri Sudheendra B.R., A.RFor Respondent: Shri D.K. Mishra, D.R
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 69A

…T(A) to be reasonable and logical on the given state of facts and the grounds raised by the assessee on merits of the case by considering the documents/records produced by the assessee. 8.7 Hon’ble Madras High Court in the case of Arul Murugan and Co. (1982) 51 STC 381 has observed as follows:’ “In a tax appeal, the appellate authority is very much committed to the assessment. The appellate authority can itself enter the arena of assessment, either by pursuing further investigation or causing further investigation to be done. It can do so on its own initiative, without being prodded by any of the parties. It ca…

INCOME TAX OFFICER, INTERNATIONAL TAXATION, WARD-1(2), BENGALURU, BENGALURU vs. MS. STANY BASIL MATHIAS, KARNATAKA

In the result, appeal filed by the revenue is dismissed

ITA 1694/BANG/2024[2019-20]Status: DisposedITAT Bangalore24 Feb 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Shri V. Parithivel, D.R
Section 142(1)Section 144Section 144C(1)Section 147Section 148ASection 156Section 250Section 69

…nds raised by the assessee on merits of the case by considering the documents/records produced by the assessee. IT(IT)A No.1694/Bang/2024 M/s. Stany Basil Mathias, Karnataka Page 6 of 7 6.1 Hon’ble Madras High Court in the case of Arul Murugan and Co. (1982) 51 STC 381 has observed as follows:’ “In a tax appeal, the appellate authority is very much committed to the assessment. The appellate authority can itself enter the arena of assessment, either by pursuing further investigation or causing further investigation to be done. It can do so on its own initiative, without being prodded by any of the parties. It ca…

SHRI VISHAL MEHTA ,RAJKOT vs. THE ITO WARD-2 (1) (2), RAJKOT

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 77/RJT/2024[2015-16]Status: DisposedITAT Rajkot07 Jan 2025AY 2015-16

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &
Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

SHRI VISHAL MEHTA ,RAJKOT vs. THE ITO WARD-2(1) (2) RAJKOT, RAJKOT

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 76/RJT/2024[2014-15]Status: DisposedITAT Rajkot07 Jan 2025AY 2014-15

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &
Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

SHRI VISHAL MEHTA,RAJKOT vs. THE ITO WARD-2(1) (2) , RAJKOT

Appeals of the assessee are allowed for statistical purposes, in above terms

ITA 75/RJT/2024[2013-14]Status: DisposedITAT Rajkot07 Jan 2025AY 2013-14

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

For Appellant: Shri Chetan Agarwal, AR &For Respondent: Shri Sanjay Punglia, CIT-DR &
Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 271BSection 69A

…of CIT vs Indian Express (Madurai) Private Limited (1983) 140 ITR 705 (Madras) which is bound form in Ramco Cement Limited Vs DCIT (2015) 55 Taxmann.com 79 (Madras) and which also mentions the decision of State of Tamil Nadu vs Arulmurugan and Company (1982) 51 STC 381 (Madras) (copy enclosed). It is, hence, requested that irrespective of decision of Ld. assessing officer and Ld. CIT(A), Ld. ITAT may independently examine the facts of the case and apply legal provisions, including the settled law that unexplained credit shall be taxed under deeming provisions. Reliance in this regard is further placed on the ord…

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State of Tamil Nadu v. Arulmurugan and Company (51 STC 381) — Cited in 49 Judgments | BharatTax