Sunil Siddharthbhai v. CIT

156 ITR 509Supreme Court of India1985#1397 most cited

What is Sunil Siddharthbhai v. CIT authority for?

A partner's contribution of a personal asset to a partnership firm does not amount to a "transfer" for capital gains purposes under the Income-tax Act, as the consideration (the partner's interest in the firm) is indeterminate, and the computational machinery for capital gains fails.

82

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2013 to 2025.

Also referred to as

Sunil Siddharthbhai v. CIT · 156 ITR 509 · capital gains · transfer to partnership firm · partner's capital contribution · section 45 · section 2(47) transfer · indeterminate consideration · machinery failure principle · legislative amendment 45(4) · partnership asset contribution

Sections most often in play

Section 143(3)Section 45(4)Section 10(38)Section 112ASection 139(1)Section 2(22B)Section 2(47)Section 244A

Issues it is cited on

section 48section 45genuineness of the transactionreasonable causescrutiny assessmentsection 80transferprevious yearsection 11personcompanybusiness

Judgments citing Sunil Siddharthbhai v. CIT

The ITO, WD-2, Thodupuzha vs. Sri.E.J.Sony, Kothamangalam

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

ITA 355/COCH/2006[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 2(24)(vi)Section 48

…f transfer of capital asset to the firm and specifically the deeming provision therein to adopt the amount recorded in books of the firm as full value of consideration. According to the Ld. AR, the Apex Court's judgment in Sunil Sidharthbhai Vs. CIT (1985) (156 ITR 509), relied on by the CIT(A) in which examination by the assessing officer as to the genuineness of the transaction and formation of the partnership firm was justified, had been rendered for a period prior to 01/04/1988. Moreover, it was submitted that the genuineness of the partnership was examined by the Apex Court in a petition filed for Special…

The ITO, Ward-2, Thodupuzha vs. Sri.Martin Johny, Kothamangalam

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

ITA 354/COCH/2006[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 2(24)(vi)Section 48

…f transfer of capital asset to the firm and specifically the deeming provision therein to adopt the amount recorded in books of the firm as full value of consideration. According to the Ld. AR, the Apex Court's judgment in Sunil Sidharthbhai Vs. CIT (1985) (156 ITR 509), relied on by the CIT(A) in which examination by the assessing officer as to the genuineness of the transaction and formation of the partnership firm was justified, had been rendered for a period prior to 01/04/1988. Moreover, it was submitted that the genuineness of the partnership was examined by the Apex Court in a petition filed for Special…

Sri.Essa Ismail Sait, Ernakulam vs. The ACIT, Cir-2(1), Ernakulam

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

ITA 605/COCH/2005[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 2(24)(vi)Section 48

…f transfer of capital asset to the firm and specifically the deeming provision therein to adopt the amount recorded in books of the firm as full value of consideration. According to the Ld. AR, the Apex Court's judgment in Sunil Sidharthbhai Vs. CIT (1985) (156 ITR 509), relied on by the CIT(A) in which examination by the assessing officer as to the genuineness of the transaction and formation of the partnership firm was justified, had been rendered for a period prior to 01/04/1988. Moreover, it was submitted that the genuineness of the partnership was examined by the Apex Court in a petition filed for Special…

M/S Jupiter Capital Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax Circle-11(5), Bangalore

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

ITA 445/BANG/2018[2014-15]Status: DisposedITAT Bangalore29 Nov 2018AY 2014-15

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodiaassessment Year : 2014-15

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri D. Sudhakara Rao, CIT (DR)
Section 2(47)

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI SUNIL KUMAR YADAV, JUDICIAL MEMBER AND SHRI ARUN KUMAR GARODIA, ACCOUNTANT MEMBER Assessment Year : 2014-15 The Assistant M/s. Jupiter Capital Pvt. Ltd., Commissioner of Income # 54, Richmond Road, Vs. Tax, Bangalore – 560 025. Circle – 4 (1) (1), PAN: AABCJ5666R Bangalore. APPELLANT RESPONDENT Assessee by : Shri S. Parthasarathi, Advocate Revenue by : Shri D. Sudhakara Rao, CIT (DR) Date of hearing : 12.09.2018 Date of Pronouncement : 29.11.2018 O R D E R Per Shri A.K. Garodia, Accountant Member This appeal is filed by the assessee and the…

Skylark Build, Mumbai vs. Asst CIT Cen Cir 4(2), Mumbai

ITA 4370/MUM/2015[2007-08]Status: DisposedITAT Mumbai29 Aug 2018AY 2007-08

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K Assessment Year: 2008-09 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K

…rupees seventyfive lakhs. That being so, the capital gains made by the company were Rs. 27,04,772 as held by the High Court. In the result both these appeals fail and they are dismissed with costs.” 5.4. In another case, in Sunil Siddarthbhai vs CIT (1985) 156 ITR 509, the Hon'ble Apex Court observed held as under:- “This and the connected appeal, filed by certificate granted by the High Court, raise the interesting question whether the capital contribution by a partner to the assets of a partnership firm at an appreciated value can be said to give rise to a capital gain in his hands liable to income-tax. In…

Skylark Build, Mumbai vs. Asst CIT Cen Cir 4(2), Mumbai

ITA 3237/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2018AY 2008-09

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K Assessment Year: 2008-09 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K

…rupees seventyfive lakhs. That being so, the capital gains made by the company were Rs. 27,04,772 as held by the High Court. In the result both these appeals fail and they are dismissed with costs.” 5.4. In another case, in Sunil Siddarthbhai vs CIT (1985) 156 ITR 509, the Hon'ble Apex Court observed held as under:- “This and the connected appeal, filed by certificate granted by the High Court, raise the interesting question whether the capital contribution by a partner to the assets of a partnership firm at an appreciated value can be said to give rise to a capital gain in his hands liable to income-tax. In…

DCIT Cen Cir 4(2), Mumbai vs. Sudhakar M. Shetty, Mumbai

ITA 2906/MUM/2015[2011-12]Status: DisposedITAT Mumbai29 Aug 2018AY 2011-12

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2007-08 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K Assessment Year: 2008-09 M/S. Skylark Build Acit, Central Circle-4(2) 402, Sagar Avenue 4Th Floor, Aayakar Bhavan बनाम/ Plot B-54, Junction Of M.K.Road, Vs. Lallubhai Park & S.V. Road Mumbai 400020 Andheri (W), Mumbai 400058 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aazfs0404K

…rupees seventyfive lakhs. That being so, the capital gains made by the company were Rs. 27,04,772 as held by the High Court. In the result both these appeals fail and they are dismissed with costs.” 5.4. In another case, in Sunil Siddarthbhai vs CIT (1985) 156 ITR 509, the Hon'ble Apex Court observed held as under:- “This and the connected appeal, filed by certificate granted by the High Court, raise the interesting question whether the capital contribution by a partner to the assets of a partnership firm at an appreciated value can be said to give rise to a capital gain in his hands liable to income-tax. In…

ACIT, Corporate Circle-1(2), Bhubaneswar vs. M/S. T.S.Alloys Limited, Bhubaneswar

In the result, appeals filed by the revenue are dismissed

ITA 405/CTK/2017[2013-14]Status: DisposedITAT Cuttack09 Aug 2018AY 2013-14

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

For Appellant: Mss Swati Kejriwal, ARFor Respondent: Shri Saad Kidwai, CIT DR

…IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH, CUTTACK BEFORE S/SHRI N.S SAINI, ACCOUNTANT MEMBER AND PAVAN KUMAR GADALE, JUDICIAL MEMBER ITA Nos.404 & 405/CTK/2017 Assessment Years : 2012-13 & 2013-14 ACIT Corporate Circle -1(2), Vs. M/s. T.S.Alloys Limited, N- Bhubaneswar. 3/24, IRC Village, Nayapali, Bhubaneswar. PAN/GIR No.AACCR 7005 H (Appellant) .. ( Respondent) Assessee by : Mss Swati Kejriwal, AR Revenue by : Shri Saad Kidwai, CIT DR Date of Hearing : 08/08/ 2018 Date of Pronouncement : 9 /08/ 2018 O R D E R Per N.S.Saini, AM These are appeals filed by the revenue against separate orders of…

ACIT, Corporate Circle-1(2), Bhubaneswar vs. M/S. T.S.Alloys Limited, Bhubaneswar

In the result, appeals filed by the revenue are dismissed

ITA 404/CTK/2017[2012-13]Status: DisposedITAT Cuttack09 Aug 2018AY 2012-13

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

For Appellant: Mss Swati Kejriwal, ARFor Respondent: Shri Saad Kidwai, CIT DR

…IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH, CUTTACK BEFORE S/SHRI N.S SAINI, ACCOUNTANT MEMBER AND PAVAN KUMAR GADALE, JUDICIAL MEMBER ITA Nos.404 & 405/CTK/2017 Assessment Years : 2012-13 & 2013-14 ACIT Corporate Circle -1(2), Vs. M/s. T.S.Alloys Limited, N- Bhubaneswar. 3/24, IRC Village, Nayapali, Bhubaneswar. PAN/GIR No.AACCR 7005 H (Appellant) .. ( Respondent) Assessee by : Mss Swati Kejriwal, AR Revenue by : Shri Saad Kidwai, CIT DR Date of Hearing : 08/08/ 2018 Date of Pronouncement : 9 /08/ 2018 O R D E R Per N.S.Saini, AM These are appeals filed by the revenue against separate orders of…

DCIT Circle 1, Tirunelveli vs. Rm Kv Fashion Garments Pvt Ltd, Tirunelveli

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

ITA 761/CHNY/2018[2014-15]Status: DisposedITAT Chennai30 Apr 2018AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

ACIT Circle 1, Tirunelveli vs. M/S Rm Kv Fbrics Private Limited, Tirunelveli

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

ITA 760/CHNY/2018[2014--15]Status: DisposedITAT Chennai30 Apr 2018

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

ACIT Circle 1, Tirunelveli vs. M/S Rm K V Silks Private Limited, Tirunelveli

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

ITA 759/CHNY/2018[2014-15]Status: DisposedITAT Chennai30 Apr 2018AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

M/S Rm Kv Fbrics Private Limited, Tirunelveli vs. ACIT Circle 1, Tirunelveli

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

ITA 614/CHNY/2018[2014-15]Status: DisposedITAT Chennai30 Apr 2018AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

M/S Rm K V Silks Private Limited, Tirunelveli vs. ACIT Circle 1, Tirunelveli

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

ITA 613/CHNY/2018[2014-15]Status: DisposedITAT Chennai30 Apr 2018AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

DCIT Circle 1, Tirunelveli vs. Rmkv Fashion Garments Pvt. Ltd., Tirunelveli

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

ITA 1626/CHNY/2017[2013-14]Status: DisposedITAT Chennai30 Apr 2018AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

DCIT Circle 1, Tirunelveli vs. Rmkv Fashion Garments Pvt. Ltd., Tirunelveli

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

ITA 1625/CHNY/2017[2012-13]Status: DisposedITAT Chennai30 Apr 2018AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

DCIT Circle 1, Tirunelveli vs. Rmkv Fabrics Pvt. Ltd., Tirunelveli

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

ITA 1624/CHNY/2017[2013-14]Status: DisposedITAT Chennai30 Apr 2018AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

DCIT Circle 1, Tirunelveli vs. Rmkv Fabrics Pvt. Ltd., Tirunelveli

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

ITA 1623/CHNY/2017[2012-13]Status: DisposedITAT Chennai30 Apr 2018AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

DCIT Circle 1, Tirunelveli vs. Rmkv Silks Pvt. Ltd., Tirunelveli

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

ITA 1622/CHNY/2017[2013-14]Status: DisposedITAT Chennai30 Apr 2018AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…

DCIT Circle 1, Tirunelveli vs. Rmkv Silks Pvt. Ltd., Tirunelveli

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

ITA 1621/CHNY/2017[2012-13]Status: DisposedITAT Chennai30 Apr 2018AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyq आयकर अपील सं./Ita No.1621/Chny/2017 "नधा"रण वष" /Assessment Year: 2012-13 Dy. Commissioner Of Income Tax, M/S. Rmkv Silks Pvt. Ltd., Circle-1, Vs. 176F, Trivandrum Road, Tirunelveli. Tirunelveli – 627 003. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.1593/Chny/2017 & Cross Appeal By Revenue In Ita No.1622/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14 M/S. Rmkv Silks Pvt. Ltd., Vs. Dy. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, Tirunelveli. [Pan: Aafcr 4024B] आयकर अपील सं./Ita No.613/Chny/2018 Cross Appeal By Revenue In Ita No.759/Chny/2018 "नधा"रण वष" /Assessment Year: 2014-15 M/S. Rmkv Silks Pvt. Ltd., Vs. Asst. Commissioner Of Income 176F, Trivandrum Road, Tax, Tirunelveli – 627 003. Circle-1, [Pan: Aafcr 4024B] Tirunelveli.

Section 47

…alue of his share in the net partnership assets as on the date of dissolution or retirement after a deduction of liabilities and prior charges..." 5.4 This principle was followed again by Hon’ble Supreme Court in the case of Sunil Siddharthbhai v. CIT [1985] 159 ITR 509 (SC) in the context of applicability of provisions of capital gains on the transfer of personal asset of the partner to the partnership firm as a capital contribution after referring to the judgment of Hon’ble Supreme Court in the case of Addanki Narayanappa v. Bhaskara Krishnappa (supra). 5.5 Having regard to the above principle of law, the ac…