Tanna And Modi v. CIT (SC)

SURYA SINGHAL,KOTA vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

…nue authorities\nIn the case of CWT vs. SanwarmalShivkumar 171 ITR 337 the\nJurisdictional High Court of Rajasthan held that the officers of the\nDepartment are bound by the circulars of the board. The Hon'ble Supreme\nCourt in case of Tanna And Modi vs. CIT, 292 ITR 209 (SC) has held\nthat a fortiori, clarificatory circulars issued by the Central Board of Direct\nTaxes may also be taken into consideration for the purpose of construction\nof the statute. The Hon'ble Supreme Court in case of Kerala State\nIndustrial Dev. Corporation Ltd., 259 ITR 51 (SC) has also held that\nFinance Minister's speech before Parliam…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

…e of income which leads to information on what has not been disclosed or is not likely to be disclosed before the Income Tax Departments rather than on obtaining confession. The assessee also relied upon the judgment in the case of Tanna And Modi Vs. CIT (SC) 292 ITR 209, Kerala State Industrial Dev. Corpn. Ltd. Vs. CIT (SC), 273 ITR 305 CIT Vs. Durgesh Oil Mills (All), Circular-CBOT Circular binding on Income Tax Authorities. Records reveals that the search proceedings were commenced on 16.1.2019 simultaneously at the residential premises of the directors of the assessee company as well as business premises of t…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISSTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JAIPUR

…e of income which leads to information on what has not been disclosed or is not likely to be disclosed before the Income Tax Departments rather than on obtaining confession. The assessee also relied upon the judgment in the case of Tanna And Modi Vs. CIT (SC) 292 ITR 209, Kerala State Industrial Dev. Corpn. Ltd. Vs. CIT (SC), 273 ITR 305 CIT Vs. Durgesh Oil Mills (All), Circular-CBOT Circular binding on Income Tax Authorities. Records reveals that the search proceedings were commenced on 16.1.2019 simultaneously at the residential premises of the directors of the assessee company as well as business premises of t…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

…income which leads to\ninformation on what has not been disclosed or is not likely to be disclosed\nbefore the Income Tax Departments rather than on obtaining confession.\nThe assessee also relied upon the judgment in the case of Tanna And\nModi Vs. CIT (SC) 292 ITR 209, Kerala State Industrial Dev. Corpn. Ltd.\nVs. CIT (SC), 273 ITR 305 CIT Vs. Durgesh Oil Mills (All), Circular-CBOT\nCircular binding on Income Tax Authorities.\nRecords reveals that the search proceedings were commenced on\n16.1.2019 simultaneously at the residential premises of the directors of the\nassessee company as well as business premises…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

…e of income which leads to information on what has not been disclosed or is not likely to be disclosed before the Income Tax Departments rather than on obtaining confession. The assessee also relied upon the judgment in the case of Tanna And Modi Vs. CIT (SC) 292 ITR 209, Kerala State Industrial Dev. Corpn. Ltd. Vs. CIT (SC), 273 ITR 305 CIT Vs. Durgesh Oil Mills (All), Circular-CBOT- Circular binding on Income Tax Authorities. Records reveals that the search proceedings were commenced on 16.1.2019 simultaneously at the residential premises of the directors of the assessee company as well as business premises of…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISSTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1, JAIPUR

…e of income which leads to information on what has not been disclosed or is not likely to be disclosed before the Income Tax Departments rather than on obtaining confession. The assessee also relied upon the judgment in the case of Tanna And Modi Vs. CIT (SC) 292 ITR 209, Kerala State Industrial Dev. Corpn. Ltd. Vs. CIT (SC), 273 ITR 305 CIT Vs. Durgesh Oil Mills (All), Circular-CBOT Circular binding on Income Tax Authorities. Records reveals that the search proceedings were commenced on 16.1.2019 simultaneously at the residential premises of the directors of the assessee company as well as business premises of t…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRE CIRCLE -1, JAIPUR

…income which leads to\ninformation on what has not been disclosed or is not likely to be disclosed\nbefore the Income Tax Departments rather than on obtaining confession.\nThe assessee also relied upon the judgment in the case of Tanna And\nModi Vs. CIT (SC) 292 ITR 209, Kerala State Industrial Dev. Corpn. Ltd.\nVs. CIT (SC), 273 ITR 305 CIT Vs. Durgesh Oil Mills (All), Circular-CBOT\nCircular binding on Income Tax Authorities.\nRecords reveals that the search proceedings were commenced on\n16.1.2019 simultaneously at the residential premises of the directors of the\nassessee company as well as business premises…

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1, JAIPUR

…income which leads to\ninformation on what has not been disclosed or is not likely to be disclosed\nbefore the Income Tax Departments rather than on obtaining confession.\nThe assessee also relied upon the judgment in the case of Tanna And\nModi Vs. CIT (SC) 292 ITR 209, Kerala State Industrial Dev. Corpn. Ltd.\nVs. CIT (SC), 273 ITR 305 CIT Vs. Durgesh Oil Mills (All), Circular-CBOT\nCircular binding on Income Tax Authorities.\n\nRecords reveals that the search proceedings were commenced on\n16.1.2019 simultaneously at the residential premises of the directors of the\nassessee company as well as business premis…

SHANTI KUMAR SETHI AND SONS,JAIPUR vs. ACIT CIRCLE-1, JAIPUR, JAIPUR

Bench: The Ld. Cit(A) Was Filed By The Assessee Against The Order Dated 07.12.2019 Passed Under Section 143(3) Of The Income Tax Act, By Acit, Circle-01, Jaipur.

…Act, say for example, the Prevention of Corruption Act. Whereas charges under the Prevention of Corruption Act may fail, no sanction having been accorded therefore, the charges under the Penal Code would not." 32. In Tanna & Modi v. CIT [2007] 161 Taxman 329/292 ITR 209 also, this court held, similarly that immunity granted for one purpose, cannot be extended for another: "20. It may be necessary for the aforementioned purpose to bear in mind that the immunity granted pursuant to acceptance of a declaration made under the voluntary taxation scheme or Kar Vivad Samadhan Scheme, 1998 does not lead to a total immun…