Trustees of Parsi Panchayat Funds & Properties v. Director of Income-tax

57 ITD 328Income Tax Appellate Tribunal1996#25278 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2019 to 2024.

Judgments citing Trustees of Parsi Panchayat Funds & Properties v. Director of Income-tax

M/S. Rdc Ventures, Mumbai vs. PCIT-27, Mumbai

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

ITA 1915/MUM/2023[2018-19]Status: DisposedITAT Mumbai09 Feb 2024AY 2018-19

Bench: Shri Vikas Awasthy & Shri Amarjit Singhm/S Rdc Ventures Vs. Principal Commissioner Office No.-110 Of Income Tax-27 Ridhhisidhhi Premises Room No. 401, 4 Th Floor, Society, Near Sahakar Tower No. 6, Vashi Talkies Tilak Nagar, Railway Station, Chembur (West) Mumbai- Commercial Complex, 400089 Vashi, Navi Mumbai -400703 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aakfr0914Q Appellant .. Respondent Appellant By : Dhran Gandhi Respondent By : Sanyogita Nagpal Date Of Hearing 29.11.2023 Date Of Pronouncement 09.02.2024

For Appellant: Dhran GandhiFor Respondent: Sanyogita Nagpal

Section 143(2)Section 143(3)Section 263

…urther submitted that faceless assessing officer is subordinate to PCIT of assessment unit, therefore, territorial PCIT, Mumbai has no power to exercise his supervisory power u/s 263 of the Act. He also referred the various judicial pronouncements: “i. (1996) 57 ITD 328 (Bom) Trustees of Parsi Panchayat Funds & Properties vs. DIT ii. 203 ITR 108 (Bom) CIT vs. Gabrial India Ltd.; 314 ITR 81(SC) CIT vs. Greenworld Corporation iii. 152 TTJ (Mumbai) 265 Essar Steel Ltd. vs. Addl. CIT iv. ITA(TP) no. 3121and 3122/Mum./2013 Tata Communications Limited vs. DCIT dated 20.12.2013 v. 132 taxmann.com 231 (Del) Abha Bansal v…

M/S. Honda Siel Power Products Ltd., Gautam Budh Nagar vs. ACIT, New Delhi

In the result the appeal filed by the assessee is dismissed

ITA 2299/DEL/2014[2007-08]Status: DisposedITAT Delhi23 Oct 2020AY 2007-08

Bench: Shri R.K. Panda & Shri Kuldip Singhassessment Year: 2007-08 Honda Siel Power Products Ltd., Vs Acit, Plot No.5, Sector-41 (Kasna), Circle-12(1), Greater Noida Industrial New Delhi. Development Area, Gautam Budh Nagar Pan: Aaach8464L (Appellant) (Respondent) Assessee By : Shri Neeraj Jain, Advocate Ms Shaily Gupta, Ca & Ms Mrinal Goyal, Ca Revenue By : Ms Sunit Singh, Cit-Dr Date Of Hearing : 12.10.2020 Date Of Pronouncement : 23.10.2020 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 14Th February 2014 Passed U/S 263 By The Cit, Delhi-4, Delhi, For Assessment Year 2007-08. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company Engaged In The Business Of Manufacturing Of Portable Generating Sets, Ic Engines, Water Pumping Sets & Manufacture & Processing Of Pressure Die-Casting Parts. It Filed It'S Return Of Income On 27Th October 2007 Declaring Nil Income. Subsequently, The Assessee Filed A Revised Return On 29Th October 2007 Declaring Total Income At Rs.31,49,18,923/-. The Ao Passed The Order Under Section 143(3) Read With Section 144C Of The Act On 24Th October 2011, Determining The Total Income Of The Assessee At Rs.44,78,49,680/- Wherein He Made Addition Of Rs.13,29,30,660/- Under Various Heads Such As Royalty, Technical Guidance, Expert Commission & On Account Of Tp Adjustment.

For Appellant: Shri Neeraj Jain, AdvocateFor Respondent: Ms Sunit Singh, CIT-DR

Section 143(3)Section 144CSection 234BSection 263Section 43B

…the case of Orient (Goa) Ltd. v DCIT: 66 ITD 479 x. Decision of the Pune Bench of the Tribunal in the case of J R. Agarwal v ACIT: 75 ITD 270 xi. Decision of the Bombay Bench of the Tribunal in the case of Trustees of Parsi Panchayat Funds & Properties v DIT: 57 ITD 328 xii. Decision of the Bombay High Court in the case of Virendra Kumar Jhamb v N.K. Vohra: 222 CTR 88 12 15. The ld. DR, on the other hand, heavily relied on the order of the CIT in exercising the powers under section 263. So far as the argument of the ld. counsel that since the order was passed under section 144C pursuant to the direction of the D…

Philips India Ltd., Kolkata vs. PCIT-IV, Kolkata

In the result, appeal of the assessee is dismissed

ITA 1142/KOL/2016[2009-2010]Status: DisposedITAT Kolkata27 Mar 2019AY 2009-2010

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi] I.T.A. No. 1142/Kol/2016 Assessment Year: 2009-10 Philips India Limited..........……………………………………....………………..…………………….….Appellant Earlier Known As Philips Electronics India Limited 7 No. Justice Chandra Madhab Road Kolkata – 700 020 [Pan : Aabcp 9487 A] Principal Commissioner Of Income Tax - Iv, Kolkata…….............…....................…...Respondent Appearances By: Shri P.J. Pardiwala, Sr. Advocate & Shri Navneet Misra, Advocate, Appeared On Behalf Of The Assessee. Shri Robin Choudhury, Addl. Cit D/R, Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : January 10Th, 2019 Date Of Pronouncing The Order : March 27Th, 2019 O R D E R Per J. Sudhakar Reddy :-

Section 143(3)Section 263Section 32

…DRP u/s 144C of the Act using his revisionary powers u/s 263 of the Act. He relied on the propositions of law laid down in the order of the Mumbai Bench of the ITAT in the case of Trustees of Parsi Panchayat Funds & Properties v. Director of Income-tax [1996] 57 ITD 328 (BOM.) and submitted that when a view was taken and when an order was passed by the Assessing Officer pursuant to the directions of a superior authority the 5 I.T.A. No. 1142/Kol/2016 Assessment Year: 2009-10 Philips India Limited same could not be the subject matter of revision u/s 263 of the Act because:- i. The Assessing Officer could not be…