UCO Bank, Calcutta v. Commissioner of Income Tax, W.B

4 SCC 599Reported decision1999#851 most cited

What is UCO Bank, Calcutta v. Commissioner of Income Tax, W.B authority for?

Circulars and instructions issued by the Central Board of Direct Taxes (CBDT) under Section 119 of the Income Tax Act have the force of law and are binding on all income tax authorities. These circulars can mitigate the rigour of statutory provisions, provide administrative relief, and ensure uniform application of the Act for the benefit of the assessee.

122

judgments rely on this decision, according to BharatTax’s citation analysis of 366,418 Indian tax judgments — from 2012 to 2025.

Also referred to as

UCO Bank Calcutta v CIT · Section 119 · CBDT circulars binding · instructions under Section 119 · force of law circulars · administrative relief assessee · income tax department binding · mitigation of rigour · uniform administration · assessee benefit

Sections most often in play

Section 36(1)(vii)Section 10(34)Section 143(3)Section 14ASection 36(1)(viia)Section 36(1)(viii)Section 37(1)Section 46(4)

Issues it is cited on

section 5(8)closely held companyprincipal director general of income-taxsection 132(5)section 65(b)accumulated profitssection 132(3)section 119(1)section 65asection 62section 36(2)(v)time barred assessment

Judgments citing UCO Bank, Calcutta v. Commissioner of Income Tax, W.B

Harjeet Singh, Haryana vs. DCIT, Central Circle-31, New Delhi

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

ITA 2031/DEL/2022[2018-19]Status: DisposedITAT Delhi20 Nov 2023AY 2018-19

Bench: Shri Shamim Yahya & Shri Kul Bharatharjeet Singh, Vs. Dcit, Central Circle 31, House No.22, Mandkola The Hatin, New Delhi. Faridabad – 121 004 (Haryana).

For Appellant: Shri Aman Garg, CAFor Respondent: Shri T. James Singson, CIT DR
Section 119Section 131Section 133

…r cannot be side-stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Therefore,…

Meena Gupta, Delhi vs. DCIT, Central Circle-14, New Delhi

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

ITA 1194/DEL/2020[2011-12]Status: DisposedITAT Delhi15 Nov 2023AY 2011-12

Bench: Shri Shamim Yahya & Shri Kul Bharatmeena Gupta, Vs. Dcit, Central Circle 14, C/O Bk Kapur & Company, Ca, New Delhi. Navyug Market, Ghaziabad – 201 001 (Uttar Pradesh).

For Appellant: Shri Madhav Kapoor, AdvocateFor Respondent: Ms. Nimisha Singh, CIT DR
Section 119Section 131Section 133

…r cannot be side-stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Therefore,…

Tregarron Limited, England vs. ACIT Circle International Tax 3(1)(2), New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 308/DEL/2023[2016-17]Status: DisposedITAT Delhi09 Nov 2023AY 2016-17

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Rajan Vora, CAFor Respondent: Shri Vizay B. Vasanta, CIT DR
Section 144C(5)

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Therefore,…

Tregarron Limited, England vs. ACIT Circle International Tax 3(1)(2), New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 307/DEL/2023[2015-16]Status: DisposedITAT Delhi09 Nov 2023AY 2015-16

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Rajan Vora, CAFor Respondent: Shri Vizay B. Vasanta, CIT DR
Section 144C(5)

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Therefore,…

Zebra Technologies Asia Pacific Pte Ltd, Bangaluru vs. Dcitcircle Int.Taxation Tax 3(1)(1), Delhi

In the result, both the appeals filed by the assessee are allowed as

ITA 1972/DEL/2022[2019-20]Status: DisposedITAT Delhi09 Nov 2023AY 2019-20

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144C(5)

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Therefore,…

Zebra Technologies Asia Pacific Pte Ltd, Bangaluru vs. DCIT, Circle Int.Taxation-3(1)(1)., New Delhi

In the result, both the appeals filed by the assessee are allowed as

ITA 1971/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Nov 2023AY 2018-19

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144C(5)

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Therefore,…

Tableau International Unlimited Company the Oval Shelbourne Road Ballsbridge Dublin, Ireland Do4E7K5, Delhi vs. DCIT, Circle 3(1)(1) Int Taxation, Delhi

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

ITA 1874/DEL/2022[2018-19]Status: DisposedITAT Delhi07 Nov 2023AY 2018-19

Bench: Shri Shamim Yahya & Shri Kul Bharattableau International Unlimited Company, Vs. Dcit, Circle 3(1)(1), C/O Mnk & Associate Company Secretaries, International Taxation, G – 41, Ground Floor, Delhi. West Patel Nagar, New Delhi – 110 008. (Pan : Aaect8018J) (Appellant) (Respondent) Assessee By : Shri Ravi Sharma, Advocate Ms. Shruti Khimta, Ar Revenue By : Shri Vijay B. Vasanta, Cit Dr

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 143Section 144CSection 144C(5)

…r cannot be side-stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 11 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Theref…

Innio Jenbacher Gmbh & Co Og (Formerly Known As Ge Jenbacher Gmbh & Co Ohg), Austria vs. ACIT, Circle-1(3)(1), Int. Taxation, New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 920/DEL/2023[2013-14]Status: DisposedITAT Delhi06 Nov 2023AY 2013-14

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144CSection 144C(5)Section 147

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. regard to…

Innio Jenbacher Gmbh & Co. Og, Austria vs. ACIT, Circle 1(3)(1), International Taxation, New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 781/DEL/2023[2013-14]Status: DisposedITAT Delhi06 Nov 2023AY 2013-14

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144CSection 144C(5)Section 147

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. regard to…

Innio Jenbacher Gmbh & Co Og, Austria vs. ACIT, Circle-1(3)(1) Int. Taxation, New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 764/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Nov 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144CSection 144C(5)Section 147

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. regard to…

Innio Jenbacher Gmbh & Co Og, Austria vs. ACIT, Circle-1(3)(1) Int. Taxation, New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 763/DEL/2023[2016-17]Status: DisposedITAT Delhi06 Nov 2023AY 2016-17

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144CSection 144C(5)Section 147

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. regard to…

Innio Jenbacher Gmbh & Co Og, Austria vs. ACIT, Circle-1(3)(1), Int. Taxation, New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 762/DEL/2023[2015-16]Status: DisposedITAT Delhi06 Nov 2023AY 2015-16

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144CSection 144C(5)Section 147

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. regard to…

Rhone Associates P.Ltd (Successor to Proactive Telecommunication P.Ltd, Ujwal Network P.Ltd and Sanchi Infratech P.Ltd), Gurgaon vs. ACIT, Central Circle-29, New Delhi

In the result, this appeal filed by the assessee is allowed as indicated

ITA 168/DEL/2023[2012-13]Status: DisposedITAT Delhi01 Nov 2023AY 2012-13

Bench: Shri Shamim Yahya & Shri Yogesh Kumar Usrhone Associates Pvt. Ltd., Vs. Acit, (Successor To Proactive Telecommunication Pvt.Ltd., Central Circle-29, Ujwal Network Pvt. Ltd. & Sanchi Infratech Pvt.Ltd.) O-44, New Mahavir Nagar, Gurgaon – 122 001 (Haryana).

For Appellant: Shri Aman Garg, CAFor Respondent: Shri P.N. Baranwal, CIT DR
Section 119Section 131Section 133

…cannot be side- stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P. Varghese vs. Income-tax Officer 1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599], ” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Therefore,…

M/S Asian Hotels Ltd vs. Commissioner of Income Tax

The appeal is disposed of in the aforesaid terms

ITA/1398/2006HC Delhi09 Oct 2023

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 37

…Signature Not Verified ITA 1398/2006 Page 10 of 29 The respondent/revenue is bound by its circulars concerning the treatment of expenditure. [See KP Verghese v. Income Tax Officer (1981) 4 SCC 173 AIR 1981 SC 1992 and UCO Bank v CIT (1999) 4 SCC 599]. (ix) It is well-established that the expression provided in Section 37 of the Act for the “purposes of the business” includes expenditure incurred for the preservation and protection of assets and property. [See CIT v. Malayalam Plantations, AIR 1964 SC 1722]. (x) The statutory authorities have wrongly applied the test of enduring benef…

Thales Six Gts France Sas, Delhi vs. DCIT, 3(1)(1), Delhi

In the result, this appeal is allowed as indicated above

ITA 2380/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Oct 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharma[Assessment Year: 2017-18]

Section 119Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘I’: NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER [Assessment Year: 2017-18] Thales Six GTS France SAS, The Deputy Commissioner of 7B, 2nd Floor, Main Pusa Road Income Tax, Rajendra Park, Delhi-110060 Vs Circle International Taxation 3(1)(1) Delhi-110002 PAN-AADCT0116G Assessee Revenue Assessee by Sh. Vishal Kalra, Adv. Ms. Reema Grewal, CA Revenue by Sh. Manvendra Goyal, CIT(DR) Date of Hearing 25.09.2023 Date of Pronouncement 09.10.2023 ORDER PER SHAMIM YAHYA, AM, This appeal by the assessee is directed ag…

Shri Mayur Bansal, Gwalior vs. The DCIT, Central, Bhopal

In the result, appeals of the revenue in IT(SS)ANo

ITA 81/IND/2021[2018-19]Status: DisposedITAT Indore28 Aug 2023AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 119Section 153ASection 156

…lar cannot be side-stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P.Varghese vs. Income-tax Officer1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599].” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Therefore,…

Shri Ishak, Indore vs. The ITO 5(4), Indore

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

ITA 13/IND/2023[2011-12]Status: DisposedITAT Indore24 Aug 2023AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Ishak Ito 5(4) Kasturbagram S.O. Mundla Indore Vs. Nayata, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Akxpi 6044 D Assessee By Shri Milind Wadhwani, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 21.08.2023 Date Of Pronouncement 24.08.2023

Section 144Section 147Section 154

…lar cannot be side-stepped causing prejudice to the assessee by bringing to naught the object for which it is issued. [See: K.P.Varghese vs. Income-tax Officer1, [1981] 7 Taxman 13 (SC); Also see: UCO Bank, Calcutta v. Commissioner of Income Tax, W.B., (1999) 4 SCC 599].” 18. The argument advanced on behalf the appellant/revenue, that recourse can be taken to Section 292B of the Act, is untenable, having regard to the phraseology used in paragraph 4 of the 2019 Circular. 19. The object and purpose of the issuance of the 2019 Circular, as indicated hereinabove, inter alia, was to create an audit trail. Therefore,…

Dy CIT-1(3)(2), Mumbai vs. Maharashtra State Co-Operative Bank Limited, Mumbai

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

ITA 3916/MUM/2019[2013-14]Status: DisposedITAT Mumbai21 Aug 2023AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

For Appellant: Mr. Sushil LakhaniFor Respondent: Mrs. Riddhi Mishra, CIT-DR
Section 143(3)Section 3Section 36(1)Section 36(1)(vii)

…e circular is in force, it aids the uniform and proper administration and application of the provisions of the administration and application of the provisions of the administration and application of the provisions of the Act. (Refer to UCO Bank v. CIT(1999) 4 SCC 599). " Act. (Refer to UCO Bank v. CIT(1999) 4 SCC 599). " Act. (Refer to UCO Bank v. CIT(1999) 4 SCC 599). " 18. In case of 18. In case of UCO Bank vs. Commissioner of Income UCO Bank vs. Commissioner of Income Tax reported in 237 ITR 889 the Sup reported in 237 ITR 889 the Supreme Court in reme Court in connection with effect of circulars issued by t…

M/S the Maharashtra State Co. Op Bank Ltd., Mumbai vs. ITO-1(3)(3), Mumbai

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

ITA 3878/MUM/2019[2013-14]Status: DisposedITAT Mumbai21 Aug 2023AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

For Appellant: Mr. Sushil LakhaniFor Respondent: Mrs. Riddhi Mishra, CIT-DR
Section 143(3)Section 3Section 36(1)Section 36(1)(vii)

…e circular is in force, it aids the uniform and proper administration and application of the provisions of the administration and application of the provisions of the administration and application of the provisions of the Act. (Refer to UCO Bank v. CIT(1999) 4 SCC 599). " Act. (Refer to UCO Bank v. CIT(1999) 4 SCC 599). " Act. (Refer to UCO Bank v. CIT(1999) 4 SCC 599). " 18. In case of 18. In case of UCO Bank vs. Commissioner of Income UCO Bank vs. Commissioner of Income Tax reported in 237 ITR 889 the Sup reported in 237 ITR 889 the Supreme Court in reme Court in connection with effect of circulars issued by t…

Polisetty Somasundaram, Guntur vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee for the AY 2020-21 is allowed

ITA 180/VIZ/2023[2020-21]Status: DisposedITAT Visakhapatnam18 Aug 2023AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.172 To 180/Viz/2023 ("नधा"रणवष"/ Assessment Year : 2012-13 To 2020-21) M/S. Polisetty Somasundaram, Vs. The Deputy Commissioner Of D.No. 8-24-31, Main Road, Income Tax, Mangalagiri Road, Central Circle-1, Guntur – 522001. Guntur. Pan: Aacfp 7251 J (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Appellant By : Sri M.V. Prasad, Ar ""याथ"क"ओरसे/ Respondent By : Sri Mn Murthy Naik, Cit-Dr

For Appellant: Sri M.V. Prasad, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 127Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153B

…articular provision for the benefit of the assessee in certain specified circumstances. So long as the circular is in force, it aids the uniform and proper administration and application of the provisions of the Act. {Refer to UCO Bank, Calcutta v. CIT [1999] 4 SCC 599.” 25. Similarly, the Hon’ble jurisdictional High Court in the case of Commissioner of Income Tax vs. Smt. Nayana P. Dedhia reported in [2004] 270 ITR 572 (AP) relying on the decision of the Hon’ble Supreme Court in the case of UCO Bank vs. CIT [1999] 237 ITR 889 (SC) observed as follows: “The Supreme Court in this judgment, which is clear from…