How many judgments cite UCO Bank v. CIT?

486 judgments on BharatTax cite UCO Bank v. CIT (237 ITR 889), spanning 2010 to 2026.

Which sections of the Income Tax Act does UCO Bank v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 153A, Section 148, Section 132, Section 250, Section 143(2).

UCO Bank v. CIT

237 ITR 889Supreme Court of India1999#145 most cited

What is UCO Bank v. CIT authority for?

CBDT circulars and instructions, while not binding on courts or assessees, are strictly binding on income-tax departmental authorities, who cannot act in contravention of them.

486

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2010 to 2026.

Also referred to as

UCO Bank v. CIT · 237 ITR 889 · Supreme Court · CBDT circulars binding on department · instructions to tax authorities · section 119 · income tax authorities bound by circulars · contravention of instructions · 143(2) notices · scope of scrutiny

Also reported as

104 Taxmann 547

Sections most often in play

Section 143(3)Section 153A Section 148 Section 132 Section 250 Section 143(2)Section 147 Section 115BBE

Issues it is cited on

section 119(1)installation pe section 5(8)section 119(2)(a)dependent agent pe agency pe service pe functional analysis closely held company section 150 far analysis section 119

Judgments citing UCO Bank v. CIT

DCIT, Circle-2(2), New Delhi vs. Anant Raj Ltd., New Delhi

The appeal is allowed partly as indicated above

ITA 5237/DEL/2017[2009-10]Status: DisposedITAT Delhi27 Nov 2020AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Sanjay Goel, CIT-DRFor Respondent: Shri Vinod Kumar Bindal, CA; Ms

Section 143(3)Section 147Section 148Section 50

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A” NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER I.T.As. No.4736/DEL/2017 Assessment Years: 2009-2010 M/s. Anant Raj Ltd., vs. Deputy Commissioner of E-2, ARA Centre, Income Tax, Jhandelwalan Extn., Circle-2(2), New Delhi. New Delhi. TAN/PAN: AABCA3972B (Appellant) (Respondent) ITAs No.5237 & 5238/DEL/2017 Assessment Years 2009-10 & 2012-13 Asst. Commissioner of vs. M/s. Anant Raj Ltd., Income Tax, E-2, ARA Centre, Circle-2(2), Jhandelwalan Extn., New Delhi. New Delhi. TAN/PAN: AABCA3972B (Appellant) (Responde…

Anant Raj Ltd., New Delhi vs. DCIT, Circle-2(2), New Delhi

The appeal is allowed partly as indicated above

ITA 4736/DEL/2017[2009-10]Status: DisposedITAT Delhi27 Nov 2020AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Sanjay Goel, CIT-DRFor Respondent: Shri Vinod Kumar Bindal, CA; Ms

Section 143(3)Section 147Section 148Section 50

M/S Embassy One Developers Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Central Circle-2(2), Bangalore

In the result, both the appeals of the assessee are partly allowed

ITA 2240/BANG/2018[2010-11]Status: DisposedITAT Bangalore26 Nov 2020AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. Ajay Rotti, CAFor Respondent: Shri. Kannan Narayanan, JCIT (DR)(ITAT), Bengaluru

…ws in force in either country will continue to govern the assessment and taxation of income in the respective country except where provisions to the contrary have been made in the agreement." 27. In the case of UCO Bank vs. CIT (1999) 154 CTR (SC) 88 : (1999) 237 ITR 889 (SC), their Lordships of Hon’ble Supreme Court had an occasion to survey the judicial precedents on the question of binding nature of the CBDT circulars. After elaborately dealing with Hon’ble Supreme Court’s judgments in the cases of Navnit Lal C. Jhaveri vs. K.K. Sen, AAC (1965) 56 ITR 198 (SC) and K.P. Varghese vs. ITO & Anr. (1981) 24 CTR (SC…

M/S Embassy One Developers Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Central Circle-2(2), Bangalore

In the result, both the appeals of the assessee are partly allowed

ITA 2239/BANG/2018[2009-10]Status: DisposedITAT Bangalore26 Nov 2020AY 2009-10

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. Ajay Rotti, CAFor Respondent: Shri. Kannan Narayanan, JCIT (DR)(ITAT), Bengaluru

Brite Infrastructure Pvt. Ltd., New Delhi vs. ACIT, Circle - 5(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3508/DEL/2019[2015-16]Status: DisposedITAT Delhi23 Nov 2020AY 2015-16

Bench: Sh. Bhavnesh Saini & Sh. Anil Chaturvedi(Through Video Conferencing) Ita No.3508/Del/2019 For A.Y. 2015-16 M/S. Brite Infrastructure Vs. Acit, Pvt. Ltd., Circle-5(1), 29, 3Rd Floor, New Delhi Shivaji Marg, New Delhi-110015 Pan-Aaace0664R (Appellant) (Respondent) Assessee By Sh. Raj Kumar, Ca & Sh. Sumit Goel, Ca Revenue By Sh. Bhopal Singh, Sr. Dr Date Of Hearing: 18/11/2020 Date Of Pronouncement: 23/11/2020 Order Per Anil Chaturvedi, Am: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 14.03.2019 Of The Commissioner Of Income Tax (A)-12, New Delhi Relating To Assessment Year 2015-16. Ita No.3508 /Del/12019

Section 14Section 143(3)Section 14A

…the set aside and no substantial of law arises. The said judgment relied upon the decision of Hon'ble Supreme Court in the case of Commissioner of Customs Vs Indian Oil Corporation and also the judgment of Hon'ble Supreme Court in the case of UCO Bank Vs CIT: 237 ITR 889. Hence, we hold that the Assessing Officer can widen the scope of scrutiny even the case is selected for limited scrutiny under CASS, however, the condition precedent for such widening of the scope is that the Assessing Officer has to seek prior approval of the authorities mentioned. Such prior approval and the permission of the PCIT is lacking i…

Assistant Commissioner of Income Tax Circle -1(1), Davanagere vs. M/S Davangere Urban Co-Op Bank, Davanagere

In the result appeal filed by revenue stands dismissed

ITA 2094/BANG/2018[2011-12]Status: DisposedITAT Bangalore08 Sept 2020AY 2011-12

Bench: Shri A.K.Garodia & Smt. Beena Pillaiassessment Year : 2011-12

For Appellant: Shri T Roumuan Paite, CIT (DR)For Respondent: Smt. Sheetal Borkar, Advocate

Section 36(1)(viia)Section 40

…me from nonperforming asset, taking a view that, the interest from NPA is assessable, even though it has not yielded income, since the assesse is following mercantile system of accounting. Decision of the Honble Supreme Court in the case of UCO Bank Vs. C.I.T 237 ITR 889 (1999) on the same issue is also relied upon. The decision of the Hon'ble High Court of Karnataka in the case Page 4 of 6 of CIT Vs Canfin Homes Ltd is eld as under: "Therefore, it is clear, if an assessee adopts mercantile system of accounting and in his accounts he shows a particular income as accruing, whether that amount is really accrued o…

United Shippers Ltd., Mumbai vs. DCIT - 3(3), Mumbai

In the result the appeal filed by the assessee is allowed

ITA 5815/MUM/2018[2015-16]Status: DisposedITAT Mumbai06 Jul 2020AY 2015-16

Bench: Shri Pramod Kumar & Shri Amarjit Singh

Section 143(2)Section 14A

…n following decisions for the proposition that only real income can be taxed and not notional income. - ShoorjiVallabhdas& Co. 46 ITR 144 (SC); - Godhra Electricity Co. Ltd.v. . CIT 225 ITR 746 (SC); - CIT vs. A. Raman & Co. 67 ITR 11(SC); - UCO Bank v. CIT 237 ITR 889 (SC); - Airport Authority of India v. CIT 340 ITR 407 (Del. )(FB); - CIT v. Motor Credit Co. P. Ltd. 127 ITR 572 (Mad.); - JCIT v. Pankaj Oxygen Ltd. 78 TTJ 119 (Nag.) - ACIT vs. Manick Chand Damani 72 TTJ 675 (Cal.). 13.1. After hearing both the parties, we do not find any reason to interfere in the order of ld. CIT(A), because the issue that on…

Hazelnut Constructions Pvt. Ltd., Mumbai vs. ITO, Ward-3(1)(4), Mumbai

The appeal of the assessee is allowed on jurisdictional issue

ITA 1730/MUM/2019[2015-16]Status: DisposedITAT Mumbai17 Jun 2020AY 2015-16

Bench: Sri Mahavir Singh, Vp & Sri Manjunatha G, Am आयकर अपील िं./ Ita No. 1730/Mum/2019 (ननर्ाारण वर्ा / Assessment Years 2015-16) Hazelnut Constructions Pvt. The Income Tax Officer Ltd. Ward 3(1)(4) बनाम/ 514, Dalamal Towers, 211, Fpj Mumbai Vs. Marg, Nariman Point, Mumbai (अपीलाथी / Appellant) (प्रत्यथी/ Respondent) स्थायी लेखा िं./Pan No. Aabch6233N अपीलाथी की ओर े/ Appellant By : Shri Chetan Karia, Ar प्रत्यथी की ओर े/ Respondent By : Shri Akhtar Ansari, Dr ुनवाई की तारीख / Date Of Hearing: 17.06.2020 घोर्णा की तारीख / Date Of Pronouncement: 17.06.2020 आदेश / O R D E R महावीर स िंह, उपाध्यक्ष / Per Mahavir Singh, Vp: This Appeal Of Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals)]-8, Mumbai, [In Short Cit(A)], In Ita No. Cit(A)-8/It-153/2017-18 Dated 19.02.2019. The Assessment Was Framed By The Income Tax Officer, Ward 3(1)(4), Mumbai (In Short Acit/Ito/ Ao) For The A.Y. 2015-16 Vide Order Dated 30.11.2017 Under Section 143(3) Of The Income-Tax Act, 1961 (Hereinafter ‘The Act’). 2. The First Issue Raised By Assessee In Its Appeal Is As Regards To The Assumption Of Jurisdiction By The Assessing Hazelnut Constructions Pvt. Ltd.; Ay; 2015-16 Officer For “Complete Scrutiny” Whereas The Case Was Selected For “Limited Scrutiny” Under Cass For The Assessment Year 2015-16. For This, Assessee Has Raised The Following Ground No.1: -

For Appellant: Shri Chetan Karia, ARFor Respondent: Shri Akhtar Ansari, DR

Section 142(1)Section 143Section 143(2)Section 143(3)

…ore CIT(A) and stated that once the Central Board Of Direct Taxes issued circular under section 119 of the Act which is binding on the jurisdictional assessing authorities in view of the decision of Hon’ble Supreme Court in the case of UCO Bank Vs. CIT (1999) 237 ITR 889 (SC). He also pointed out the case law of Hon’ble Calcutta High Court in the case of Amal Kumar Ghosh Vs. ACIT (2014) 361 ITR 0458, wherein Hon’ble Calcutta High Court has considered exactly the very same issue and held that the Circular issued by CBDT under section 119 of the Act is binding on the Revenue authorities. Further, he relied on the H…

Assistant Commissioner of Income Tax, Circle- 1(1), Davanagere vs. M/S. D C C Co-Operative Bank Limited, Davanagere

In the result, appeal of the Revenue for Assessment Year 2014-15 is dismissed

ITA 1405/BANG/2019[2014-15]Status: DisposedITAT Bangalore29 May 2020AY 2014-15

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)(ITAT), Bengaluru

…garding the addition made by the AO on account of interest accrued on non-performing assets (NPA) which was deleted by CIT(A). This addition was deleted by learned CIT(A) by following the judgment of Hon’ble Apex Court rendered in the case of UCO Bank Vs. CIT 237 ITR 889 (1999) and of Hon’ble Karnataka High Court rendered in the case of CIT Vs. Canfin Homes Ltd., 347 ITR 0382. It could not be shown by learned DR of the Revenue as to how these judgments are not applicable in the present case and since, the order of CIT(A) is by following these two binding judgments of Hon’ble Apex Court and of Hon’ble Karnataka Hi…

Assistant Commissioner of Income Tax, Circle - 1(1), Davanagere vs. M/S. D D C Co-Operative Bank Limited, Davanagere

In the result, appeal of the Revenue for Assessment Year 2014-15 is dismissed

ITA 1404/BANG/2019[2013-14]Status: DisposedITAT Bangalore29 May 2020AY 2013-14

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)(ITAT), Bengaluru

DCIT, Cir-5(1), Kolkata vs. M/S. Proficient Commodities Pvt. Ltd., Kolkata

In the result, the cross objection filed by the assessee in CO No

ITA 1346/KOL/2016[2012-13]Status: DisposedITAT Kolkata18 Mar 2020AY 2012-13

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1346/Kol/2016 ("नधा"रणवष" / Assessment Year:2012-13)

For Appellant: Shri Ram Bilash Meena, CIT DRFor Respondent: Shri Somnath Ghosh, Advocate

Section 143(2)Section 143(3)

…es Pvt. Ltd. ITA No.1346/Kol/2016&C. O. No. 36/Kol/2019 Assessment Year:2012-13 6. We find that the Hon'ble Chhatishgarh High Court in Sunita Finlease Ltd.'s case (supra) has also considered the decision of Hon'ble Supreme Court in the case of UCO Bank (1999) 237 ITR 889 and quoted from page 896 as under: "Such instructions may be by way of relaxation of any of the provisions of the sections specified there or otherwise. The Board thus has power, inter alia, to tone down the rigour of the law and ensure a fair enforcement of its provisions, by issuing circulars in exercise of its statutory powers under section 11…

Kaybee P.Ltd, Mumbai vs. ITO 10(1)(3) (Erstwhile Juridictional ITO 8(2)(2), Mumbai

In the result, the appeal is allowed in the terms indicated above

ITA 4950/MUM/2018[2006-07]Status: DisposedITAT Mumbai28 Feb 2020AY 2006-07

Section 143(3)Section 271Section 271ASection 271BSection 92ASection 92A(1)(b)Section 92A(2)Section 92DSection 92E

…structions and directions of the Board”. Once a circular is issued, even if it is in deviation with the provisions of the law or relaxes the rigour of law, it binds the field authorities. As held by Hon‟ble Supreme Court in the case of UCO Bank Vs CIT [(1999) 237 ITR 889], “The relevant circulars of the Board cannot be ignored. The question is not whether a circular can override or detract ITA No. 4949 and 4950/Mum/15 Assessment year: 2006-07 Page 9 of 17 from the provisions of the Act; the question is whether the circular seeks to mitigate the rigour of a particular section for the benefit of the assessee in c…

Kaybee P.Ltd, Mumbai vs. ITO 10(1)(3) (Erstwhile Juridictional ITO 8(2)(2), Mumbai

In the result, the appeal is allowed in the terms indicated above

ITA 4949/MUM/2018[2006-07]Status: DisposedITAT Mumbai28 Feb 2020AY 2006-07

Section 143(3)Section 271Section 271ASection 271BSection 92ASection 92A(1)(b)Section 92A(2)Section 92DSection 92E

Kaybee P.Ltd, Mumbai vs. ITO 10(1)(3) (Erstwhile Juridictional ITO 8(2)(2), Mumbai

In the result, the appeal is allowed in the terms indicated above

ITA 2165/MUM/2015[2007-08]Status: DisposedITAT Mumbai28 Feb 2020AY 2007-08

Section 143(3)Section 92ASection 92A(1)Section 92A(1)(b)Section 92A(2)

…ITA No. 2165/Mum/15 Assessment year: 2007-08 Page 1 of 15 IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI K BENCH, MUMBAI [Coram: Pramod Kumar (Vice President) and Saktijit Dey (Judicial Member)] ITA No 2165/Mum/15 Assessment year: 2007-08 Kaybee Pvt Ltd ……………….............Appellant 301, A Wing, Solaris I, Saki Vihar Road Andheri (East), Mumbai 400 072 [PAN: AAACK1715H] Vs Income Tax Officer Ward 10(1)(3), Mumbai ………….……......Respondent Appearances by P J Pardiwalla along-with Madhur Agarwal for the appellant Ujjawal Kumar for the respondent Dates of hearing of the appeal : February 18 and 21, 2020 Date of prono…

Kaybee P.Ltd, Mumbai vs. ITO 10(1)(3) (Erstwhile Juridictional ITO 8(2)(2), Mumbai

In the result, the appeal is allowed in the terms indicated above

ITA 2164/MUM/2015[2006-07]Status: DisposedITAT Mumbai28 Feb 2020AY 2006-07

Section 143(3)Section 92ASection 92A(1)Section 92A(1)(b)Section 92A(2)

…structions and directions of the Board”. Once a circular is issued, even if it is in deviation with the provisions of the law or relaxes the rigour of law, it binds the field authorities. As held by Hon’ble Supreme Court in the case of UCO Bank Vs CIT [(1999) 237 ITR 889], “The relevant circulars of the Board cannot be ignored. The question is not whether a circular can override or detract from the provisions of the Act; the question is whether the circular seeks to mitigate the rigour of a particular section for the benefit of the assessee in certain specified circumstances. So long as such a circular is in forc…

DCIT, Meerut vs. M/S Sarva Up Gramin Bank, Meerut

In the result, the appeal of the revenue is dismissed

ITA 2096/DEL/2017[2013-14]Status: DisposedITAT Delhi24 Feb 2020AY 2013-14

Bench: Sh. Kuldip Singhdr. B. R. R. Kumarita No. 2096/Del/2017 : Asstt. Year : 2013-14 Deputy Commissioner Of Income Vs M/S Sarva Up Gramin Bank, Tax, Circle-2, C-39/5, Jagriti Vihar, Meerut Meerut (Appellant) (Respondent) Pan No. Aacas9891G Assessee By : Sh. Vivek Gupta, Ca Revenue By : Sh. Saras Kumar, Sr. Dr Date Of Hearing: 16.01.2020 Date Of Pronouncement: 24.02.2020

For Appellant: Sh. Vivek Gupta, CAFor Respondent: Sh. Saras Kumar, Sr. DR

Section 143(3)Section 148Section 36(1)(viia)

…5. The case of the assessee for the assessment year 2012-13 has been adjudicated by the ITAT in ITA No. 1937/Del/2016 in assessee’s own case wherein the deduction was allowed taking into consideration, the CBDT Circular No. 421 dated 12.06.1985, UCO Bank Ltd. 237 ITR 889 (SC), Catholic Syrian Bank 88 ITD 185, South Indian Bank 233 CTR 214. Since, the factual matter remains unchanged, in the absence of any other judgment contrary to the facts available on record, the addition made by the revenue is hereby ordered to be deleted. 6. For the sake of brevity, the operative portion of the order of the ITAT in the case…

Urban Improvement Co. (P) Ltd., New Delhi vs. ITO Ward - 27(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 7496/DEL/2019[2015-16]Status: DisposedITAT Delhi07 Feb 2020AY 2015-16

Bench: Sh. Kuldip Singhdr. B. R. R. Kumarita No. 7496/Del/2019 : Asstt. Year : 2015-16 Urban Improvement Co. (P) Ltd., Vs Income Tax Officer, C/O Raj Kumar & Associates, Ca, Ward-27(2), L-7A(Lgf), South Extn., Part-Ii, New Delhi New Delhi-110049 (Appellant) (Respondent) Pan No. Aaacu1004F Assessee By : Sh. Raj Kumar Gupta, Ca Revenue By : Sh. Saras Kumar, Sr. Dr Date Of Hearing: 20.01.2020 Date Of Pronouncement: 07.02.2020

For Appellant: Sh. Raj Kumar Gupta, CAFor Respondent: Sh. Saras Kumar, Sr. DR

Section 115JSection 142(1)Section 143(2)Section 43C

…the set aside and no substantial of law arises. The said judgment relied upon the decision of Hon’ble Supreme Court in the case of Commissioner of Customs Vs Indian Oil Corporation and also the judgment of Hon’ble Supreme Court in the case of UCO Bank Vs CIT: 237 ITR 889. Hence, we hold that the Assessing Officer can widen the scope of scrutiny even the case is selected for limited scrutiny under CASS, however, the condition precedent for such widening of the scope is that the Assessing Officer has to seek prior 9 Urban Improvement Co. Pvt. Ltd. approval of the authorities mentioned. Such prior approval and the…

The Shimoga District Co-Operative, Shimoga vs. ACIT-Circle-1, Sindagi

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

ITA 1499/BANG/2016[2011-12]Status: DisposedITAT Bangalore17 Jan 2020AY 2011-12

Bench: Shri B.R Baskaran & Shri Pavan Kumar Gadaleassessment Year : 2011-12

For Appellant: Shri S.V Ravishankar, AdvocateFor Respondent: Smt. R Premi, JCIT (DR)

Section 145Section 271(1)(c)Section 80P

…Ltd., Vs. DCIT (ITA No.429/Bang/2011) dated 12/10/2012 and restored the matter to the file of the AO with certain directions. He submitted that the coordinate bench has considered the decision rendered by Hon’ble Supreme Court in the case of UCO Bank Vs. CIT (237 ITR 889) in this regard, wherein it was held that the interest due on loans which were doubtful of recovery need not be recognized as income. Accordingly, the ld AR submitted that the impugned penalty should be deleted. 6. On the contrary the ld DR submitted that the assessee has consciously not declared interest accrued on loans but not received by it…

ACIT, Meerut vs. M/S. Sarva Up Gramin Bank, Meerut

In the result, the appeal of the Revenue is dismissed

ITA 1937/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Dec 2019AY 2012-13

Bench: Sh. Bhavnesh Saini & Dr. B. R. R. Kumar

For Appellant: Sh. Vivek Gupta, CAFor Respondent: Ms. Ashima Neb, Sr. DR

Section 36(1)(viia)

…igate the rigour of a particular 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 (UCO Bank vs. CIT 237 ITR 889 (SC) followed) 9. We have also gone through the guidelines given by the Supreme Court in the case of DCIT vs. Catholic Syrian Bank 88 ITD 185. In that case, the Hon’ble Court had to consider whether a bank was eligible to claim a deduction for bad debts u/s 36(1)(vii) in respect of its (rural & 40 M/s Sarva UP Gramin Bank urban) advances and a…

The DCIT(Exemption), Bhopal vs. M/S. Indore Education and Service Society, Indore

In the result, the appeal filed by the revenue is

ITA 468/IND/2018[13-14]Status: DisposedITAT Indore19 Nov 2019

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2013-14 Dcit M/S. Indore Education & (Exemption) Service Society बनाम/ Bhopal 2Nd Floor, Income Tax Office Vs. Metro Walk Building E-5, Arera Colony Near Bittan Market Bhopal (Appellant) (Revenue ) P.A. No.Aaati3186K

Section 10Section 11Section 13(1)(c)Section 143(3)

…r as under: (i) Sushil Kumar Das V Income Tax Officer (2011) 11 ITR(Trib) 17 146 Taxman 335 (Guj) (ii) Raj rani Gulati CIT Central Tilak (2012) 346 ITR 543(All) (iii) S.R.Koshti V CIT 146 Taxman 335(Guj) (iv) K.P.Varghese V ITO 131 ITR 597 (v) UCO Bank V CIT 237 ITR 889 (v) CIT Bharat Aluminum Ltd 303 ITR 256 (Del) (vi) CIT V Dhampur Sugar Ltd 90 ITR 236 (All) (vii) Xerox India Ltd V DCIT New Delhi (ITA 158/2010) Further after relying on the validity of Circular No 14 dated 11.04.1955 as examined by Honourable Apex Court in the case of CIT V Makendm Mills reported in 234 ITR 56 in which the Honourable Court has…