Union of India v. A. Sanyasi Rao

219 ITR 330Supreme Court of India1996#2628 most cited

What is Union of India v. A. Sanyasi Rao authority for?

Presumptive taxation provisions, such as those under Section 44AC, are intended to simplify income calculation, not to levy tax when there is no actual income. Such provisions may not be applicable in cases where an assessee incurs losses or where they lead to an unconscionable taxation on gross income.

44

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2011 to 2022.

Also referred to as

Union of India v. A. Sanyasi Rao · 219 ITR 330 · presumptive taxation · Section 44AC · Section 44BBA · applicability when no income · gross income taxation · purpose of presumptive provisions · income computation presumptive · losses and presumptive tax

Issues it is cited on

section 44bbsection 44bsection 148 noticeassistant directorsection 44apermanent establishmentprofits and gains of business or professionsection 149liable to taxsection 44section 234bnon-resident

Judgments citing Union of India v. A. Sanyasi Rao

Shri Patel Enterprises, Korba(Cg) vs. Dy. Commissioner of Income Tax, Circle- Korba

In the result, the appeal of the assessee is partly allowed for statistical purpose in terms of our observations as discussed herein above

ITA 112/BIL/2017[2012-13]Status: DisposedITAT Raipur21 Sept 2022AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.112/Rpr/2017 (ननधाारण वषा / Assessment Year : 2012-2013) M/S Patel Enterprises, Vs Dcit, Circle-Korba A-3, Vikas Complex, First Floor, Power House Road, Korba (C.G.) Pan No. : Aajfm 0718 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Prakash Chand Agrawal, CAFor Respondent: Shri P.K.Mishra, CIT-DR
Section 143(1)Section 251

…आयकर अऩीऱीय अधधकरण, रायऩुर न्यायऩीठ, रायऩुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR श्री रविश सूद, न्याययक सदस्य एवं श्री अरुण खोड़वऩया, ऱेखा सदस्य के समक्ष । BEFORE SHRI RAVISH SOOD, JM & SHRI ARUN KHODPIA, AM आयकर अऩीऱ सं./ITA No.112/RPR/2017 (ननधाारण वषा / Assessment Year : 2012-2013) M/s Patel Enterprises, Vs DCIT, Circle-Korba A-3, Vikas Complex, First Floor, Power House Road, Korba (C.G.) PAN No. : AAJFM 0718 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee by : Shri Prakash Chand Agrawal, CA राजस्व की ओर से /Revenue by : Shri P.K.Mishra, CIT-DR सुनिाई की तार…

Dy CIT-It-1(1)(2), Mumbai vs. M/S Arc Line, Mumbai

In the result, this appeal by the revenue stands dismissed

ITA 7347/MUM/2019[2013-14]Status: DisposedITAT Mumbai06 Oct 2021AY 2013-14

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm) I.T.A. No. 7347/Mum/2019 (Assessment Year 2013-14)

Section 9Section 90

…d. Ground No.5 : is with regard to determination of profit u/s.44B of the Act. f find that this issue relates to applicability of section 44B of the Act. While the appellant contends that the decision of Hon'ble Supreme Court in Union of India v. Sanyasi Rao (219 ITR 330) has been disregarded by the AO, my predecessor-CIT(A) 10 has held (at para no.4.2 on page nos. 4 & 5 of his order for A.Y.2008-09) that the income of the PE has to be adopted in accordance with the taxation laws of the contracting state in which the PE is situated. It follows that the income from shipping business has to be computed in accordan…

DCIT(It), Circle - 2(1), Kolkata vs. M/S. the Timken Company, Kolkata

In the result, all these appeals of the In the result, all these appeals of the revenue are dismissed

ITA 1277/KOL/2018[2011-12]Status: DisposedITAT Kolkata19 Feb 2020AY 2011-12

Bench: Sri J. Sudhakar Reddy & Sri S.S. Godara) Assessment Year: 2008-09 Assessment Year: 2009-10 Assessment Year: 2010-11 Assessment Year: 2011-12

Section 250

…axation on gross basis is contained in Sec.44AC basis is contained in Sec.44AC of the Act and the Hon'ble Supreme Court in of the Act and the Hon'ble Supreme Court in the case of Union of India vs. A. Sanyasi Rao & Ors Union of India vs. A. Sanyasi Rao & Ors. 219 ITR 330 (SC) held that . 219 ITR 330 (SC) held that in case of presumptive basis of taxation an option for computation of profits in case of presumptive basis of taxation an option for computation of profits in case of presumptive basis of taxation an option for computation of profits under ss. 28 to 43C 43C of the Act should be read in s. 44D. Similar o…

DCIT(It), Circle - 2(1), Kolkata vs. M/S. the Timken Company, Kolkata

In the result, all these appeals of the In the result, all these appeals of the revenue are dismissed

ITA 1276/KOL/2018[2010-11]Status: DisposedITAT Kolkata19 Feb 2020AY 2010-11

Bench: Sri J. Sudhakar Reddy & Sri S.S. Godara) Assessment Year: 2008-09 Assessment Year: 2009-10 Assessment Year: 2010-11 Assessment Year: 2011-12

Section 250

…axation on gross basis is contained in Sec.44AC basis is contained in Sec.44AC of the Act and the Hon'ble Supreme Court in of the Act and the Hon'ble Supreme Court in the case of Union of India vs. A. Sanyasi Rao & Ors Union of India vs. A. Sanyasi Rao & Ors. 219 ITR 330 (SC) held that . 219 ITR 330 (SC) held that in case of presumptive basis of taxation an option for computation of profits in case of presumptive basis of taxation an option for computation of profits in case of presumptive basis of taxation an option for computation of profits under ss. 28 to 43C 43C of the Act should be read in s. 44D. Similar o…

DCIT(It), Circle - 2(1), Kolkata vs. M/S. the Timken Company, Kolkata

In the result, all these appeals of the In the result, all these appeals of the revenue are dismissed

ITA 1275/KOL/2018[2009-10]Status: DisposedITAT Kolkata19 Feb 2020AY 2009-10

Bench: Sri J. Sudhakar Reddy & Sri S.S. Godara) Assessment Year: 2008-09 Assessment Year: 2009-10 Assessment Year: 2010-11 Assessment Year: 2011-12

Section 250

…axation on gross basis is contained in Sec.44AC basis is contained in Sec.44AC of the Act and the Hon'ble Supreme Court in of the Act and the Hon'ble Supreme Court in the case of Union of India vs. A. Sanyasi Rao & Ors Union of India vs. A. Sanyasi Rao & Ors. 219 ITR 330 (SC) held that . 219 ITR 330 (SC) held that in case of presumptive basis of taxation an option for computation of profits in case of presumptive basis of taxation an option for computation of profits in case of presumptive basis of taxation an option for computation of profits under ss. 28 to 43C 43C of the Act should be read in s. 44D. Similar o…

DCIT(It), Circle - 2(1), Kolkata vs. M/S. the Timken Company, Kolkata

In the result, all these appeals of the In the result, all these appeals of the revenue are dismissed

ITA 1274/KOL/2018[2008-09]Status: DisposedITAT Kolkata19 Feb 2020AY 2008-09

Bench: Sri J. Sudhakar Reddy & Sri S.S. Godara) Assessment Year: 2008-09 Assessment Year: 2009-10 Assessment Year: 2010-11 Assessment Year: 2011-12

Section 250

…axation on gross basis is contained in Sec.44AC basis is contained in Sec.44AC of the Act and the Hon'ble Supreme Court in of the Act and the Hon'ble Supreme Court in the case of Union of India vs. A. Sanyasi Rao & Ors Union of India vs. A. Sanyasi Rao & Ors. 219 ITR 330 (SC) held that . 219 ITR 330 (SC) held that in case of presumptive basis of taxation an option for computation of profits in case of presumptive basis of taxation an option for computation of profits in case of presumptive basis of taxation an option for computation of profits under ss. 28 to 43C 43C of the Act should be read in s. 44D. Similar o…

Hiranandani Industrial Enterprises, Mumbai vs. Assistant Commissioner of Income Tax Circle-17(1), Mumbai

In the result, the appeal is allowed

ITA 2305/MUM/2018[2010-11]Status: DisposedITAT Mumbai27 Dec 2019AY 2010-11

Bench: Shri Ravish Sood () & Shri N.K. Pradhan () Assessment Year: 2010-11 Hiranandani Industrial Enterprises, The Assistant Commissioner Of 514, Dalamal Towers, 211, F P J Vs. Income Tax, Circle-17(1), Marg, Nariman Point, Mumbai- Room No. 117, Aayakar Bhavan, 400021 Mumbai-400020. Pan No. Aaafh1372E Appellant Respondent

For Appellant: Shri Chetan A. Karia, ARFor Respondent: Shri V. Vinod Kumar, DR
Section 143(3)Section 48Section 50Section 50CSection 50C(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “H” MUMBAI BEFORE SHRI RAVISH SOOD (JUDICIAL MEMBER) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2010-11 Hiranandani Industrial Enterprises, The Assistant Commissioner of 514, Dalamal Towers, 211, F P J Vs. Income Tax, Circle-17(1), Marg, Nariman Point, Mumbai- Room no. 117, Aayakar Bhavan, 400021 Mumbai-400020. PAN No. AAAFH1372E Appellant Respondent Assessee by : Shri Chetan A. Karia, AR Revenue by : Shri V. Vinod Kumar, DR Date of Hearing : 05/11/2019 Date of pronouncement : 27/12/2019 ORDER PER N.K. PRADHAN, A.M. This is an appeal filed by…

Arc Line (Mauritius), Mumbai vs. DCIT (Intl. Tax) Range 1(1)(2), Mumbai

In the result, the appeal is partly allowed

ITA 2332/MUM/2018[2014-15]Status: DisposedITAT Mumbai09 Sept 2019AY 2014-15

Bench: Shri Mahavir Singh () & Shri N.K. Pradhan () Assessment Year: 2014-15 Arc Line (Mauritius) Deputy Commissioner Of C/O 3C Runwal&Omkar Income Tax (International Vs. Esquare Sion Chunabhatti, Taxation)-1(1)(2), Junction, Sion – Trombay Mumbai. Road, Sion (E), Mumbai- 400022. Pan No. Aadca0878J Appellant Respondent

For Appellant: Mr. Dharsh KothariFor Respondent: Mr. NishantSamaiya, DR
Section 143(3)Section 44B

…rofits of the Appellant Company under section 44B of the Act, thereby disregarding the profits actually earned by the Appellant Company from its Indian operations, ignoring the decision of the Hon'ble Supreme Court in the case of Union of India v. Sanyasi Rao 219 ITR 330(SC). 3. Briefly stated, the facts are that the appellant-company is a non- resident company incorporated in Mauritius. It is engaged in the business of shipping. It declared income from shipping activities, but claimed it as exempt under provisions of Double Taxation Avoidance Agreement (‘DTAA’) by taking support of Article-8 of DTAA entered AR…

Assistant Commissioner of Income Tax-1(1), Raipur vs. Shri. Javed Ali Pradhan, Raipur

In the result, all appeals filed by the Revenue are dismissed

ITA 132/BIL/2011[2007-08]Status: DisposedITAT Raipur10 Jan 2018AY 2007-08

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…ld be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held in 219 ITR 330 (SC). 1.40 The impugned addition was made purely on presumptive basis and this is against the ratio pronounced by the MP HC in (1996) 218 ITR 48 (MP) wherein it was held that : “Why should every exercise begin with mistrust or no trust ? Law lives on logic and hence any illogicality basing on probabilities/ technicalities or notions is to be spur…

Assistant Commissioner of Income Tax-1(1), Raipur vs. Shri. Javed Ali Pradhan, Raipur

In the result, all appeals filed by the Revenue are dismissed

ITA 131/BIL/2011[2006-07]Status: DisposedITAT Raipur10 Jan 2018AY 2006-07

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…ld be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held in 219 ITR 330 (SC). 1.40 The impugned addition was made purely on presumptive basis and this is against the ratio pronounced by the MP HC in (1996) 218 ITR 48 (MP) wherein it was held that : “Why should every exercise begin with mistrust or no trust ? Law lives on logic and hence any illogicality basing on probabilities/ technicalities or notions is to be spur…

Assistant Commissioner of Income Tax-1(1), Raipur vs. Shri. Javed Ali Pradhan, Raipur

In the result, all appeals filed by the Revenue are dismissed

ITA 130/BIL/2011[2005-06]Status: DisposedITAT Raipur10 Jan 2018AY 2005-06

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…ld be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held in 219 ITR 330 (SC). 1.40 The impugned addition was made purely on presumptive basis and this is against the ratio pronounced by the MP HC in (1996) 218 ITR 48 (MP) wherein it was held that : “Why should every exercise begin with mistrust or no trust ? Law lives on logic and hence any illogicality basing on probabilities/ technicalities or notions is to be spur…

Assistant Commissioner of Income Tax-1(1), Raipur vs. Shri. Javed Ali Pradhan, Raipur

In the result, all appeals filed by the Revenue are dismissed

ITA 128/BIL/2011[2003-04]Status: DisposedITAT Raipur10 Jan 2018AY 2003-04

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…ld be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held in 219 ITR 330 (SC). 1.40 The impugned addition was made purely on presumptive basis and this is against the ratio pronounced by the MP HC in (1996) 218 ITR 48 (MP) wherein it was held that : “Why should every exercise begin with mistrust or no trust ? Law lives on logic and hence any illogicality basing on probabilities/ technicalities or notions is to be spur…

Assistant Commissioner of Income Tax-1(1), Raipur vs. Shri. Javed Ali Pradhan, Raipur

In the result, all appeals filed by the Revenue are dismissed

ITA 127/BIL/2011[2002-03]Status: DisposedITAT Raipur10 Jan 2018AY 2002-03

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…ld be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held in 219 ITR 330 (SC). 1.40 The impugned addition was made purely on presumptive basis and this is against the ratio pronounced by the MP HC in (1996) 218 ITR 48 (MP) wherein it was held that : “Why should every exercise begin with mistrust or no trust ? Law lives on logic and hence any illogicality basing on probabilities/ technicalities or notions is to be spur…

Assistant Commissioner of Income Tax-1(1), Raipur vs. Shri. Javed Ali Pradhan, Raipur

In the result, all appeals filed by the Revenue are dismissed

ITA 126/BIL/2011[2001-02]Status: DisposedITAT Raipur10 Jan 2018AY 2001-02

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

For Appellant: NoneFor Respondent: Shri R.K.Singh, CITDR

…ld be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held in 219 ITR 330 (SC). 1.40 The impugned addition was made purely on presumptive basis and this is against the ratio pronounced by the MP HC in (1996) 218 ITR 48 (MP) wherein it was held that : “Why should every exercise begin with mistrust or no trust ? Law lives on logic and hence any illogicality basing on probabilities/ technicalities or notions is to be spur…

The Timken Company, Kolkata vs. The DDIT, International Taxation - 3(1), Kolkata

In the result appeals for AY 2004-05 to 2007-08 are allowed

ITA 1268/KOL/2014[2005-06]Status: DisposedITAT Kolkata29 Nov 2017AY 2005-06

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]

For Appellant: Shri Ravi Sharma, ARFor Respondent: Shri N.B.Som, Addl. CIT, Sr.DR

…mpany 6 non-resident corporate assessee, at the rate of 20 per cent of such fees. A similar presumptive basis of taxation on gross basis is contained in Sec.44AC of the Act and the Hon’ble Supreme Court in the case of Union of India vs. A. Sanyasi Rao & Ors. 219 ITR 330 (SC) held that in case of presumptive basis of taxation an option for computation of profits under ss. 28 to 43C of the Act should be read in s. 44AC. It was the plea of the Assessee that similar option should be read into the provisions of Sec.44D of the Act r/w Sec.115A of the Act. If it is so read, then on admitted facts that there was no elem…

The Timken Company, Kolkata vs. A.D.I.T (International Taxation) - II, Kolkata

In the result appeals for AY 2004-05 to 2007-08 are allowed

ITA 2139/KOL/2013[2004-05]Status: DisposedITAT Kolkata29 Nov 2017AY 2004-05

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]

For Appellant: Shri Ravi Sharma, ARFor Respondent: Shri N.B.Som, Addl. CIT, Sr.DR

…mpany 6 non-resident corporate assessee, at the rate of 20 per cent of such fees. A similar presumptive basis of taxation on gross basis is contained in Sec.44AC of the Act and the Hon’ble Supreme Court in the case of Union of India vs. A. Sanyasi Rao & Ors. 219 ITR 330 (SC) held that in case of presumptive basis of taxation an option for computation of profits under ss. 28 to 43C of the Act should be read in s. 44AC. It was the plea of the Assessee that similar option should be read into the provisions of Sec.44D of the Act r/w Sec.115A of the Act. If it is so read, then on admitted facts that there was no elem…

ADIT(It)-3(1), Kolkata vs. The Timken Company, Kolkata

In the result appeals for AY 2004-05 to 2007-08 are allowed

ITA 387/KOL/2010[2002-03]Status: DisposedITAT Kolkata29 Nov 2017AY 2002-03

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]

For Appellant: Shri Ravi Sharma, ARFor Respondent: Shri N.B.Som, Addl. CIT, Sr.DR

…mpany 6 non-resident corporate assessee, at the rate of 20 per cent of such fees. A similar presumptive basis of taxation on gross basis is contained in Sec.44AC of the Act and the Hon’ble Supreme Court in the case of Union of India vs. A. Sanyasi Rao & Ors. 219 ITR 330 (SC) held that in case of presumptive basis of taxation an option for computation of profits under ss. 28 to 43C of the Act should be read in s. 44AC. It was the plea of the Assessee that similar option should be read into the provisions of Sec.44D of the Act r/w Sec.115A of the Act. If it is so read, then on admitted facts that there was no elem…

Pratap Ratan Das, Mumbai vs. ITO 14(1)(4), Mumbai

In the result, the assessee’s appeal is dismissed

ITA 1272/MUM/2012[2008-09]Status: DisposedITAT Mumbai21 Sept 2016AY 2008-09

Bench: Shri Jason P. Boaz, Am & Shri Sandeep Gosain, Jm आयकर अपील सं./ I.T.A. No. 1272/Mum/2012 ("नधा"रण वष" / Assessment Year: 2008-09)

For Appellant: Shri Mohammed Rizwan
Section 143(1)Section 271(1)(c)Section 50CSection 68

…by section 50C Section 50C is only a measure of tax and not the subject matter of tax. The valuation rule of the Stamp Act is for the purpose of computation' of income. It is only a standard' of measure for imposing tax. (Principle laid down in A. Sanyasi Rao 219 ITR 330 (SC) followed; (ii) Section 50C was introduced with a view to prevent evasion of tax and under- valuation of the transaction and must be read in that context. The classification made by section sac is in respect of an identifiable group of assesses and is not arbitrary, unreasonable or discriminatory. (K.R. Palanisamy vs. UOI 306 ITR 61 (Mad) fol…

ADIT, Dehradun vs. M/S. Hallin Marine Uk Ltd., Dehradun

In the result, both the appeal and the cross objection filed by the assessee are dismissed and the appeal filed by the Revenue is allowed partly for statistical purposes

ITA 5290/DEL/2012[2009-10]Status: DisposedITAT Delhi20 Jan 2016AY 2009-10

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 M/S. Hallin Marine Uk Ltd., Vs. Adit, Intl. Taxation, Dehradun C/O Nangia & Company, Suite 4A, Plaza M-6, Jasola, New Delhi (Pan: Aabch9433L) (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 44BSection 9(1)(vii)Section 92

…ITR 823 (Bom); (15) Godhra Electricity Co. Ltd. vs. CIT (1997) 139 CTR (SC) 564 : (1997) 225 ITR 746 (SC); (16) CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC); (17) Union of India & Anr. vs. A. Sanyasi Rao & Ors. (1996) 132 CTR (SC) 81 : (1996) 219 ITR 330 (SC); (18) CIT vs. Amarchand N. Shroff (1963) 48 ITR 59 (SC); (19) CIT vs. Ajax Products Ltd. (1965) 55 ITR 741 (SC); (20) Sedco Forex International Drilling Inc. vs. Jt. CIT (Tribunal ‘D’ Bench, Delhi) (ITA No. 2024/Del/2001) (Asst. yr. 1998-99); (21) Circular No. 495 dt. 22nd Sept., 1987 [(1988) 67 CTR (St) 1] in respect of s. 44BB; (22) Financ…

Hallin Marine Uk Ltd., New Delhi vs. ADIT, Dehradun

In the result, both the appeal and the cross objection filed by the assessee are dismissed and the appeal filed by the Revenue is allowed partly for statistical purposes

ITA 5217/DEL/2012[2009-10]Status: DisposedITAT Delhi20 Jan 2016AY 2009-10

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 M/S. Hallin Marine Uk Ltd., Vs. Adit, Intl. Taxation, Dehradun C/O Nangia & Company, Suite 4A, Plaza M-6, Jasola, New Delhi (Pan: Aabch9433L) (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 44BSection 9(1)(vii)Section 92

…ITR 823 (Bom); (15) Godhra Electricity Co. Ltd. vs. CIT (1997) 139 CTR (SC) 564 : (1997) 225 ITR 746 (SC); (16) CIT vs. Tejaji Farasram Kharawalla Ltd. (1968) 67 ITR 95 (SC); (17) Union of India & Anr. vs. A. Sanyasi Rao & Ors. (1996) 132 CTR (SC) 81 : (1996) 219 ITR 330 (SC); (18) CIT vs. Amarchand N. Shroff (1963) 48 ITR 59 (SC); (19) CIT vs. Ajax Products Ltd. (1965) 55 ITR 741 (SC); (20) Sedco Forex International Drilling Inc. vs. Jt. CIT (Tribunal ‘D’ Bench, Delhi) (ITA No. 2024/Del/2001) (Asst. yr. 1998-99); (21) Circular No. 495 dt. 22nd Sept., 1987 [(1988) 67 CTR (St) 1] in respect of s. 44BB; (22) Financ…

Union of India v. A. Sanyasi Rao (219 ITR 330) — Cited in 44 Judgments | BharatTax