V.S. Sivalingam Chettiar v. CIT

62 ITR 678High Court1966#18210 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2020 to 2024.

Sections most often in play

Section 143(3)Section 147Section 148Section 201Section 237Section 9(1)(vii)

Issues it is cited on

section 237vsv schemesection 9(1)(vii)section 34fees for technical servicessection 35section 9(1)advance taxsection 201escapement of incomesection 20income-tax officer

Judgments citing V.S. Sivalingam Chettiar v. CIT

DCIT, INTL. TAXN., CIRCLE 1(2), BANGALORE vs. IBM CANADA LIMITED, BANGALORE

In the result, the appeal filed by the revenue is hereby dismissed

ITA 1330/BANG/2024[2014-15]Status: DisposedITAT Bangalore23 Aug 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Yogesh Kumar Us

For Appellant: Shri Sharath Rao, CA, Dhiraj R, AdvocateFor Respondent: Shri Subramanian S, JCIT
Section 143(3)Section 147Section 148Section 201Section 9(1)(vii)

…oceedings could be vacated only by recourse to section 34, as this was not a case for the application of section 35." (p. 659) 10. The aforesaid view has been subsequently followed by the Madras High Court in the case of V.S. Sivalingam Chettiar v. CIT [1966] 62 ITR 678 and by the Rajasthan High Court in the case of Manak Lal Purwal v, CIT (19851 155 ITR 6481. In this case. Rajasthan High Court has held that the order for filing the proceedings is held to be order of assessment. 11. In view of the above decision, we are of the view that in the present case, order for dropping the proceedings amounts to order of a…

DCIT, INTL. TAXN., CIRCLE 1(2), BANGALORE vs. IBM SINGAPORE PTE. LIMITED , BANGALORE

In the result, the appeal filed by the revenue is hereby dismissed

ITA 1329/BANG/2024[2017-18]Status: DisposedITAT Bangalore23 Aug 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Yogesh Kumar Us

For Appellant: Shri Sharath Rao, CA, Dhiraj R, AdvocateFor Respondent: Shri Subramanian S, JCIT
Section 143(3)Section 147Section 148Section 201Section 9(1)(vii)

…oceedings could be vacated only by recourse to section 34, as this was not a case for the application of section 35." (p. 659) 10. The aforesaid view has been subsequently followed by the Madras High Court in the case of V.S. Sivalingam Chettiar v. CIT [1966] 62 ITR 678 and by the Rajasthan High Court in the case of Manak Lal Purwal v, CIT (19851 155 ITR 6481. In this case. Rajasthan High Court has held that the order for filing the proceedings is held to be order of assessment. 11. In view of the above decision, we are of the view that in the present case, order for dropping the proceedings amounts to order of a…

DCIT, INTL TAXN, CIRCLE-1(2), BANGALORE vs. IBM ITALIA SPA, INDIA

In the result, the appeal filed by the revenue is hereby dismissed

ITA 1325/BANG/2024[2014-15]Status: DisposedITAT Bangalore23 Aug 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Yogesh Kumar Us

For Appellant: Shri Sharath Rao, CA, Dhiraj R, AdvocateFor Respondent: Shri Subramanian S, JCIT
Section 143(3)Section 147Section 148Section 201Section 9(1)(vii)

…oceedings could be vacated only by recourse to section 34, as this was not a case for the application of section 35." (p. 659) 10. The aforesaid view has been subsequently followed by the Madras High Court in the case of V.S. Sivalingam Chettiar v. CIT [1966] 62 ITR 678 and by the Rajasthan High Court in the case of Manak Lal Purwal v, CIT (19851 155 ITR 6481. In this case. Rajasthan High Court has held that the order for filing the proceedings is held to be order of assessment. 11. In view of the above decision, we are of the view that in the present case, order for dropping the proceedings amounts to order of a…

DCIT, INTL. TAXN., CIRCLE 1(2), BANGALORE vs. IBM DEUTSCHLAND GMBH, INDIA

In the result, the appeal filed by the revenue is hereby dismissed

ITA 1312/BANG/2024[2014-15]Status: DisposedITAT Bangalore23 Aug 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Yogesh Kumar Us

For Appellant: Shri Sharath Rao, CA, Dhiraj R, AdvocateFor Respondent: Shri Subramanian S, JCIT
Section 143(3)Section 147Section 148Section 201Section 9(1)(vii)

…oceedings could be vacated only by recourse to section 34, as this was not a case for the application of section 35." (p. 659) 10. The aforesaid view has been subsequently followed by the Madras High Court in the case of V.S. Sivalingam Chettiar v. CIT [1966] 62 ITR 678 and by the Rajasthan High Court in the case of Manak Lal Purwal v, CIT (19851 155 ITR 6481. In this case. Rajasthan High Court has held that the order for filing the proceedings is held to be order of assessment. 11. In view of the above decision, we are of the view that in the present case, order for dropping the proceedings amounts to order of a…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - AGARTALA , AGARTALA vs. SHRI SUBHAJIT PAUL, AGARTALA

In the result, cross-objection nos

ITA 116/GTY/2018[2014-15]Status: DisposedITAT Guwahati31 Jul 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.116/Gau/2018 ("नधा"रणवष" / Assessment Year:2014-15)

For Appellant: Shri Rockein Saikia, JCIT, Sr. DRFor Respondent: Shri Sanjay Modi, FCA
Section 143(2)Section 143(3)Section 153D

…notice of demand specifying the sum payable should be served on the assessee in the prescribed form and would be accompanied by an assessment as held in the case of CIT Vs. Kailasho Devi Burman (1978) 115 ITR 732 (Cal.,) SivalingamChettiar (VS) Vs. CIT (1966) 62 ITR 678 (Mad.), Kalyankumar Ray Vs. CIT (1991) 191 ITR 634 (SC), Arrah Sasaram Light Railway Co. Ltd. Vs. CIT (1993) 204 ITR 807 (Cal), Shahdara (Delhi) Saharanpur Light Railway Co. Ltd. Vs. CIT (1994) 208 ITR 882 (Cal), etc. The limitation period prescribed in section 153 is the period within which the AO has to complete one stage of the proceedings, tha…

V.S. Sivalingam Chettiar v. CIT (62 ITR 678) — Cited in 5 Judgments | BharatTax