Vindhiya Metal Corporation v. CIT

156 ITR 233Reported decision#8784 most cited

What is Vindhiya Metal Corporation v. CIT authority for?

The existence of a condition precedent for exercising powers under Section 132 of the Income Tax Act is open to judicial scrutiny. The absence of such a condition precedent can vitiate the authorization and subsequent proceedings.

12

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2025 to 2025.

Also referred to as

Vindhiya Metal Corporation v. CIT · 156 ITR 233 · section 132 · condition precedent · judicial scrutiny · vitiating authorisation · search and seizure · assessment proceedings

Sections most often in play

Section 131Section 132Section 132ASection 133ASection 143(3)Section 147Section 153ASection 226

Issues it is cited on

section 132(1)(a)section 102section 226warrant of authorisationsection 131(1a)survey under section 133apanchnamasection 22section 132(1)satisfaction notesection 132aescapement of income

Judgments citing Vindhiya Metal Corporation v. CIT

Protein Entertainment Pvt Ltd., Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru

In the result, all the appeals of the assessee are hereby partly allowed

ITA 591/BANG/2024[2017-18]Status: DisposedITAT Bangalore23 May 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Protein Entertainment Pvt Ltd., Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru

In the result, all the appeals of the assessee are hereby partly allowed

ITA 590/BANG/2024[2016-17]Status: DisposedITAT Bangalore23 May 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Protein Entertainment Pvt Ltd., Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru

In the result, all the appeals of the assessee are hereby partly allowed

ITA 589/BANG/2024[2015-16]Status: DisposedITAT Bangalore23 May 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Protein Entertainment Pvt Ltd., Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru

In the result, all the appeals of the assessee are hereby partly allowed

ITA 588/BANG/2024[2014-15]Status: DisposedITAT Bangalore23 May 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Protein Entertainment Pvt Ltd., Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru

In the result, all the appeals of the assessee are hereby partly allowed

ITA 587/BANG/2024[2013-14]Status: DisposedITAT Bangalore23 May 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Protein Entertainment Pvt Ltd., Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru

In the result, all the appeals of the assessee are hereby partly allowed

ITA 586/BANG/2024[2012-13]Status: DisposedITAT Bangalore23 May 2025AY 2012-13

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Dommallur Shivanna Nandish, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bangalore

In the result, all the appeals of the assessee are hereby partly allowed

ITA 339/BANG/2024[2017-18]Status: DisposedITAT Bangalore23 May 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Dommallur Shivanna Nandish, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bangalore

In the result, all the appeals of the assessee are hereby partly allowed

ITA 338/BANG/2024[2016-17]Status: DisposedITAT Bangalore23 May 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Dommallur Shivanna Nandish, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle -1(2), Bangalore

In the result, all the appeals of the assessee are hereby partly allowed

ITA 337/BANG/2024[2015-16]Status: DisposedITAT Bangalore23 May 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Dommallur Shivanna Nandish, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bengaluru

In the result, all the appeals of the assessee are hereby partly allowed

ITA 336/BANG/2024[2014-15]Status: DisposedITAT Bangalore23 May 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Dommallur Shivanna Nandish, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bangalore

In the result, all the appeals of the assessee are hereby partly allowed

ITA 335/BANG/2024[2013-14]Status: DisposedITAT Bangalore23 May 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Docket Tech Solutions Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(2), Bangalore

In the result, all the appeals of the assessee are hereby partly allowed

ITA 1566/BANG/2024[2017-18]Status: DisposedITAT Bangalore23 May 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 131Section 133A

…preconditions under section 132 of the Act. In . ITA No.334-339, 586-591 & 1566/Bang/2024 Page 21 of 24 holding so, we draw support and guidance from the decision of Hon’ble Allahabad High Court in the case of Vindhiya Metal Corporation vs. CIT reported in 156 ITR 233 where it was held as under: It is settled that the existence or otherwise of the condition precedent to exercise of power under these provisions is open to judicial scrutiny. The absence of the condition precedent would naturally have the effect of vitiating the authorisation made by the Commissioner in either of the two provisions and the procee…

Vindhiya Metal Corporation v. CIT (156 ITR 233) — Cited in 12 Judgments | BharatTax