VLS Finance Ltd. v. CIT (Del)

113 ITD 655Income Tax Appellate Tribunal#2324 most cited

What is VLS Finance Ltd. v. CIT (Del) authority for?

In search assessments, income-tax authorities are not at fault for adopting a less drastic procedure, such as a restraint order instead of seizing all books, if they only seize necessary documents. Such an assessment is not barred by limitation if completed within the prescribed period, calculated from the date of the last panchanama.

49

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2022.

Also referred to as

VLS Finance Ltd. v. CIT · 113 ITD 655 · section 153A(1)(b) · search assessment · limitation period · panchanama date · restraint order · seizure of books · time barred assessment

Issues it is cited on

time barred assessmentcasus omissussection 153a(1)(b)section 2(22)section 153(1)deemed dividendsection 2(22)(e)section 40a(2)kelvinatormere change of opinionpanchnamasection 194a

Judgments citing VLS Finance Ltd. v. CIT (Del)

DCIT, COIMBATORE vs. O.ARUMUGASAMY, COIMBATORE

ITA 777/CHNY/2017[2012-13]Status: DisposedITAT Chennai28 Sept 2022AY 2012-13

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

O.ARUMUGASAMY,CHENNAI vs. DCIT, COIMBATORE

ITA 763/CHNY/2017[2012-13]Status: DisposedITAT Chennai28 Sept 2022AY 2012-13

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. SHRI A. SENTHILKUMAR, COIMBATORE

ITA 2707/CHNY/2016[2011-12]Status: DisposedITAT Chennai28 Sept 2022AY 2011-12

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

A. SENTHIL KUMAR,COIMBATORE vs. DCIT, COIMBATORE

ITA 2570/CHNY/2016[2011-12]Status: DisposedITAT Chennai28 Sept 2022AY 2011-12

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. O.ARUMUGASAMY, COIMBATORE

ITA 1833/CHNY/2015[2011-12]Status: DisposedITAT Chennai28 Sept 2022AY 2011-12

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. O.ARUMUGASAMY, COIMBATORE

ITA 1398/CHNY/2015[2008-09]Status: DisposedITAT Chennai28 Sept 2022AY 2008-09

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. O.ARUMUGASAMY, COIMBATORE

ITA 1011/CHNY/2015[2010-11]Status: DisposedITAT Chennai28 Sept 2022AY 2010-11

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. A.SENTHIL KUMAR, COIMBATORE

ITA 1010/CHNY/2015[2010-11]Status: DisposedITAT Chennai28 Sept 2022AY 2010-11

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. SENTHIL ENTERPRISES, COIMBATORE

ITA 709/CHNY/2014[2010-11]Status: DisposedITAT Chennai28 Sept 2022AY 2010-11

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. SHRI T.M.MUTHUKUMAR, COIMBATORE

ITA 150/CHNY/2013[2005-06]Status: DisposedITAT Chennai28 Sept 2022AY 2005-06

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. SHRI O.ARUMUGASAMY, COIMBATORE

ITA 144/CHNY/2013[2009-10]Status: DisposedITAT Chennai28 Sept 2022AY 2009-10

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. SHRI O.ARUMUGASAMY, COIMBATORE

ITA 143/CHNY/2013[2008-09]Status: DisposedITAT Chennai28 Sept 2022AY 2008-09

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. SHRI M.PALANISAMY, COIMBATORE

ITA 142/CHNY/2013[2009-10]Status: DisposedITAT Chennai28 Sept 2022AY 2009-10

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. SHRI M.PALANISAMY, COIMBATORE

ITA 141/CHNY/2013[2008-09]Status: DisposedITAT Chennai28 Sept 2022AY 2008-09

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

ITA 140/CHNY/2013[2009-10]Status: DisposedITAT Chennai28 Sept 2022AY 2009-10

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

ITA 139/CHNY/2013[2008-09]Status: DisposedITAT Chennai28 Sept 2022AY 2008-09

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT,, COIMBATORE vs. SHRI. O. ARUMUGASAMY,, COIMBATORE

ITA 860/CHNY/2012[2007-08]Status: DisposedITAT Chennai28 Sept 2022AY 2007-08

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT,, COIMBATORE vs. SHRI. O. ARUMUGASAMY,, COIMBATORE

ITA 859/CHNY/2012[2006-07]Status: DisposedITAT Chennai28 Sept 2022AY 2006-07

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT,, COIMBATORE vs. SHRI. O. ARUMUGASAMY,, COIMBATORE

ITA 858/CHNY/2012[2005-06]Status: DisposedITAT Chennai28 Sept 2022AY 2005-06

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

DCIT,, COIMBATORE vs. SHRI. O. ARUMUGASAMY,, COIMBATORE

ITA 857/CHNY/2012[2004-05]Status: DisposedITAT Chennai28 Sept 2022AY 2004-05

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

Section 132Section 153A

…ssment on 31.12.2008 is, in my view, in order. 7.3. In the following cases, it has been held that authorities could not be faulted for following a less drastic procedure. "a) VLS Finance Ltd. Vs. CIT (Del) 289 ITR 286 b) Krishna Verma Vs. ACIT (1TAT, SB-Del) 113 ITD 655 Search during 29.6.98 to 5.8.98Last panchanama drawn on 5.8.98 ie within 60 days of initiation of search- Limitation of two year period would come to an end on 30.8.2000 – No ulterior motives could be attributed to the authorities in failing to seize the books of accounts and instead passing a restraint order – The authorities went through the bo…

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VLS Finance Ltd. v. CIT (Del) (113 ITD 655) — Cited in 49 Judgments | BharatTax