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“Section 2(7)”

Section References (mined)Section 2Section 2(7)56 judgments

MRS. SUREKHA LEGAL REPRESENTATIVE OF LATE SHRI. DEVARAJ,BENGALURU vs. INCOME TAX OFFICER, WARD-7(2)(5), BANGALORE

In the result, appeal filed by the assessee is allowed

ITA 2419/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19 Mrs. Surekha (Legal Representative Of Late Shri Devaraj, Since Dead) No.112, 1St Main, Ramarao Layout Vs. Ito Bsk 3Rd Phase, 3Rd Stage Ward 7(2)(5) Bengaluru 560 085 Bengaluru Pan No :Asvps2939R Appellant Respondent Appellant By : Sri Balachandran, A.R. Respondent By : Sri N. Balusamy, D.R. Date Of Hearing : 17.02.2026 Date Of Pronouncement : 06.03.2026

For Appellant: Sri Balachandran, A.RFor Respondent: Sri N. Balusamy, D.R
Section 143(2)Section 250

made out under section 159(2) of the Act as well as in light of the definition of assessee under section 2(7)(b) read with section 159 is a matter that also requires consideration. 16. There is no dispute as regards to the general proposition that proceedings against

JADAGADDER PAKKERAPPA, LEGAL HEIR SAROJAMMA,SHIKARIPURA vs. INCOME TAX OFFICER, WARD-1 & TPS,, SHIMOGA

In the result, appeal filed by the assessee is allowed

ITA 1406/BANG/2025[2016-17]Status: DisposedITAT Bangalore25 Feb 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17

For Appellant: Sri Varun Bhat, A.RFor Respondent: Sri Balusamy N., D.R
Section 142(1)Section 144Section 147Section 148Section 15Section 250

made out under section 159(2) of the Act as well as in light of the definition of assessee under section 2(7)(b) read with section 159 is a matter that also requires consideration. 16. There is no dispute as regards to the general proposition that proceedings against

INDEPENDENT AND PUBLIC SPIRITED MEDIA FOUNDATION ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, (CENTRAL), BENGALURU

In the result appeal of the assessee is dismissed

ITA 625/BANG/2023[Nill]Status: DisposedITAT Bangalore16 Jan 2026

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : Na

For Appellant: S/Shri. A. Sheshadri, CA and Bhardwaj Sheshadri, AdvocateFor Respondent: Shri
Section 11Section 12Section 12ASection 133A

Further, under the income tax system, jurisdiction over a 'case' is recognized by the PAN assigned to each person/ assessee as defined in section 2(7) of the Act. The jurisdiction of each PAN is assigned to a particular CIT/Assessing Officer according to alphabetical or territorial basis. The CIT/AO exercises

ANDHRA PRADESH STATE CIVIL SUPPLIES CORPORATION LIMITED,KANURU vs. ITO, TDS, WARD(1), ELURU, ELURU

In the result, appeal of the assessee is allowed for statistical purposes

ITA 29/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam03 Dec 2025AY 2019-20

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.29/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2019-20) Vs. Andhra Pradesh State Civil The Income Tax Officer (Tds)-Ward-1 Eluru – 534001 Supplies Corporation Limited Andhra Pradesh 10-152/1, 4Th Floor Sai Towers, Ashok Nagar Bandar Road, Kanuru – 520007 Andhra Pradesh [Pan: Aabca7161R]

Section 154Section 201(1)Section 249(2)Section 249(3)

आयकर अपीलीय अधिकरण, धिशाखापटणम पीठ, धिशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM “DIVISION” BENCH, VISAKHAPATNAM (HYBRID HEARING) श्री रिीश

M/S U.P STATE INDUSTRIAL DEVELOPMENT CORPORATION LTD.,KANPUR vs. ASTT. COMMISSIONER OF INCOME TAX-VI, KANPUR

ITA 4/LKW/2004[1996-97]Status: DisposedITAT Lucknow14 Oct 2025AY 1996-97
For Appellant: Sh. Pankaj Shukla, Adv & ShubhamFor Respondent: Sh. Puneet Kumar, CIT DR
Section 10Section 17Section 2Section 2(5)Section 2(7)Section 8(2)

unless, the two conditions, viz, (a) the receipts are in the nature of "chargeable Interest" as defined in section 2(5) read with section 2(7) of the "Act"; and (b) the recipients of such income is a "Credit Institution' or 'any other financial company' as defined under the exhaustion ... mentioned above can be treated as 'chargeable interest' under section 2(5) of the Act read with the definition of interest under section 2(7) of the "Act". 8. BECAUSE the receipts amounting to Rs. 1,90,31,586/- by way of interest on "Loan and Others including UPSEB Loans

M/S U.P STATE INDUSTRIAL DEVELOPMENT CORPORATION LTD.,KANPUR vs. ASTT. COMMISSIONER OF INCOME TAX-VI, KANPUR

In the result, both the appeals of the assessee is held to be partly allowed

ITA 3/LKW/2004[1995-96]Status: DisposedITAT Lucknow14 Oct 2025AY 1995-96
For Appellant: \nSh. Pankaj Shukla, Adv & Shubham
Section 10Section 17Section 2Section 2(5)Section 2(7)Section 8(2)

conditions, viz,\n(a) the receipts are in the nature of \"chargeable Interest\" as defined in section 2(5)\nread with section 2(7) of the \"Act\"; and\n(b) the recipients of such income is a \"Credit Institution' or 'any other financial\ncompany' as defined under the exhaustion definitions ... mentioned above can be treated as\n'chargeable interest' under section 2(5) of the Act read with the definition of\ninterest under section 2(7) of the \"Act\".\n8. BECAUSE the receipts amounting to Rs.1,90,31,586/- by way of interest on\n\"Loan and Others including UPSEB

ADVANTAGE INDIA,NEW DELHI vs. PR.CIT (CENTRAL)-II, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 634/DEL/2019[-]Status: DisposedITAT Delhi18 Sept 2025
For Appellant: \nShri Sanjay Mehra, FCAFor Respondent: \nShri Javed Akhtar, CIT [DR]
Section 127Section 127(2)Section 12A

Further, under the income tax system, jurisdiction over\na 'case' is recognized by the PAN assigned to each person/\nassessee as defined in section 2(7) of the Act. The jurisdiction\nof each PAN is assigned to a particular CIT/Assessing Officer according\nto alphabetical or territorial basis. The CIT/AO exercises

LATE SATISH MEHTA THRU LH KAPIL MEHTA,DELHI vs. ITO WARD 34(4) NEW DELHI, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 4646/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Aug 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Raj Kumar, CAFor Respondent: Shri Manish Gupta, Sr. DR
Section 142(1)Section 143(2)Section 159Section 159(3)Section 2(7)

find that the legal representative of late Satish Mehta is his son Sh. Kapil Mehta. The deemed assessee u/s 159(3) read with section 2(7) would therefore be "Kapil Mehta" and not Late Satish Mehta who would be liable to pay tax relating to Lt. Satish Mehta

JAWAHARLAL GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI

In the result, all appeals filed by the respective assesses are allowed

ITA 538/MUM/2025[2007-08]Status: DisposedITAT Mumbai29 Jul 2025AY 2007-08

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal &For Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

India for a period or periods amounting in all to sixty days or more in that year.” 27. Further, reference was drawn to section 2(7), which defines "assessee" for the purpose of the Act as under: "2. In this Act, unless the context otherwise requires: (7) "assessee" means

SHAM GULABRAI TULSYANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI

In the result, all appeals filed by the respective assesses are allowed

ITA 483/MUM/2025[2007-08]Status: DisposedITAT Mumbai29 Jul 2025AY 2007-08
For Appellant: Shri Ashok Khandelwal & Akash KhandelwalFor Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

period or periods amounting in all to sixty days or more in that year.”\n\n27.\nFurther, reference was drawn to section 2(7), which defines \"assessee\" for the purpose of the Act as under:\n\n"2. In this Act, unless the context otherwise requires:\n(7) \"assessee\" means

NARAINDAS GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1),, MUMBAI

In the result, all appeals filed by the respective assesses are allowed

ITA 464/MUM/2025[2006-07]Status: DisposedITAT Mumbai29 Jul 2025AY 2006-07

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal &For Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

India for a period or periods amounting in all to sixty days or more in that year.” 27. Further, reference was drawn to section 2(7), which defines "assessee" for the purpose of the Act as under: "2. In this Act, unless the context otherwise requires: (7) "assessee" means

NARAINDAS GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI

In the result, all appeals filed by the respective assesses are allowed

ITA 463/MUM/2025[2007-08]Status: DisposedITAT Mumbai29 Jul 2025AY 2007-08

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal &For Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

India for a period or periods amounting in all to sixty days or more in that year.” 27. Further, reference was drawn to section 2(7), which defines "assessee" for the purpose of the Act as under: "2. In this Act, unless the context otherwise requires: (7) "assessee" means

PARTAB GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1), MUMBAI, MUMBAI

In the result, all appeals filed by the respective assesses are allowed

ITA 449/MUM/2025[2007-08]Status: DisposedITAT Mumbai29 Jul 2025AY 2007-08

Bench: Shri Amit Shukla & Shri Vikram Singh Yadav

For Appellant: Shri Ashok Khandelwal &For Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

India for a period or periods amounting in all to sixty days or more in that year.” 27. Further, reference was drawn to section 2(7), which defines "assessee" for the purpose of the Act as under: "2. In this Act, unless the context otherwise requires: (7) "assessee" means

PARTAB GULABRAI TULSIANI,DELHI vs. ACIT, INT. TAX CIRCLE 4(2)(1),, MUMBAI

ITA 448/MUM/2025[2006-07]Status: DisposedITAT Mumbai29 Jul 2025AY 2006-07
For Appellant: Shri Ashok Khandelwal & Akash KhandelwalFor Respondent: Shri Krishna Kumar, Sr.DR
Section 147Section 149(1)(c)Section 234ASection 254

period or periods amounting in all to sixty days or more in that year.”\n\n27. Further, reference was drawn to section 2(7), which defines \"assessee\" for the purpose of the Act as under:\n\n"2. In this Act, unless the context otherwise requires:\n\n(7) \"assessee

SUNIL GUPTA,DELHI vs. ACIT, CIRCLE-55(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 634/DEL/2020[2012-13]Status: DisposedITAT Delhi21 Feb 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Naveen Chandraadvantage India Vs. The Pr. C.I.T 101-102, Oriental House Central - 2 Gulmohar Enclave New Delhi New Delhi

For Appellant: Shri Sanjay Mehra, FCAFor Respondent: Shri Javed Akhtar, CIT [DR]
Section 127Section 127(2)Section 12ASection 13(1)(c)

Further, under the income tax system, jurisdiction over a ‘case’ is recognized by the PAN assigned to each person/ assessee as defined in section 2(7) of the Act. The jurisdiction of each PAN is assigned to a particular CIT/Assessing Officer according to alphabetical or territorial basis. The CIT/AO exercises

INCOME TAX OFFICER, WARD- 3(1), GANGTOK, GANGTOK, SIKKIM vs. NIRMALA SHARMA, SORENG, WEST SIKKIM

In the result, both the appeals filed by the assessee as well as the Revenue are allowed for statistical purposes

ITA 2298/KOL/2024[2018-19]Status: DisposedITAT Kolkata13 Feb 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 10Section 147Section 250Section 69

frequently as payment to labourers had to be made. Since the income was exempt u/s 10(26AAA) of the Act and as per section 2(7) of the Act she was not an assessee as an assessee means a person by whom any tax or any other sum of money

NIRMALA SHARMA,GANGTOK vs. I.T.O., WARD - 3(1), GANGTOK, GANGTOK

In the result, both the appeals filed by the assessee as well as the Revenue are allowed for statistical purposes

ITA 2227/KOL/2024[2018-2019]Status: DisposedITAT Kolkata13 Feb 2025AY 2018-2019

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 10Section 147Section 250Section 69

frequently as payment to labourers had to be made. Since the income was exempt u/s 10(26AAA) of the Act and as per section 2(7) of the Act she was not an assessee as an assessee means a person by whom any tax or any other sum of money

ACIT-16(2), MUMBAI, AAYAKAR BHAVAN vs. FAKHRUDDIN TAIYEBALI PADARIA, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 5500/MUM/2024[2017-18]Status: DisposedITAT Mumbai07 Jan 2025AY 2017-18

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailassessment Year: 2017-18 Acit- 16(2), Mumbai Fakhruddin Taiyebali Padaria 5Th Floor, Shabbir Place, 80 Vs. Dr. A.L. Nair Road, Mumbai- 400008. Pan: Abdpp 7103 P (Appellant) (Respondent) Present For: Assessee By : None Revenue By : Shri Dinesh A Chourasia, Sr. Dr Date Of Hearing : 03.12.2024 Date Of Pronouncement : 07.01.2025

For Appellant: NoneFor Respondent: Shri Dinesh A Chourasia, Sr. DR
Section 144Section 147Section 148Section 159Section 250Section 292BSection 69A

name of a dead person. Since strong reliance has been placed by the learned counsel for the respondent on the provisions of section 2(7) and 2(29) read with sections 159 and 292B of the Act, reference may be made to the said provisions, which read as under ... Fakhruddin Taiyebali Padaria A.Y. 2017-18 "Section 2(7) "assessee" means a person by whom any tax or any other sum of money is payable under this Act, and includes – (a) every person in respect of whom any proceeding under the Act has been taken for the assessment

VIDHARBHA KONKAN GRAMIN BANK ,NAGPUR vs. INCOME TAX OFFICER WARD 1(5) , NAGPUR

In the result, appeal filed by the assessee for A

ITA 8/NAG/2019[2015-2016]Status: DisposedITAT Nagpur28 Nov 2024AY 2015-2016

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri C. NareshFor Respondent: Shri Sandipkumar Salunke
Section 22Section 36(1)Section 36(1)(viia)Section 36(1)(viii)Section 80P

have to go by the letter of the law, and not its spirit or intent." The new definition of the word "interest" in section 2(7) is in two parts. Firstly, it says that "interest" means interest on loans and advances. Secondly, it includes two other items in the definition ... advances. Secondly, two other categories are also included in the definition of the word "interest" as specified in clauses (a) and (b) of section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT v. Sahara India Savings and Investment Corporation

VIDHARBHA KONKAN GRAMIN BANK ,NAGPUR vs. INCOME TAX OFFICER WARD 1(5) , NAGPUR

In the result, appeal filed by the assessee for A

ITA 7/NAG/2019[2014-15]Status: DisposedITAT Nagpur28 Nov 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri C. NareshFor Respondent: Shri Sandipkumar Salunke
Section 22Section 36(1)Section 36(1)(viia)Section 36(1)(viii)Section 80P

have to go by the letter of the law, and not its spirit or intent." The new definition of the word "interest" in section 2(7) is in two parts. Firstly, it says that "interest" means interest on loans and advances. Secondly, it includes two other items in the definition ... advances. Secondly, two other categories are also included in the definition of the word "interest" as specified in clauses (a) and (b) of section 2(7). In our opinion, the word "means can only have one meaning, that is, it is CIT v. Sahara India Savings and Investment Corporation

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