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“Section 66(2)”

Section References (mined)Section 66Section 66(2)35 judgments

The decision most relied on for Section 66(2) is CIT v. Mahalakshmi Textile Mills Ltd. (66 ITR 710), cited in 93 judgments on BharatTax.

Leading authorities on Section 66(2)

CIT v. Mahalakshmi Textile Mills Ltd.
66 ITR 710 · 1967 · Supreme Court
93
citing judgments

Income tax law intends to avoid double taxation, and where an item is brought to tax in one form, appropriate relief or adjustment should be provided to prevent its taxation again in another form. This principle is applicable when considering government grants or subsidies included in income and their impact on the actual cost of assets for depreciation.

T.N.K. Govindaraju Chetty v. CIT
66 ITR 465 · 1967 · Supreme Court
89
citing judgments

Interest received under Sections 28 and 34 of the Land Acquisition Act, 1894, for delayed or enhanced compensation, is a revenue receipt and is taxable under the Income Tax Act.

KNC Chandrashekhar v. ACIT SumatiDayal
66 TTJ 355 · ITAT
33
citing judgments

A cash credit can be assessed even if the transaction was conducted through a cheque, as mere proof of identity or cheque payment is insufficient to establish the creditor's creditworthiness and the genuineness of the credit.

66 (Cal) 11. Bagmane Constructions (P) Ltd. v. Commissioner of Income Tax, Bangalore
57 Taxmann.com 120 · 2015 · High Court
11
citing judgments

Loans or advances given by a company to shareholders are not deemed dividends under section 2(22)(e) if they are given in return for an advantage conferred on the company, such as being for business purposes like the purchase of an asset. This also applies if the payment is not out of accumulated profits or is a trade advance made as consideration for goods received or asset purchase.

Judgments citing Section 66(2)

R Suresh & Co, Mumbai vs. ACIT - 19(3), Mumbai

ITA 6515/MUM/2025[2010-11]Status: DisposedITAT Mumbai30 Dec 2025AY 2010-11

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Shri. Rashesh ShahFor Respondent: Assessee by
Section 143(3)Section 145(3)Section 147Section 148

Tribunal and did not move the High Court to 8 R Suresh & Co. direct a reference in regard to those questions under section 66(2), Those questions, therefore, cannot be raised in this court. We have dealt with the reference made on the basis that the finding that the amounts

Rupesh Tambi, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-2, Jaipur

In the result, the appeal of the assessee is Partly allowed

ITA 1470/JPR/2024[2015-16]Status: DisposedITAT Jaipur29 Oct 2025AY 2015-16
For Appellant: Shri S. R. Sharma, CA &For Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 1Section 132Section 133ASection 153ASection 271Section 271A

same time estimate the profit must, however, depend upon the facts of each case. The High Court, in disposing of the application under section 66(2). expressed the view that because the amount of Rs.20,000 was entered in the books of account of the business, there was some material

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

ITA 675/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Oct 2025AY 2018-19
Section 153ASection 250Section 68

आIT A Nos.56 to 61/JP/2025 Shri Ambika Garments vs. ACIT आयकर अपीलीय अधिकरण, जयपुर न्यायाधी, जयपुर IN THE INCOME TAX

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 673/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Prasad Vishwanath [1969] 72 ITR 194 (SC) [01-08-1968] has held as under:- "The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some ... same time estimate the profit must, however, depend upon the facts of each case. The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 672/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Prasad Vishwanath [1969] 72 ITR 194 (SC) [01-08-1968] has held as under:- "The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some ... same time estimate the profit must, however, depend upon the facts of each case. The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some

Shri Ambica Garments, Jodhpur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 61/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Prasad Vishwanath [1969] 72 ITR 194 (SC) [01-08-1968] has held as under:- "The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some ... same time estimate the profit must, however, depend upon the facts of each case. The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur, Jodhpur

In the result, all appeals of the assessee are disposed off in terms of

ITA 59/JPR/2025[2017-18]Status: DisposedITAT Jaipur15 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Prasad Vishwanath [1969] 72 ITR 194 (SC) [01-08-1968] has held as under:- "The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some ... same time estimate the profit must, however, depend upon the facts of each case. The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 57/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Prasad Vishwanath [1969] 72 ITR 194 (SC) [01-08-1968] has held as under:- "The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some ... same time estimate the profit must, however, depend upon the facts of each case. The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur

ITA 56/JPR/2025[2014-15]Status: DisposedITAT Jaipur15 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

same time estimate the profit must, however, depend upon the facts of each case. The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs. 20,000 was entered in the books of account of the business, there was some

Income Tax Officer Ward-1 Jhunjhunu, Jhunjhunu vs. Bagaria Trade Impex, Churu

In the result, appeal of the Revenue is allowed and order of the AO is

ITA 705/JPR/2025[2013-14]Status: DisposedITAT Jaipur29 Sept 2025AY 2013-14

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Sandeep Goel, Adv., Ld. ARFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 139Section 143(2)Section 143(3)Section 147Section 250Section 68

accepted the decision of the Tribunal and did not move the High Court to direct a reference in regard to those questions under section 66(2). Those questions, therefore, could not be raised at this stage." In the instant case also, the assessee primarily relying on technical issues and effectively ... accepted the decision of the Tribunal and did not move the High Court to direct a reference in regard to those questions under section 66(2). Those questions, therefore, could not be raised at this stage.” In the instant case also, the assessee primarily relying on technical issues and effectively

Income Tax Officer Ward 1 Jhunjhunu, Jhunjhunu vs. Bagaria Trade Impex, Churu

In the result, appeal of the Revenue is allowed and order of the AO is

ITA 697/JPR/2025[2014-15]Status: DisposedITAT Jaipur29 Sept 2025AY 2014-15

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Sandeep Goel, Adv., Ld. ARFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 139Section 143(2)Section 143(3)Section 147Section 250Section 68

accepted the decision of the Tribunal and did not move the High Court to direct a reference in regard to those questions under section 66(2). Those questions, therefore, could not be raised at this stage." In the instant case also, the assessee primarily relying on technical issues and effectively ... accepted the decision of the Tribunal and did not move the High Court to direct a reference in regard to those questions under section 66(2). Those questions, therefore, could not be raised at this stage.” In the instant case also, the assessee primarily relying on technical issues and effectively

Income Tax Officer Ward 1 Jhunjhunu, Jhunjhunu vs. Bagaria Trade Impex, Churu

In the result, appeal of the Revenue is allowed and order of the AO is

ITA 696/JPR/2025[2013-14]Status: DisposedITAT Jaipur29 Sept 2025AY 2013-14

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Sandeep Goel, Adv., Ld. ARFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 139Section 143(2)Section 143(3)Section 147Section 250Section 68

accepted the decision of the Tribunal and did not move the High Court to direct a reference in regard to those questions under section 66(2). Those questions, therefore, could not be raised at this stage." In the instant case also, the assessee primarily relying on technical issues and effectively ... accepted the decision of the Tribunal and did not move the High Court to direct a reference in regard to those questions under section 66(2). Those questions, therefore, could not be raised at this stage.” In the instant case also, the assessee primarily relying on technical issues and effectively

Income Tax Officer, Delhi vs. Akash Deep Sethi, Delhi

In the result, the appeal filed by the Revenue is dismissed and at the same time, the cross objections filed by the assessee are also dismissed

ITA 4973/DEL/2024[2021-22]Status: DisposedITAT Delhi16 Jul 2025AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri S. Rifaur Rahmanincome Tax Officer, Vs. Akash Deep Sethi, Delhi. B-236, Derawal Nagar, Model Town, Delhi – 110 009. (Pan : Abyps8933P) Co No.26/Del/2025 (In Ita No.4973/Del/2024) (Assessment Year: 2021-22) Akash Deep Sethi, Vs. Income Tax Officer, B-236, Derawal Nagar, Delhi. Model Town, Delhi – 110 009. (Pan : Abyps8933P) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate Shri Aman Garg, Ca Ms. Kirti, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 27.05.2025 Date Of Order : 16.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133(6)Section 139Section 142(1)Section 143(2)Section 143(3)Section 44A

similar to section 256 of 1961 Act were discussed and it was held that the High Court has no power under section 66(2) of the Indian Income-tax Act, 1922, which is in parimateria with section256(2) of the Act, to call upon the Appellate Tribunal to state

Sahyog Construction, Vadodara vs. The ACIT, Circle-1(1)(1) Previously Circle-1(3), Vadodara

In the result, appeal filed by the assessee is dismissed

ITA 104/AHD/2025[2017-18]Status: FixedITAT Ahmedabad03 Jul 2025AY 2017-18

Bench: PER SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri Hemant Suthar, A.RFor Respondent: Shri Kamlesh Makwana, CIT. DR
Section 115BSection 250Section 68

accepted the decision of the Tribunal and did not move the High Court to direct a reference in regard to those questions under section 66(2). Those questions, therefore, cannot be raised in this court. We have dealt with the reference made on the basis that the finding that

ITO, Ward-24(1), New Delhi vs. Sun-New Creations and Marketign Pvt. Ltd., New Delhi

The appeal of the revenue is dismissed

ITA 1096/DEL/2021[2017-18]Status: DisposedITAT Delhi25 Jun 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royito, Ward 24(1) Vs. M/S Sun New Creations New Delhi & Marketing Pvt. Ltd. A-2/71, Rajouri Garden, West Delhi, New Delhi – 110027 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacch4883P Appellant .. Respondent C.O. No. 59/Del/2025 (Assessment Year 2017-18) M/S Sun New Creations Vs. Ito, Ward 24(1) & Marketing Pvt. Ltd. New Delhi A-2/71, Rajouri Garden, West Delhi, New Delhi – 110027 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacch4883P Appellant .. Respondent

For Appellant: Sh. Vikas Jain, Adv, &For Respondent: Ms. Harpreet Kaur Hansra, Sr
Section 143(2)Section 143(3)Section 68

receipt from business. It is unnecessary to pursue this matter further, as this is not one of the questions referred under section 66(2). 11.7 While pursuing the assessment order, I find that the AO holds cash sales/service income as unexplained due to various reasons given

DCIT., Circle-13(1), Hyderabad vs. The Singareni Collieries Company Limited, Kothagudem

In the result, assessee’s appeals for the A

ITA 308/HYD/2024[AY-2020-2]Status: DisposedITAT Hyderabad12 Jun 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd आयकर अपील"य अ

DCIT., Circle-13(1), Hyderabad vs. The Singareni Collieries Company Ltd, Kothagudem

In the result, assessee’s appeals for the A

ITA 300/HYD/2024[2015--16]Status: DisposedITAT Hyderabad12 Jun 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd आयकर अपील"य अ

Singareni Collieries Company Limited, Kothagudem vs. ACIT., Circle-1, Khammam

In the result, assessee’s appeals for the A

ITA 284/HYD/2024[2016-17]Status: DisposedITAT Hyderabad12 Jun 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd आयकर अपील"य अ

Singareni Collieries Company Limited, Kothagudem vs. ACIT., Circle- 1, Khammam

In the result, assessee’s appeals for the A

ITA 283/HYD/2024[2015-16]Status: DisposedITAT Hyderabad12 Jun 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

ITA Nos 283 284 286 and 300 301 and 308 of 2024 Singareni Collieries Company Ltd आयकर अपील"य अ

Kailash Chand Maheshwari, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

ITA 1465/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 May 2025AY 2017-18
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

same time estimate the profit must, however, depend upon the facts of each case. ……………… The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs.20,000 was entered in the books of account of the business, there was some material