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“Section 31(3)”

Section References (mined)Section 31Section 31(3)61 judgments

MENAKURU SUKUMAR REDDY,HYDERABAD vs. DCIT(A), CHENNAI

ITA 993/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 251(2)Section 69A

Shapoorji Pallonji Mistry 44 ITR 891 (SC), wherein it was held\nthat:\n“Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the\nIndian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment\nyear 1947-48 - Whether it would not be open ... principle that emerges as a result of the authorities of this court is that the\nAppellate Assistant Commissioner has no jurisdiction, under section 31(3) of the\nAct, to assess a source of income which has not been processed by the\nIncometax Officer and which is not disclosed either

MENAKURU SUKUMAR REDDY,HYDERABAD vs. DCIT(A), CHENNAI

In the result the appeal of the revenue is dismissed

ITA 992/CHNY/2025[2016-17]Status: DisposedITAT Chennai02 Mar 2026AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 147Section 148Section 251(2)Section 69A

Shapoorji Pallonji Mistry 44 ITR 891 (SC), wherein it was held that: “Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the Indian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment year 1947-48 - Whether it would not be open to AAC to introduce ... principle that emerges as a result of the authorities of this court is that the Appellate Assistant Commissioner has no jurisdiction, under section 31(3) of the Act, to assess a source of income which has not been processed by the Incometax Officer and which is not disclosed either

MENAKURU SUKUMAR REDDY,HYDERABAD vs. DCIT(A), CHENNAI

In the result the appeal of the revenue is dismissed

ITA 991/CHNY/2025[2015-16]Status: DisposedITAT Chennai02 Mar 2026AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 147Section 148Section 251(2)Section 69A

Shapoorji Pallonji Mistry 44 ITR 891 (SC), wherein it was held that: “Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the Indian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment year 1947-48 - Whether it would not be open to AAC to introduce ... principle that emerges as a result of the authorities of this court is that the Appellate Assistant Commissioner has no jurisdiction, under section 31(3) of the Act, to assess a source of income which has not been processed by the Incometax Officer and which is not disclosed either

ACIT, CHENNAI vs. MENAKURU SUKUMAR REDDY , CHENNAI

ITA 1644/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 251(2)Section 69A

Shapoorji Pallonji Mistry 44 ITR 891 (SC), wherein it was held\nthat:\n“Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the\nIndian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment\nyear 1947-48 - Whether it would not be open ... principle that emerges as a result of the authorities of this court is that the\nAppellate Assistant Commissioner has no jurisdiction, under section 31(3) of the\nAct, to assess a source of income which has not been processed by the\nIncometax Officer and which is not disclosed either

ACIT, CHENNAI vs. MENAKURU SUKUMAR REDDY, CHENNAI

ITA 1639/CHNY/2025[2015-16]Status: DisposedITAT Chennai02 Mar 2026AY 2015-16
For Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 147Section 148Section 251(2)Section 69A

Shapoorji Pallonji Mistry 44 ITR 891 (SC), wherein it was held\nthat:\n“Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the\nIndian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment\nyear 1947-48 - Whether it would not be open ... principle that emerges as a result of the authorities of this court is that the\nAppellate Assistant Commissioner has no jurisdiction, under section 31(3) of the\nAct, to assess a source of income which has not been processed by the\nIncometax Officer and which is not disclosed either

BHASIN MOTORS LTD,NEW DELHI vs. ACIT, CIRCLE -(4)2, NEW DELHI

ITA 5544/DEL/2019[2014-15]Status: DisposedITAT Delhi11 Feb 2026AY 2014-15
Section 133(6)Section 143(3)Section 150(1)Section 234ASection 251(1)(c)Section 251(2)Section 68

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL,\nDELHI BENCH: ‘F' NEW DELHI\nBEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

BHASIN MOTORS PVT. LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-2, NEW DELHI

ITA 1699/DEL/2019[2014-15]Status: DisposedITAT Delhi11 Feb 2026AY 2014-15
Section 143(3)Section 150(1)Section 234ASection 251(1)(c)Section 251(2)Section 68

{ "clean_text": "ITA Nos.1699 & 5544/Del/2019\n\nIN THE INCOME TAX APPELLATE TRIBUNAL,\nDELHI BENCH: ‘F' NEW DELHI\n\nBEFORE SHRI

KAKINADA INFRASTRUCTURE HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

ITA 1053/HYD/2025[2021-2022]Status: DisposedITAT Hyderabad21 Jan 2026AY 2021-2022
For Appellant: \nShri Naresh Jain, AdvocateFor Respondent: MS Reema Yadav, Sr. AR
Section 270A

Income Tax, U.P. v. Kanpur Coal Syndicate\nMANU/SC/0123/1964: [1964]531TR225(SC) a three Judge Bench\nof this Court discussed the scope of Section 31(3)(a) of the Income\nTax Act, 1922 which is almost identical to Section 251(1)(a). The\nCourt held as under ... appeal lies, Section 31 of the Act describes the powers\nof the Appellate Assistant Commissioner in such an appeal.\nUnder Section 31(3)(a) in disposing of such an appeal the\nAppellate Assistant Commissioner may, in the case of an\norder of assessment, confirm, reduce, enhance or annul the\nassessment

DBG LEASING AND HOUSING LTD.,,NEW DELHI vs. ITO-7(1), NEW DELHI

In the result, the Assessee’s appeal is dismissed

ITA 8308/DEL/2019[2008-09]Status: DisposedITAT Delhi15 Dec 2025AY 2008-09

Bench: Shri Mahavir Singh & Shri Krinwant Sahayasstt. Year : 2008-09 Dbg Leasing & Housing Ltd., Vs Ito, Ward 7(1), New Delhi C-88, Gali No. 8, Jyoti Colony, Shahdara, Delhi – 110 032 (Pan: Aaacd0473F) (Appellant) (Respondent) Appellant By : Shri Ved Jain, Adv. & Ms. Uma Upadhyay, Ca Respondent By : Ms. Harpreet Kaur Hansra, Sr. Dr

For Appellant: Shri Ved Jain, Adv. & Ms. Uma Upadhyay, CAFor Respondent: Ms. Harpreet Kaur Hansra, SR. DR
Section 147Section 29ASection 30(2)Section 31(1)

Corporate Insolvency Resolution Process of the corporate debtor and the Resolution Plan to IBBI to be recorded in its database in terms of Section 31(3) (b) of the Code. The Resolution Professional is further directed to hand over all the records, premises, and properties of the corporate debtor

JAI MATA DI OM,THANE vs. PR. COMM. OF INCOME TAX, THANE-1, THANE

In the result, the appeal of the assessee is allowed

ITA 3342/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 Oct 2025AY 2021-22
For Appellant: Shri Subodh Ratnaparkhi, ARFor Respondent: Shri Vivek Perampurna (CIT-DR)
Section 143Section 143(3)Section 263Section 69C

nITR 688 and CIT v. Kanpur Coal Syndicate [1964] 53 ITR\n225(SC), the Court inter alia held that under section 31(3)(a) in\ndisposing of such an appeal the Appellate Assistant Commissioner\nmay, in the case of an order of assessment, confirm, reduce, enhance or\nannul the assessment

M/S KOHINOOR FOODS LTD.,DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are allowed as indicated above

ITA 1549/DEL/2016[2011-12]Status: DisposedITAT Delhi22 Aug 2025AY 2011-12

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’: NEW DELHI BEFORE SHRI PRAKASH CHAND YADAV, JUDICIAL MEMBER AND SHRI

M/S KOHINOOR FOODS LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

In the result, both the appeals of the assessee are allowed as indicated above

ITA 1900/DEL/2015[2010-11]Status: DisposedITAT Delhi22 Aug 2025AY 2010-11

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’: NEW DELHI BEFORE SHRI PRAKASH CHAND YADAV, JUDICIAL MEMBER AND SHRI

DOCTOR BAWITLUNG ZOTHANKIMA,AIZAWL vs. DCIT, SILCHAR

Appeal of the assessee is partly allowed for statistical purposes

ITA 212/GTY/2024[2021-22]Status: DisposedITAT Guwahati11 Aug 2025AY 2021-22

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 10(26)Section 250Section 68Section 69A

principle that emerges as a result of the authorities of this court is that the Appellate Assistant Commissioner has no jurisdiction, under section 31(3) of the Act, to assess a source of income which has not been processed by the ITO and which is not disclosed either ... therefore, the Appellate Assistant Commissioner cannot travel beyond the subject-matter of the assessment. In other words, the power of enhancement under section 31(3) of the Act is restricted to the subject-matter of assessment or the source of income which have been considered expressly or by clear implication

CUPID DIAMONDS PRIVATE LIMITED,MUMBAI vs. PRICIPAL COMMISSIONER OF INCOME TAX-5, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 478/MUM/2025[2021-22]Status: DisposedITAT Mumbai11 Aug 2025AY 2021-22
For Appellant: \nShri Shubhash Shetty & Shri Vinayaka RaoFor Respondent: \nShri R.A. Dhyani, (CIT-DR)
Section 133(6)Section 143(3)Section 263

nITR 688 and CIT v. Kanpur Coal Syndicate [1964] 53 ITR\n225(SC), the Court inter alia held that under section 31(3)(a) in\ndisposing of such an appeal the Appellate Assistant Commissioner\nmay, in the case of an order of assessment, confirm, reduce, enhance or\nannul the assessment

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(3), MUMBAI, MUMBAI vs. PHULCHAND EXPORTS PRIVATE LIMITED, MUMBAI

In the result, appeals of the Revenue in ITA No

ITA 3103/MUM/2025[2019-20]Status: DisposedITAT Mumbai04 Aug 2025AY 2019-20
For Appellant: Shri Shankarlal Jain & Shri Satish KumarFor Respondent: Shri R.A Dhyani, (CIT-DR)
Section 132Section 143(3)Section 14ASection 153ASection 36(1)(iii)

Court held as under:-\n\"5. In CIT v. Kanpur Coal Syndicate, a three Judge bench of this Court discussed the scope of Section 31(3)(a) of the Income Tax Act, :1922 which is almost identical to Section 251(l)(a). The court held - asunder ... appeal lies, Section 31 of the Act describes the powers of the Appellate Assistant Commissioner in such an appeal. Under Section 31(3)(a) in disposing of such an appeal the Appellate Assistant Commissioner may, in the case of an order of assessment, confirm, reduce, enhance or annul the assessment

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 3(3), MUMBAI, MUMBAI vs. PHULCHAND EXPORTS PRIVATE LIMITED, MUMBAI

In the result, appeals of the Revenue in ITA No

ITA 3102/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Aug 2025AY 2018-19
For Appellant: \nShri Shankarlal Jain & Shri Satish KumarFor Respondent: \nShri R.A Dhyani, (CIT-DR)
Section 132Section 143(3)Section 14ASection 153ASection 36(1)(iii)

Court held as under:-\n"5. In CIT v. Kanpur Coal Syndicate, a three Judge bench of this Court\ndiscussed the scope of Section 31(3)(a) of the Income Tax Act, :1922 which is\nalmost identical to Section 251(l)(a). The court held - asunder ... appeal lies, Section 31 of the Act describes the powers of the Appellate\nAssistant Commissioner in such an appeal. Under Section 31(3)(a) in\ndisposing of such an appeal the Appellate Assistant Commissioner may, in\nthe case of an order of assessment, confirm, reduce, enhance or annul the\nassessment

PHULCHAND EXPORTS PVT LTD ,MUMBAI vs. ASST. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 3(3), MUMBAI

In the result, appeals of the Revenue in ITA No

ITA 2415/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Aug 2025AY 2018-19
For Respondent: \nShri Shankarlal Jain & Shri Satish Kumar
Section 132Section 143(3)Section 14ASection 153ASection 36(1)(iii)

Court held as under:-\n\"5. In CIT v. Kanpur Coal Syndicate, a three Judge bench of this Court\ndiscussed the scope of Section 31(3)(a) of the Income Tax Act, :1922 which is\nalmost identical to Section 251(l)(a). The court held - asunder ... appeal lies, Section 31 of the Act describes the powers of the Appellate\nAssistant Commissioner in such an appeal. Under Section 31(3)(a) in\ndisposing of such an appeal the Appellate Assistant Commissioner may, in\nthe case of an order of assessment, confirm, reduce, enhance or annul the\nassessment

KAUSHAL ANIL SHAH,MUMBAI vs. PR. CIT-20, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 1952/MUM/2025[2021-22]Status: DisposedITAT Mumbai04 Aug 2025AY 2021-22
For Appellant: \nShri Reepal G. Trashawala,ARFor Respondent: \nShri Ritesh Misra,(CIT-DR)
Section 143(3)Section 263Section 271ASection 69C

nITR 688 and CIT v. Kanpur Coal Syndicate [1964] 53 ITR\n225(SC), the Court inter alia held that under section 31(3)(a) in\ndisposing of such an appeal the Appellate Assistant Commissioner\nmay, in the case of an order of assessment, confirm, reduce, enhance or\nannul the assessment

GANGUNAIDU SABBAVARAPU,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-2(5), VISAKHPATNAM

ITA 177/VIZ/2025[2023-24]Status: DisposedITAT Visakhapatnam27 Jun 2025AY 2023-24
Section 10(37)Section 139(1)Section 143(1)Section 2(37)Section 250Section 254Section 96

Court held as under :-\n\"5. In CIT v. Kanpur Coal Syndicate, a three Judge bench of this Court\ndiscussed the scope of Section 31(3)(a) of the Income Tax Act, 1922 which is\nalmost identical to Section 251(1)(a). The court held as under ... appeal lies, Section 31 of the Act describes the powers of the Appellate\nAssistant Commissioner in such an appeal. Under Section 31(3)(a) in\ndisposing of such an appeal the Appellate Assistant Commissioner may, in the\ncase of an order of assessment, confirm, reduce, enhance or annul the\nassessment

OCHHAB LAL JAIN,UDAIPUR vs. DCIT CENTRAL CIRCLE-1, UDAIPUR, UDAIPUR

In the result, both the appeals of the assessee are allowed

ITA 429/JODH/2025[2016-17]Status: DisposedITAT Jodhpur29 May 2025AY 2016-17
Section 132Section 132(1)Section 132(4)Section 139(1)Section 143(3)Section 153ASection 69A

nthis view is challenged in this appeal by the Commissioner of Income-tax, Bombay. The\nearliest case, which considered the meaning of section 31(3), was JagarnathTherani vs.\nCommissioner of Income-tax AIR 1925 Pat. 408 decided by the Patna High Court. In that\ncase, the assessee had three businesses ... other intention in express words. The Income-tax\nAct was amended several times in the last 37 years, but no amendment of section 31(3)\nwas undertaken to nullify the rulings, to which we have referred. In view of this, we do\nnot think that we should interpret section 31

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