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“Section 149(3)”

Section References (mined)Section 149Section 149(3)47 judgments

TIMES INTERNET LIMITED (REPRESENTATIVE ASSESSEE OF WILLOW TV INTERNATIONAL LTD),NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

Appeal is allowed

ITA 2239/DEL/2024[2016-17]Status: DisposedITAT Delhi21 Mar 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2016-17 M/S. Times Internet Ltd. Vs. Dcit, (Representative Assessee Of New Delhi Willow Tv International Ltd.), Express Building, 9-10 Bahadurshah Zafar Marg, New Delhi Pan: Aabct1559M (Appellant) (Respondent) Assessee By Sh. Ajay Vohra, Sr. Adv. Sh. Shaurya, Ca Sh. Deepesh Jain, Adv. Department By Sh. Vijay B. Basanta, Cit(Dr)

Section 147Section 148Section 148ASection 149Section 163Section 246

interpretations, one favourable to the asses-see has to be preferred to the one favouring the revenue. The change of language made in sections 149(3) and 163 of the 1961 Act as compared to the corresponding provisions in the 1922 Act is not without meaning and purpose ... provisions of sub-section (2) of section 163 of the 1961 Act. Without deciding this matter, no notice under section 148 read with section 149(3) of the 1961 Act can be issued." This decision of the Punjab and Haryana High Court came to be considered by the Madras High

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 50/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2016-17

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 49/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2009-10

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 48/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2008-09

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 47/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2007-08

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 46/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2006-07

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 45/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2005-06

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 44/AHD/2020[2004-05]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2004-05

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 43/AHD/2020[2002-03]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2002-03

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 42/AHD/2020[2001-02]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2001-02

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 41/AHD/2020[2000-01]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2000-01

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 40/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2016-17

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 39/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2009-10

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 38/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2008-09

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 37/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2007-08

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 36/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2006-07

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 35/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2005-06

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 34/AHD/2020[2004-05]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2004-05

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 33/AHD/2020[2002-03]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2002-03

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 32/AHD/2020[2001-02]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2001-02

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

Dutt's case (supra), there was no occasion for the Hon’ble Court to refer to, or take note of, the Explanation below Section 149(3), introduced with effect from 1st April 2012, which categorically made the amendment retrospective. The relevant part of the ITAT order regarding non-binding nature ... case of CIT v. Thana Electricity Co. Ltd. [1994] 206 ITR 727, and, more so in this case, particularly when Explanation below section 149(3), which did not come up for consideration before Their Lordships, has explicitly been relied upon by the learned Commissioner (Departmental Representative) before

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