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“Section 144(8)”

Section References (mined)Section 144Section 144(8)8 judgments

The decision most relied on for Section 144(8) is Hindustan Aluminium Corporation Ltd. v. CIT (144 ITR 474), cited in 119 judgments on BharatTax.

Leading authorities on Section 144(8)

Hindustan Aluminium Corporation Ltd. v. CIT

144 ITR 474 · 1983 · High Court

citing judgments

The Calcutta High Court held that a lump sum revenue expenditure, which is of a significant amount and provides benefits spread over several years, can be allowed as a deduction proportionately over the period of benefit. This approach prevents distortion of the profits of a single assessment year.

CIT v. M. M.Khambatbala

198 ITR 144 · 1992 · High Court

citing judgments

Revisional powers under Section 263 can be exercised even if the issue is debatable, provided the order is erroneous and prejudicial to the revenue's interest.

Labhchand Bohra v. ITO

8 DTR 44 · 2008 · High Court

citing judgments

An assessee is not required to establish the capacity of a lender to advance money, as this would amount to proving the 'source of source' of a cash credit, which is beyond the assessee's burden.

Judgments citing Section 144(8)

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT

Section 139Section 143(3)Section 147

been stated in assessment order that "the case was transferred on 23.1.2024 from Faceless to JAO under the provision of section 144(8) of the Act.” However, the fact is that, initial notice for reopening of assessment u/s 148 itself was issued by JAO and not by FAO. Moreover, even

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 819/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jul 2025AY 2018-19

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT

Section 139Section 143(3)Section 147

been stated in assessment order that "the case was transferred on 23.1.2024 from Faceless to JAO under the provision of section 144(8) of the Act.” However, the fact is that, initial notice for reopening of assessment u/s 148 itself was issued by JAO and not by FAO. Moreover, even

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 818/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jul 2025AY 2017-18

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT

Section 139Section 143(3)Section 147

been stated in assessment order that "the case was transferred on 23.1.2024 from Faceless to JAO under the provision of section 144(8) of the Act.” However, the fact is that, initial notice for reopening of assessment u/s 148 itself was issued by JAO and not by FAO. Moreover, even

Ravinder Singh Thakkar, Jaipur vs. Assistant Commssioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 817/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Jul 2025AY 2016-17

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT

Section 139Section 143(3)Section 147

been stated in assessment order that "the case was transferred on 23.1.2024 from Faceless to JAO under the provision of section 144(8) of the Act.” However, the fact is that, initial notice for reopening of assessment u/s 148 itself was issued by JAO and not by FAO. Moreover, even

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 816/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT

Section 139Section 143(3)Section 147

been stated in assessment order that "the case was transferred on 23.1.2024 from Faceless to JAO under the provision of section 144(8) of the Act.” However, the fact is that, initial notice for reopening of assessment u/s 148 itself was issued by JAO and not by FAO. Moreover, even

Hindustan Construction Company Limited, Mumbai vs. Principle Commissioner of Income Tax, Mumbai.

In the result, the appeal of the assessee is allowed

ITA 1043/MUM/2024[2017-18]Status: DisposedITAT Mumbai21 Oct 2024AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Gagan Goyalhindustan Construction Company Ltd., Hincon House, Lbs Marg, Vikhroli (W), Mumbai, Maharashtra – 400 083. Pan No.: Aaach0968B ..... Appellant Vs. Pcit, Mumbai-6, R. No. 501, 5Th Floor, Aayakar Bhavan, M.K. Road, Mumbai - 400 020. ..... Respondent

For Appellant: Shri Kalpesh Unadkat, Ld. ARFor Respondent: Shri K. C. Selvamani, Ld. DR

Section 143(3)Section 263Section 90Section 92C

144C (5) of the Act. In addition to this it is pertinent to mention here that as per section 144(8) of the Act, the Dispute Resolution Panel may confirm, reduce or enhance the variations proposed in the draft order so, however, that it shall not set aside any proposed

Gaurav Dugar, Chennai vs. PCIT-8, Chennai

ITA 948/CHNY/2024[2014-15]Status: DisposedITAT Chennai30 Aug 2024AY 2014-15

Bench: Shri Mahavir Singh & Shri S.R. Raghunatha

For Appellant: Shri S.Sridhar, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar, CIT

Section 143(3)Section 147Section 147wSection 148Section 263Section 43CSection 52(2)(vii)Section 56(2)(vii)

आयकर अपील"य अ"धकरण,‘सी’"याय पीठ,चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ीमहावीर

Guala Closures (India) Pvt. Ltd., Panaji vs. The Principal Commissioner of Income Tax, Panaji., Select City

Appeal is dismissed in above terms

ITA 205/PAN/2019[2012-13]Status: DisposedITAT Panaji13 Oct 2023AY 2012-13

Bench: Shri Satbeer Singh Godara & Dr. Dipak Ripote

For Appellant: Shri Ketan VedFor Respondent: Shri P.S. Shivshankar, CIT-DR

Section 143(3)Section 144(3)Section 144CSection 253Section 263Section 4

IN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH : PANAJI (THROUGH VIRTUAL HEARING AT ITAT : PUNE BENCHES : PUNE) BEFORE SHRI SATBEER