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“Kelvinator”

Judicial DoctrinesKelvinator - 147Kelvinator - 147924 judgments

The decision most relied on for Kelvinator is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on Kelvinator

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

CIT v. Kelvinator of India Ltd.
256 ITR 1 · 2002 · High Court
439
citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

CIT v. Usha International Ltd.
348 ITR 485 · 2012 · High Court
231
citing judgments

A reassessment is invalid due to 'mere change of opinion' if an issue was raised during original assessment but no addition was made, implying the issue was examined. However, if a subject matter was not examined and no opinion was formed, the principle of 'change of opinion' does not apply.

New Delhi Television Ltd. v. DCIT
116 Taxmann.com 151 · 2020 · Supreme Court
139
citing judgments

Reassessment initiated under Section 147/148 is invalid if the Assessing Officer relies on material obtained post-recording of reasons, or if it amounts to a mere change of opinion on facts fully and truly disclosed by the assessee during the original assessment. An assessee's obligation extends only to the full and true disclosure of primary facts, not to provide further assistance or inferences.

Idea Cellular Ltd. v. Dy. CIT
301 ITR 407 · 2008 · High Court
107
citing judgments

The Assessing Officer is considered to have applied their mind and formed an opinion on an issue if the assessee fully disclosed all material facts and responded to queries during the original assessment, even without explicit discussion in the assessment order. Reopening an assessment beyond four years on such an issue without new tangible material constitutes a mere change of opinion and is impermissible under Section 147.

Principal Commissioner of Income-tax-5 v. Shodiman Investments (P.) Ltd.
422 ITR 337 · 2020 · High Court
84
citing judgments

Reassessment cannot be initiated on "borrowed satisfaction"; the Assessing Officer must independently apply their mind to tangible material to form a reasonable belief that income has escaped assessment. The sanctioning authority under Section 151 must also apply its mind to the recorded reasons before granting approval.

KLM Royal Dutch Airlines v. Additional Director of Income Tax
292 ITR 49 · 2007 · High Court
78
citing judgments

Reassessment proceedings under Section 147 cannot be initiated based on a mere change of opinion or reappraisal of existing facts, but require new or fresh tangible material or information indicating escapement of income.

Judgments citing Kelvinator

DCIT-Circle-3(3) (1), Mumbai vs. S D Corporation Private Limited, Mumbai

In the result, the appeal of the revenue vide ITA Nos

ITA 6193/MUM/2019[2013-14]Status: DisposedITAT Mumbai30 Aug 2023AY 2013-14

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos.6191 To 6194, 6204 & 6033 /Mum/2019 (A.Ys. 2008-09, 2009-10, 2011-12 To 2014-15)

For Appellant: Mahita NairFor Respondent: Dharmesh Shah &
Section 115JSection 143(3)Section 147

periods of four years. Hence, in view of the judgment of the Hon'ble Supreme Court in Court in the case of CIT v. Kelvinator of India Ltd. [2010] 320 1TR 561 (SC), I am acting within jurisdiction while reopening the assessment on the basis of "tangible material

DCIT-Circle-3(3)(1), Mumbai vs. S D Corporation Private Limited, Mumbai

In the result, the appeal of the revenue vide ITA Nos

ITA 6192/MUM/2019[2011-12]Status: DisposedITAT Mumbai30 Aug 2023AY 2011-12

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos.6191 To 6194, 6204 & 6033 /Mum/2019 (A.Ys. 2008-09, 2009-10, 2011-12 To 2014-15)

For Appellant: Mahita NairFor Respondent: Dharmesh Shah &
Section 115JSection 143(3)Section 147

periods of four years. Hence, in view of the judgment of the Hon'ble Supreme Court in Court in the case of CIT v. Kelvinator of India Ltd. [2010] 320 1TR 561 (SC), I am acting within jurisdiction while reopening the assessment on the basis of "tangible material

DCIT-Circle-3(3) (1), Mumbai vs. S D Corporation Private Ltd, Mumbai

In the result, the appeal of the revenue vide ITA Nos

ITA 6191/MUM/2019[2014-15]Status: DisposedITAT Mumbai30 Aug 2023AY 2014-15

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos.6191 To 6194, 6204 & 6033 /Mum/2019 (A.Ys. 2008-09, 2009-10, 2011-12 To 2014-15)

For Appellant: Mahita NairFor Respondent: Dharmesh Shah &
Section 115JSection 143(3)Section 147

periods of four years. Hence, in view of the judgment of the Hon'ble Supreme Court in Court in the case of CIT v. Kelvinator of India Ltd. [2010] 320 1TR 561 (SC), I am acting within jurisdiction while reopening the assessment on the basis of "tangible material

DCIT Circle 3(3)(1), Mumbai vs. S D Corporation Private Limited, Mumbai

In the result, the appeal of the revenue vide ITA Nos

ITA 6033/MUM/2019[2008-09]Status: DisposedITAT Mumbai30 Aug 2023AY 2008-09

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos.6191 To 6194, 6204 & 6033 /Mum/2019 (A.Ys. 2008-09, 2009-10, 2011-12 To 2014-15)

For Appellant: Mahita NairFor Respondent: Dharmesh Shah &
Section 115JSection 143(3)Section 147

periods of four years. Hence, in view of the judgment of the Hon'ble Supreme Court in Court in the case of CIT v. Kelvinator of India Ltd. [2010] 320 1TR 561 (SC), I am acting within jurisdiction while reopening the assessment on the basis of "tangible material

Shri Vijay Tondon, Raipur vs. Income Tax Officer, Ward-3(1), Raipur

In the result, the assessee's appeal is allowed in terms of our observations above

ITA 93/RPR/2022[2013-14]Status: DisposedITAT Raipur24 Aug 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 93/Rpr/2022 "नधा"रण वष" / Assessment Year : 2013-14 Shri Vijay Tondon, H.No.34, Sector-1, Shankar Nagar Road, Gitanjali Nagar, Raipur-492 001 (C.G.) Pan : Abupt1550H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Sakshi Gopal Agrawal, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 144Section 147Section 148Section 54

view above is fortified by the landmark judgment of the Hon’ble Supreme Court in the case of CIT, Delhi Vs. Kelvinator of India Ltd. (2010) 320 ITR 561 (SC). We, thus, in terms of our observations above vacate the assessment framed by the A.O u/s 144 r.w.s

Showtime Events India Pvt. Ltd., New Delhi vs. DCIT, Circle- 23(1), New Delhi

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

ITA 4239/DEL/2017[2008-09]Status: DisposedITAT Delhi22 Aug 2023AY 2008-09

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Shri Raghvendra Singh, AdvFor Respondent: Shri Anuj Garg, Sr. DR
Section 143(3)Section 147Section 148Section 154

there was no new tangible material evidence and, therefore, the ratio laid down by the Hon'ble Supreme Court in the case of Kelvinator of India Limited 320 ITR 561 squarely apply. 16. We find that while dismissing the challenge of the assessee, the ld. CIT(A) has followed ... Royal Dutch Airlines 292 ITR 49. The relevant part reads as under: “The Full Bench of this Court in Commissioner of Income-Tax v. Kelvinator of India Ltd. [2002] 256 ITR 1 had opined that the amendments introduced into Section 147 with effect from 1.4.1989 have not altered the position

M/S. Scicom Technologies Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is allowed

ITA 6075/DEL/2013[2007-08]Status: DisposedITAT Delhi11 Aug 2023AY 2007-08

Bench: Sh. N. K. Billaiya & Sh. Yogesh Kumar Usassessment Year: 2007-08 Scicom Technologies Pvt. Dcit Ltd. (Not Known As Wipro Vs Circle – 7 (1) Energy It Services India P. New Delhi Ltd.)32-33, M-2, 1St Floor, Kaushal Bazar, Nehru Place, New Delhi Pan No.Aaaci6192A (Appellant) (Respondent)

Section 143Section 148

what was already there in his records. This is against the ratio laid down by the Hon’ble Supreme Court in the case of Kelvinator of India Limited 320 ITR 561. As no new tangible material has been brought on record the reopening can only be just a change

Mirnal Mehta, Cuttack vs. ITO Wrd-2(4), Cuttack

In the result, appeal of the assessee is allowed

ITA 169/CTK/2023[2017-18]Status: HeardITAT Cuttack09 Aug 2023AY 2017-18
For Appellant: Shri Mohit Sheth, AdvocateFor Respondent: Shri S.C.Mohanty, Sr. DR
Section 143(3)Section 147Section 148

opinion and the same is liable to be cancelled in view of the decision of the Hon‟ble Supreme Court in the case of Kelvinator of India Ltd., reported in [2010] 320 ITR 561 (SC), wherein the Hon‟ble Supreme Court has categorically held that the Assessing Officer ... bank account, which called for any addition. 11 14. A perusal of the decision of the Hon‟ble Supreme Court in the case of Kelvinator of India Ltd., referred by the ld.AR, shows that there must be „tangible material‟ to come to conclusion that there is escapement of income from

Ultratech Cement Limited, Mumbai vs. ACIT- CC -1(4), Mumbai

ITA 221/MUM/2022[2012-13]Status: DisposedITAT Mumbai03 Aug 2023AY 2012-13

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2012-13

For Appellant: Shri. Nitesh Joshi, A.R. &For Respondent: Shri. Alok Kumar, CIT DR
Section 132Section 143(3)Section 153CSection 35D

permissible under the garb of reopening under section 147/148 of the Act. Honourable Supreme Court of India in case of CIT vs Kelvinator of India Ltd (2010) 320 ITR 561 (SC) held that there is a difference between power to review and power to re-assess under section

Chhattisgarh State Beverage Corporation Ltd., Raipur vs. Deputy Commissioner of Income Tax, Circle-3(1), Raipur

In the result, appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 198/RPR/2022[2013-14]Status: DisposedITAT Raipur03 Aug 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 198/Rpr/2022 "नधा"रण वष" / Assessment Year : 2013-14 Chhattisgarh State Beverages Corporation Limited Aabkari Bhavan, Chokra Nala, Labhandi, Raipur-492 001 (C.G.) Pan : Aaccc3163B .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-3(1), Raipur. ……""यथ" / Respondent

For Appellant: Shri Praveen Jain, CAFor Respondent: Dr. Simran Bhullar, CIT-DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 37

support of his aforesaid contention had relied on the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Kelvinator of India Ltd. (2010) 320 ITR 561 (SC) a/w host of other judicial pronouncements. 10. Per contra, the Ld. Departmental Representative (for short ‘DR’) relied

Nagpur Power & Industries Ltd, Mumbai vs. A.C.I.T.-3(2)(2), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 505/MUM/2023[2009-2010]Status: DisposedITAT Mumbai01 Aug 2023AY 2009-2010

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Blem/S. Nagpur Power & Industries Ltd V. Acit – 3(2)(2) 20Th Floor, Nirmal Aayakar Bhavan, M.K. Road Nariman Point, Mumbai – 400021 Mumbai - 400020 Pan: Aaacn5438N (Appellant) (Respondent) Assessee Represented By : Shri Surinder Mehra Department Represented By : Dr. Mahesh Akhade & Shri Chetan Kacha

Section 143(1)Section 143(2)Section 143(3)Section 148Section 14ASection 37(1)

Land Developers Pvt. Ltd. VITO 450 ITR 108 (Bom) 7) Manan Trading Co. Pvt. Ltd. Vs. DCIT 449 ITR 587 (Bom) 8) CIT Vs. Kelvinator of India Ltd. reported in 320 ITR 561 (SC) 9) Garden Silk Mills Ltd. vs. DCIT 222 ITR 27, 29, 30 (Gujarat

Forever Flourishing Fin. & Inv. Pvt. Ltd., Mumbai vs. DCIT (CC)-3(4), Mumbai

In the result, appeal for the assessment year 2012

ITA 6120/MUM/2019[2013-14]Status: DisposedITAT Mumbai31 Jul 2023AY 2013-14

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Ashok Bansal/Ajay DagaFor Respondent: Mr. Ankush Kapoor, CIT-DR
Section 143(2)Section 147

permissible in law as held by the Apex Court in the in law as held by the Apex Court in the case of Kelvinator of India Ltd. case of Kelvinator of India Ltd. 1.iii. Further, in any event, the CIT (A) erred in holding that Further, in any event ... support of contention, relied on the The Ld. Counsel in support of contention decision of the Hon’ble Supreme Court in the case of Kelvinator of decision of the Hon’ble Supreme Court in the case of Kelvinator of decision of the Hon’ble Supreme Court in the case

Forever Flourishing Fin & Inv. Pvt Ltd, Mumbai vs. DCIT-CC-3(4), Mumbai

In the result, appeal for the assessment year 2012

ITA 6040/MUM/2019[2012-13]Status: DisposedITAT Mumbai31 Jul 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Ashok Bansal/Ajay DagaFor Respondent: Mr. Ankush Kapoor, CIT-DR
Section 143(2)Section 147

permissible in law as held by the Apex Court in the in law as held by the Apex Court in the case of Kelvinator of India Ltd. case of Kelvinator of India Ltd. 1.iii. Further, in any event, the CIT (A) erred in holding that Further, in any event ... support of contention, relied on the The Ld. Counsel in support of contention decision of the Hon’ble Supreme Court in the case of Kelvinator of decision of the Hon’ble Supreme Court in the case of Kelvinator of decision of the Hon’ble Supreme Court in the case

Omega Finhold Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 14, New Delhi

In the result, the appeal filed by the assessee is allowed

ITA 1286/DEL/2018[2010-11]Status: DisposedITAT Delhi27 Jul 2023AY 2010-11
Section 115JSection 147Section 148

material. The existence of tangible and relevant material is a precondition for assuming jurisdiction, as has been held in the case of CIT vs. Kelvinator of India Ltd. reported in 320 ITR 561 (SC) and ACIT vs. Rajesh Jhaveri Stock Brokers (P) Ltd. reported in 291 ITR 500 (SC). Hence

Shri Murlimanohar Ramkishan Mundhra, Surat vs. Income Tax Officer, Ward - 1(2)(1), Surat

In the result, ground No. 1 of the appeal is allowed

ITA 158/SRT/2023[2013-14]Status: DisposedITAT Surat18 Jul 2023AY 2013-14

Bench: Shri Pawan Singhआ.अ.सं./Ita No.158/Srt/2023 (Ay 2013-14) (Hearing In Physical Court) Murlimanohar Ramkishan Income Tax Officer, Ward-1(2)(1), (Old Ward- Mundhra, 301 To 308, Vs 1(2)(3) Surat, Aayakar Third Floor, Shree Krishna Market, Near Metro Tower, Bhavan, Majura Gate, Ring Road, Surat-395002 Surat-395001 Pan No: Aflpm 6057 P अपीलाथ"/Appellant ""यथ" /Respondent "नधा"रती क" ओर से /Assessee By Shri Sudhir Surana, Ca & Shri Om Prakash Soni, Ca राज"व क" ओर से /Revenue By Shri Vinod Kumar, Sr-Dr अपील पंजीकरण/Appeal Instituted On 03.03.2023 सुनवाई की तारीख/Date Of Hearing 03.05.2023 उ"घोषणा क" तार"ख/Date Of 18.07.2023 Pronouncement Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of National Faceless Appeal Centre, Delhi [For Short To As “Ld. Nfac/Ld.Cit(A)”] Dated 13.01.2023 For Assessment Year 2013-14, Which In Turn Arises From The Addition Made By The Assessing Officer In Assessment Order Passed Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 30.11.2018. The Assessee Has Raised The Following Ground Of Appeal:- Murllimanohar R Mundhra “1. Ld. Cit(A) Erred In Law & On Facts Confirming The Reassessment Proceeding Initiated By The Ld. Ao, Without Properly Appreciating The Submission Of The Appellant.

Section 143(2)Section 143(3)Section 147Section 148Section 254(1)Section 57

opinion is removed then in the grab of re-opening assessment, review would take place as has been held in CIT, Delhi vs. Kelvinator of India Ltd. (2010) 320 ITR 561 (SC). On the merit of addition, the Ld. AR for the assessee retreated that assessee has claimed interest expense

Icici Bank Limited, Mumbai vs. The Dy. Commissioner of Income-Tax 2(3)(1), Mumbai

In the result both appeals of the assessee and revenue are dismissed

ITA 158/MUM/2023[2001-02]Status: DisposedITAT Mumbai30 Jun 2023AY 2001-02

Bench: Shri Amit Shukla & Shri Amarjit Singhdcit Cir 3(1) Vs. Icici Bank Ltd. Room No. 607, 6 Th Floor, Icici Towers, Bkc, Aayakar Bhavan, Bandra(E) Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaact1398K Appellant .. Respondent Icici Bank Ltd. Vs. Dcit Cir. 2(3)(1) Icici Towers, North East Room No. 552, 5Th Floor, Wing, Ground Floor, Aayakar Bhavan, M.K. Bkc, Bandra(E) Road, Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaact1398K Appellant .. Respondent Appellant By : Ms. Aarti Visanji, Ar Respondent By : Shri. K.C. Selvamani, Dr Date Of Hearing 01.06.2023 Date Of Pronouncement .06.2023 आदेश / O R D E R Per Amarjit Singh (Am)

For Appellant: Ms. Aarti Visanji, ARFor Respondent: Shri. K.C. Selvamani, DR
Section 10Section 115JSection 143(3)Section 148Section 154Section 33Section 47

initiate reassessment proceedings upon a mere change of opinion as has been held by the Supreme Court in the case of CIT v. Kelvinator of India Ltd. (320 ITR 561) P a g e | 12 ICICI BANK LTD V/S DCIT 2(3)(1) ICICI BANK LTD V/S DCIT

The DCIT Cir 3(1), Mumbai vs. M/S. Icici Bank Ltd, Mumbai

In the result both appeals of the assessee and revenue are dismissed

ITA 5765/MUM/2008[2001-2002]Status: DisposedITAT Mumbai30 Jun 2023AY 2001-2002

Bench: Shri Amit Shukla & Shri Amarjit Singhdcit Cir 3(1) Vs. Icici Bank Ltd. Room No. 607, 6 Th Floor, Icici Towers, Bkc, Aayakar Bhavan, Bandra(E) Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaact1398K Appellant .. Respondent Icici Bank Ltd. Vs. Dcit Cir. 2(3)(1) Icici Towers, North East Room No. 552, 5Th Floor, Wing, Ground Floor, Aayakar Bhavan, M.K. Bkc, Bandra(E) Road, Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaact1398K Appellant .. Respondent Appellant By : Ms. Aarti Visanji, Ar Respondent By : Shri. K.C. Selvamani, Dr Date Of Hearing 01.06.2023 Date Of Pronouncement .06.2023 आदेश / O R D E R Per Amarjit Singh (Am)

For Appellant: Ms. Aarti Visanji, ARFor Respondent: Shri. K.C. Selvamani, DR
Section 10Section 115JSection 143(3)Section 148Section 154Section 33Section 47

initiate reassessment proceedings upon a mere change of opinion as has been held by the Supreme Court in the case of CIT v. Kelvinator of India Ltd. (320 ITR 561) P a g e | 12 ICICI BANK LTD V/S DCIT 2(3)(1) ICICI BANK LTD V/S DCIT

Puri Oil Mills Ltd, New Delhi vs. ACIT, Circle-20(1), New Delhi

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

ITA 7726/DEL/2019[2013-14]Status: DisposedITAT Delhi30 Jun 2023AY 2013-14

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 143(3)Section 2(24)Section 44A

knowledge of the A.O. Therefore, the reopening of - assessment was invalid." 19. Further, the Hon'ble Supreme Court in the case of CIT Vs. Kelvinator of India Ltd. (2010) 320 ITR 561 S.C, while deciding the question whether the concept of “change of opinion” stands obliterated with effect from ... decided on 18th January, 2010 which approves this Court‟s Full Bench decision in the case of Commissioner of Income Tax vs. Kelvinator of India Limited:256 ITR 1 (Del.) (HC). The power of re-assessment is different from the power of review. The Assessing Officer has been given

Puri Oil Mills Ltd., New Delhi vs. ACIT, Circle- 20(1), New Delhi

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

ITA 6971/DEL/2018[2012-13]Status: DisposedITAT Delhi30 Jun 2023AY 2012-13

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 143(3)Section 2(24)Section 44A

knowledge of the A.O. Therefore, the reopening of - assessment was invalid." 19. Further, the Hon'ble Supreme Court in the case of CIT Vs. Kelvinator of India Ltd. (2010) 320 ITR 561 S.C, while deciding the question whether the concept of “change of opinion” stands obliterated with effect from ... decided on 18th January, 2010 which approves this Court‟s Full Bench decision in the case of Commissioner of Income Tax vs. Kelvinator of India Limited:256 ITR 1 (Del.) (HC). The power of re-assessment is different from the power of review. The Assessing Officer has been given

Dinesh Agarwal, Jaipur vs. DCIT Cir-6, Jaipur

ITA 17/JPR/2022[2008-09]Status: DisposedITAT Jaipur30 Jun 2023AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta (C.A.)For Respondent: Mrs Monisha Choudhary (Addl.CIT)
Section 147Section 148Section 50C

tangible material. (1) M.J. Pharmaceuticals Ltd."v. Deputy Commissioner of Income-tax, Central Circle 32, Mumbai (2008) 167 Txmann 136 (Mumbai) (2)CIT v. Kelvinator of India Ltd. [2010] 187 Taxman 312 (SC) (3) Saurabh Natvarlal Soparkar v. Assistant Commissioner of Income-tax, Circle 4(2) (2021) 131 taxmann.com