THE PR.COMMISSIONER OF INCOME TAX vs. SRI KOUNDINYA EDUCATIONAL SOCIETY
ITTA/179/2019HC Andhra Pradesh29 Oct 2019
Bench: C.PRAVEEN KUMAR,CHEEKATI MANAVENDRANATH ROY
7. Estoppel by conduct does not of itself constitute an
independent cause of action. The assumed fact or state of
affairs (which one party is estopped from denying) may be
relied upon defensively or it may be used aggressively as the
factual foundation of an action arising under ordinary
principles with the entitlement to ultimate relief being
determined