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Documents citing Gupta Traders vs Commissioner Of Income-Tax on 15 December, 1981

Shanti Vijay & Co. & Ors. vs Income Tax Officer on 30 January, 1997

10.2 In the case of Gupta Traders (supra), the Hon'ble Allahabad High Court have taken similar view when it held that "Expln. 3 to sub-s. (3)(of s. 153) embraces within its scope persons other than the assessee as well, but lays down the condition that such third party should be given an opportunity of being heard before the order depriving him of the right of pleading limitation is passed."
Income Tax Appellate Tribunal - Delhi Cites 30 - Cited by 0 - Full Document

Deputy Commissioner Of Income Tax vs Indian Syntans Investments (P) Ltd. on 30 June, 2006

A direction or finding as contemplated by Section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee and in relevance to a particular assessment year. To be a necessary finding it must be directly involved in the disposal of the case. To be a direction as contemplated by Section 153(3) it must be an express direction necessary for the disposal of the case before the authority or Court vide Rajinder Nath v. CIT ; Gupta Traders v. CIT (; CIT v. Tarajan Tea Co. (P) Ltd. and CIT v. Goel Brothers , etc. The case of an expatriate employee was to be decided on the basis of the provisions of Article XIV of the treaty, whereas corporate income was to be decided on the basis of either Article III or Article XVI of the treaty or Section 44BB of the Act.
Income Tax Appellate Tribunal - Chennai Cites 82 - Cited by 2 - Full Document

Foramer vs Commissioner Of Income-Tax And Anr. on 17 August, 2000

20. A direction or finding as contemplated by Section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee and in relevance to a particular assessment year. To be a necessary finding it must be directly involved in the disposal of the case. To be a direction as contemplated by Section 153(3)(ii) it must be an express direction necessary for the disposal of the case before the authority or court vide Rajinder Nath v. CIT [1979] 120 ITR 14 (SC); Gupta Traders v. CIT [1982] 135 ITR 504 (All); CIT v. Tarajan Tea Co. (P.)
Allahabad High Court Cites 22 - Cited by 32 - M Katju - Full Document

Atul Traders vs Income Tax Officer on 14 July, 2005

9. There is no dispute over the ratio laid down in the aforesaid decisions of this Court. We also do not propose to hold that M/s Atul Traders and M/s Atul Industrial Corporation are one entity/juristic person. No such submission has either been raised on behalf of the respondents. The contention of the respondent on this point is that M/s Atul Traders was not required to be given separate notice for affording opportunity of hearing under Section 153(3), Expln. 3, as that would have been a mere empty formality.
Allahabad High Court Cites 11 - Cited by 18 - A K Yog - Full Document

Shanti Vijay & Co. & Ors. vs Income Tax Officer. on 30 January, 1997

10.2 In the case of Gupta Traders (supra), the Honble Allahabad High Court have taken similar view when it held that "Expln. 3 to sub-s. (3)(of s. 153) embraces within its scope persons other than the assessee as well, but lays down the condition that such third party should be given an opportunity of being heard before the order depriving him of the right of pleading limitation is passed."
Delhi High Court Cites 30 - Cited by 0 - Full Document

Munshi Mini Rice Mill, Hooghly vs Assessee on 14 October, 2014

A direction or finding as contemplated by section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee and in relevance to a particular assess- ment year. To be a necessary finding it must be directly involved in the disposal of the case. To be a direction as contemplated by section 153(3)(ii) it must be an express direction necessary for the disposal of the case before the authority or court vide Rajinder Nath v. CIT [1979] 120 ITR 14 (SC) ; Gupta Traders v. CIT [1982] 135 ITR 504 (All) ; CIT v. Tarajan Tea Co. (P.)
Income Tax Appellate Tribunal - Kolkata Cites 28 - Cited by 0 - Full Document

Bengal Export Corporation, Kolkata vs Assessee on 22 October, 2014

A direction or finding as contemplated by section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee and in relevance to a particular assess- ment year. To be a necessary finding it must be directly involved in the disposal of the case. To be a direction as contemplated by section 153(3)(ii) it must be an express direction necessary for the disposal of the case before the authority or court vide Rajinder Nath v. CIT [1979] 120 ITR 14 (SC) ; Gupta Traders v. CIT [1982] 135 ITR 504 (All) ; CIT v. Tarajan Tea Co. (P.)
Income Tax Appellate Tribunal - Kolkata Cites 28 - Cited by 0 - Full Document
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