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Sun Pharmaceuticals Industries Ltd. ( ... vs The Acit,Cent.Circle-1, Baroda on 8 April, 2021

Further the Madras High Court applied the principles as pronounced in the Peter Dixon case in Canara Industrial and Banking Syndicate Ltd. vs CIT 21 ITR 96 and held that premium payable would be interest where the loan does not provide for any interest. Further, interest is defined in section 2{2SA) of the Act and is reproduced as under:
Income Tax Appellate Tribunal - Ahmedabad Cites 121 - Cited by 61 - Full Document

Simplex Concrete Piles (India) Ltd. And ... vs Deputy Commissioner Of Income-Tax And ... on 2 April, 2003

25. On the other hand, Mr. Som has relied on a passage from Kanga and Palkhivala's the Law and Practice of Income Tax, Volume I, 8th edition, p. 1200, in order to interpret the meaning of the word "information". In the said passage, it was observed that: "The word 'information' does not necessarily imply factual material in contradistinction to the legal aspect of a case. 'Information' may be as to a fact (Niranjan and Co. (P.) Ltd. v. CIT [1986] 159 ITR 153 (SC) (revised return after completion of assessment) ; Mahabir Prasad Munna Lal v. CZT [1947] 15 ITR 393, 403 (All); Badar Shoe Stores, In re [1946] 14 ITR 431 (All); Ambalal Jivabhai Patel v. ITO [1964] 54 ITR 308 (Guj); West India Cotton Association Ltd. v. K.C. Rao, ITO [1966] 61 ITR 226 (Guj); CIT v. Narainji Manji Rathore [1967] 66 ITR 322 (Patna); Elphinstone Picture Palace v. Union of India [1969] 74 ITR 115 (Patna) and British Electrical and Pumps P. Ltd. v. ITO but the word also includes some cases of information as to the state of the law (Maharaj Kumar Kamal Singh v. CIT ; V.M. Raghavalu Naidu and Sons v. CIT [1945] 13 ITR 194 (Mad) ; CIT v. K.M.S. Lakshmana Iyer [1945] 13 ITR 242 (Mad) ; Canara Industrial and Banking Syndicate Ltd. v. CIT [1964] 51 ITR 479 (Mys) and Thakur Das Tej Prakash v. ITO , e.g., information that a case on a certain point of law has been decided by the court in a particular way Chatturam Horilram Ltd. v. CIT or that a case has been overruled (CIT v. Sir Mahomed Yusuf lsmail [1944] 12 ITR 8, 15 (Bom); Maharaj Kumar Kamal Singh v. CIT [1954] 26 ITR 79 (Patna); Mooljee Sicka and Co. v. Second Addl.
Calcutta High Court Cites 49 - Cited by 36 - D K Seth - Full Document

Vashist Bhargava vs Income-Tax Officer, Salary Circle on 10 December, 1974

In regard to the audit notes being "information" we are supported in our conclusion by all the other decisions of the High Courts placed before us, viz., Canara Industrial and Banking Syndicate Ltd., v. Commissioner of Income-Tax, (1964) 51 I.T.R. 479 (Mysore), per Hegde and Ahmed Ali Khan, JJ., Commisioner of Income-Tax v. Ketakutty, (1972) 85 I.T.R. 102 (Kerala) per Mathew and Krishnamoorthy lyer, JJ., Muthukrishna Reddiar v. Commissioner of Income-Tax, (1973)90 I.T.R. 503 (Kerala) per Govindan Nair and Sadasivan, Jj, and Commissioner of Income-Tax v. H. H. Smt. Chand Kanwarji, (1972) 84 I.T.R. 584, per Hardayal Hardy and M.R.A. Ansari, JJ. of this Court .
Delhi High Court Cites 33 - Cited by 23 - Full Document

Delhi Glass Works P. Ltd. vs Commissioner Of Income-Tax on 16 November, 1970

In Canara Industrial and Banking Syndicate v. Commissioner of Income-tax, [1964] 51 I.T.R. 479 (Mys.), the Mysore High Court held that if income had escaped assessment owing to the failure of the Income-tax Officer to understand the true implication of a notification, and the Income-tax Officer later on finds that on a correct interpretation of the notification the income was liable to be assessed, he can take proceedings under Section 34 for assessment of such income; the word "information" in Section 34 was wide enough to apply to such a case.
Delhi High Court Cites 21 - Cited by 3 - Full Document

Commissioner Of Income-Tax, Bombay ... vs H. Holck Larsen on 12 August, 1971

39. On the other side of the line are the decisions of the Madras High Court in Salem provident Fund Society Ltd. v. Commissioner of Income-tax and Commissioner of Income-tax v. Rathinasabapathy Mudaliar, the decision of the Mysore High Court in Canara Industrial and Banking Syndicate Ltd. v. Commissioner of Income-tax and of the Kerala High Court in United Mercantile Co. Ltd. v. Commissioner of Income-tax. Broadly, these cases have taken the view that if an Income-tax officer discovers an error committed by him in the original assessment proceedings, what is seen by him would be information to himself and such information would fall within section 34 (1) (b).
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