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M/S Quasar Developers Pvt. Ltd., 202, ... vs Ito, Ward-6(2), Jaipur on 8 February, 2023

Further the Full Bench of Patna High Court in case of Loknath Goenka Vs. CIT (2019) 417 ITR 521/266 Taxman 199 with reference to insertion of section 64(1)(iii) w.e.f. 01.04.1976 held that the tax liability under the said provision could be charged on the assessee in the assessment which was to be made for that accounting year i.e. 1976-77 which would be done in A.Y. 1977-78 as the amending act introducing a new tax liability which came into force w.e.f. 01.04.1976 could not be given a retrospective effect and be made applicable to assessment year 1976-77. The relevant part of the judgment reads as under:-
Income Tax Appellate Tribunal - Jaipur Cites 17 - Cited by 0 - Full Document

Silver Wings Life Spaces, Kota vs Dcit Circle-1 Kota, Kota on 31 July, 2024

The principal is also applicable in the present case . Full Bench of Hon'ble Patna High Court in case of Loknath Goenka v. CIT (2019) 417 ITR 521 with reference to insertion of section 64(1)(iii) w.e.f. 01.04.1976 held that the tax liability under the said provision could be charged on the assessee in the assessment in the assessment which was to be made for that accounting year i.e. 1976-77 which would be done in A.Y. 1977-78 as the amending act introducing a new tax liability which came into force w.e.f.
Income Tax Appellate Tribunal - Jaipur Cites 88 - Cited by 0 - Full Document

Jagdish Kumar Arora,Bhawanimandi vs Dcit, Central Circle- Kota, Kota on 11 February, 2025

The principal is also applicable in the present case 44 ITA No. 1195/JP/2024 Jagdish Kumar Arora . Full Bench of Hon'ble Patna High Court in case of Loknath Goenka v. CIT (2019) 417 ITR 521 with reference to insertion of section 64(1)(iii) w.e.f. 01.04.1976 held that the tax liability under the said provision could be charged on the assessee in the assessment in the assessment which was to be made for that accounting year i.e. 1976-77 which would be done in A.Y. 1977-78 as the amending act introducing a new tax liability which came into force w.e.f. 01.04.1976 could not be given a retrospective effect and be made applicable to assessment year 1976-77. The relevant part of the judgment reads as under:
Income Tax Appellate Tribunal - Jaipur Cites 105 - Cited by 0 - Full Document

Income Tax Officer Ward 29(1), New Delhi vs Sahil Jain, New Delhi on 12 November, 2025

1. 417 ITR 521 (Patna) Loknath Goenka Vs CIT In view of the judgments of the Apex Court in the case of Kesoram Industries and Cotton Mills Ltd. (supra) as well as Karimtharuvi Tea Estate Ltd. (supra) this Court would have no hesitation in holding that for deciding the liability of a particular provision of the Income Tax Act, the date of accrual of income would be relevant. If the provision comes into force in a particular financial year, it would apply to the assessment for that year but cannot be made applicable in respect of assessment for a previous year.
Income Tax Appellate Tribunal - Delhi Cites 31 - Cited by 0 - Full Document
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