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Documents citing A2Z Infra Engineering Limited, Gurgaon vs Ccit- Central Circle-2, Faridabad on 28 March, 2023

Om Infra Limited, Jaipur Rajasthan vs Dcit, Central Circle-1, Jaipur, ... on 31 July, 2024

Om Infra Limited vs. DCIT, Central Circle-01, Jaipur The appellant has not shown how the issue is debatable. The appellant has taken various legal grounds and has submitted judgments on the issue that rectification cannot be done on an issue which is debatable and having more than one bonafide opinions however the submission of the appellant is only legal in nature and the appellant has not been able to show how those judgments and the legal principles are applicable to the present facts of the case. The appellant has not submitted any judgments which support the view of the appellant on the facts of the case. There is no dispute that in case there are two bonafide opinions and there are judgments which are Sontradictory on an issue such an issue cannot be rectified under section 154. However in the present case appellant has not cited any such bonafide explanation or judgment in its support in view of the discussion, this ground of Appeal is dismissed.
Income Tax Appellate Tribunal - Jaipur Cites 51 - Cited by 0 - Full Document

Manmegh Singh Kanwar,Uttar Pradesh vs Ito,Ward-73(1), Delhi on 28 November, 2025

7. We find that the coordinate Bench of the Delhi Tribunal in the case of A2Z Infra Services Limited Vs. DCIT had held that while processing the return u/s. 143(1) prior to the decision of the Hon'ble Supreme Court there were binding decisions of jurisdictional High Court and, therefore, the AO / CPC could not have disallowed the employee's contribution to PF/ESI while passing intimation u/s. 143(1) of the Act and while holding so the coordinate Bench followed the decision of the Hon'ble Chattisgarh High Court in the case of Raj Kumar Bothra Vs. DCIT (476 ITR 249). The relevant observations of the Tribunal as under :-
Income Tax Appellate Tribunal - Delhi Cites 18 - Cited by 0 - Full Document

M/S. Bharat Beedi Works Private ... vs Deputy Commisioner Of Income Tax, ... on 21 April, 2025

Cases Rebuttals At para 11 of the decision, it was held that "Once this is so the revised returns filed by the assessee for both the Kumar Jagdish said assessment years were not valid in law and Chandra Sinha could not have been treated and acted upon as V. CIT [1996] 86 revised returns contemplated by sub-section (5) of Taxman 122 (Sc) section 139 - which means that section 153(1)(c) was not attracted in this case." {CLI 2 - Pg. 875 - 876} Sharavathy At para 7 of the decision, it was held that "it cannot be Conductors (P.) said to be a bonafide omission in the original return to Ltd. V. CCIT make a claim of the deduction clearly admissible to the [2017] 87 assessee. The issue being a debatable one, the revised Taxmann.Com return for that purpose could not have been filed by the 244 (Karnataka) assessee and Respondent No.1 cannot be faulted in Page 58 of 74 ITA Nos. 642 to 645/Bang/2024 rejecting such condonation of delay application." {CLI 2
Income Tax Appellate Tribunal - Bangalore Cites 69 - Cited by 0 - Full Document

M/S. Bharat Beedi Works Private ... vs Deputy Commisioner Of Income Tax, ... on 21 April, 2025

Cases Rebuttals At para 11 of the decision, it was held that "Once this is so the revised returns filed by the assessee for both the Kumar Jagdish said assessment years were not valid in law and Chandra Sinha could not have been treated and acted upon as V. CIT [1996] 86 revised returns contemplated by sub-section (5) of Taxman 122 (Sc) section 139 - which means that section 153(1)(c) was not attracted in this case." {CLI 2 - Pg. 875 - 876} Sharavathy At para 7 of the decision, it was held that "it cannot be Conductors (P.) said to be a bonafide omission in the original return to Ltd. V. CCIT make a claim of the deduction clearly admissible to the [2017] 87 assessee. The issue being a debatable one, the revised Taxmann.Com return for that purpose could not have been filed by the 244 (Karnataka) assessee and Respondent No.1 cannot be faulted in Page 58 of 74 ITA Nos. 642 to 645/Bang/2024 rejecting such condonation of delay application." {CLI 2
Income Tax Appellate Tribunal - Bangalore Cites 69 - Cited by 0 - Full Document

M/S. Bharat Beedi Works Private Limited ... vs Assistant Commisioner Of Income Tax, ... on 21 April, 2025

Cases Rebuttals At para 11 of the decision, it was held that "Once this is so the revised returns filed by the assessee for both the Kumar Jagdish said assessment years were not valid in law and Chandra Sinha could not have been treated and acted upon as V. CIT [1996] 86 revised returns contemplated by sub-section (5) of Taxman 122 (Sc) section 139 - which means that section 153(1)(c) was not attracted in this case." {CLI 2 - Pg. 875 - 876} Sharavathy At para 7 of the decision, it was held that "it cannot be Conductors (P.) said to be a bonafide omission in the original return to Ltd. V. CCIT make a claim of the deduction clearly admissible to the [2017] 87 assessee. The issue being a debatable one, the revised Taxmann.Com return for that purpose could not have been filed by the 244 (Karnataka) assessee and Respondent No.1 cannot be faulted in Page 58 of 74 ITA Nos. 642 to 645/Bang/2024 rejecting such condonation of delay application." {CLI 2
Income Tax Appellate Tribunal - Bangalore Cites 69 - Cited by 0 - Full Document

M/S. Bharat Beedi Works Private ... vs Deputy Commisioner Of Income Tax, ... on 21 April, 2025

Cases Rebuttals At para 11 of the decision, it was held that "Once this is so the revised returns filed by the assessee for both the Kumar Jagdish said assessment years were not valid in law and Chandra Sinha could not have been treated and acted upon as V. CIT [1996] 86 revised returns contemplated by sub-section (5) of Taxman 122 (Sc) section 139 - which means that section 153(1)(c) was not attracted in this case." {CLI 2 - Pg. 875 - 876} Sharavathy At para 7 of the decision, it was held that "it cannot be Conductors (P.) said to be a bonafide omission in the original return to Ltd. V. CCIT make a claim of the deduction clearly admissible to the [2017] 87 assessee. The issue being a debatable one, the revised Taxmann.Com return for that purpose could not have been filed by the 244 (Karnataka) assessee and Respondent No.1 cannot be faulted in Page 58 of 74 ITA Nos. 642 to 645/Bang/2024 rejecting such condonation of delay application." {CLI 2
Income Tax Appellate Tribunal - Bangalore Cites 69 - Cited by 0 - Full Document

Ranbir Singh Sorout,Faridabad vs Ito, Ward-2(2), Faridabad on 20 August, 2025

4.2.2019, 22.8.2019 and 11.12.2020 for the assessment years 2017-18, 2018-19 and 2019-20 respectively which were prior to the decision of the Hon'ble Supreme Court in the case of Checkmate Services Pvt. Ltd., the issue was highly debatable and therefore outside the purview of scope of section 143(1) of the Act. Ld. Counsel placed reliance on the decisions of Hon'ble Chhattisgarh High Court in the case of Raj Kumar Bothra vs. DCIT in TaxC No.56 of 2025 dated 8.5.2025, decision of the coordinate bench of Delhi ITAT in the case of A2Z Infra Services Ltd. vs. DCIT in ITA No.970/Del/2023 & 72/Del/2024 dated 16.6.2025, in support of the above contention.
Income Tax Appellate Tribunal - Delhi Cites 33 - Cited by 0 - Full Document

Ranbir Singh Sorout,Faridabad vs Ito,Ward-2(2), Faridabad on 20 August, 2025

4.2.2019, 22.8.2019 and 11.12.2020 for the assessment years 2017-18, 2018-19 and 2019-20 respectively which were prior to the decision of the Hon'ble Supreme Court in the case of Checkmate Services Pvt. Ltd., the issue was highly debatable and therefore outside the purview of scope of section 143(1) of the Act. Ld. Counsel placed reliance on the decisions of Hon'ble Chhattisgarh High Court in the case of Raj Kumar Bothra vs. DCIT in TaxC No.56 of 2025 dated 8.5.2025, decision of the coordinate bench of Delhi ITAT in the case of A2Z Infra Services Ltd. vs. DCIT in ITA No.970/Del/2023 & 72/Del/2024 dated 16.6.2025, in support of the above contention.
Income Tax Appellate Tribunal - Delhi Cites 33 - Cited by 0 - Full Document
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