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1 - 10 of 10 (0.28 seconds)Section 153 in The Income Tax Act, 1961 [Entire Act]
Section 251 in The Income Tax Act, 1961 [Entire Act]
Vastal N. Parikh vs Income-Tax Officer on 10 July, 1985
12. Learned counsel for the petitioner in support of his contention referred to the case of AB. Parikh v. ITO . In the aforesaid decision, the learned single Judge has taken the view that when
the entity in question are independent legal/juristic person, then notice should be given under Expln. 3 of Section 153 of the Act. Relevant portion of the judgment reads :
Section 148 in The Income Tax Act, 1961 [Entire Act]
Section 149 in The Income Tax Act, 1961 [Entire Act]
Rajinder Nath Etc vs Commissioner Of Income Tax, Delhi on 13 August, 1979
On the basis of the above quoted passage an attempt is being made to argue that the word 'free' in one of the impugned orders (referred to above), shows that there is no concluded direction as such under Section 153(3) read with Expln. 3(ii) of the Act.
The Income Tax Act, 1961
Rani Rajendra Kumari Ba vs Income-Tax Officer, "B" Ward on 12 April, 1972
In support of his contention he has relied upon the decision reported in the case of Rani Rajendra Kumari Ba v. ITO and Anr. decision of this Court reported in Gupta Traders v. CIT .
Gupta Traders vs Commissioner Of Income-Tax on 15 December, 1981
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.
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