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1 - 10 of 21 (0.56 seconds)Section 148 in The Income Tax Act, 1961 [Entire Act]
Section 54EC in The Income Tax Act, 1961 [Entire Act]
V. Jaganmohan Rao And Ors. vs Commissioner Of Income-Tax And Excess ... on 31 July, 1969
In this case, the High Court has also discussed the judgment of Hon'ble
Supreme Court in V. Jaganmohan Rao v/s CIT [1970] 75 ITR 373 (SC), as
relied upon by the Assessing Officer in this case.
Section 50C in The Income Tax Act, 1961 [Entire Act]
Manjinder Singh Kang vs Commissioner Of Income-Tax Amritsar ... on 13 September, 2010
32. Punjab and Haryana High Court in case of Majinder Singh Kang
Vs. Commissioner of Income- Tax and anr (supra) ofcourse has
sounded a different note. We may, however, notice that the
explanatory memorandum to Explanation 3 to Section 147 of the Act
was not brought to the notice of the High Court in the said decision.
The High Court gave considerable importance on such Explanation 3
to Section 147 of the Act and the language used therein."
The Commissioner Of Income Tax vs The Atlas Cycle Industries Limited on 20 August, 2010
"27. From the above, it can be seen that the explanation was meant
to be clarificatory in nature and to put the issue beyond any legal
controversy. When the Legislature found that in face of the provisions
contained in Section 147 of the Act post 01.04.1989 some of the
courts had taken a view that the Assessing Officer is restricted to the
reassessment proceedings only on issues in respect of which the
reasons were recorded for reopening the assessment, such
explanation was introduced in the statute. Thus, the explanation was
meant to be merely clarificatory in nature and was introduced with
Mr. Hamid Zain Vasi
16
the purpose of putting at rest the legal controversy regarding the true
interpretation of Section 147 of the Act which had arisen on account
of certain judicial pronouncements. We have noticed that prior to
enactment of Explanation 3 to Section 147, Punjab and Haryana High
Court in case of Commissioner of Income Tax Vs. Atlas Cycle
Industries reported in 180 ITR 319 (supra) had taken a restricted
view of the power of the Assessing Officer to make any addition on
the grounds not mentioned in the reasons recorded for reopening the
assessment.
Section 154 in The Income Tax Act, 1961 [Entire Act]
Commissioner Of Income Tax, New Delhi vs Air France on 13 April, 2009
In case of CIT vs. Jet Airways (I) Ltd. ,the High
Court, in its elaborate decision considering the statutory provisions,
different judicial pronouncements and the explanatory memorandum
for introduction of Explanation 3 to Section 147 of the Act, ruled in
favour of the assessee.
Travancore Cements Ltd. vs Assistant Commissioner Of Income Tax on 1 September, 2006
We may also notice that Kerela High Court in case of
Travencore Cements Ltd. Vs. Assistant Commissioner of Income-Tax
and anr reported in 305 ITR 170 had taken somewhat similar stand.