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1 - 5 of 5 (0.17 seconds)Section 132 in The Income Tax Act, 1961 [Entire Act]
Itc Limited, Kolkata vs Acit, Rg-8, Kolkata, Kolkata on 28 November, 2018
intimated the same to the Department and is not pressing the ground.
The Hon'ble Supreme Court in the case of DCIT vs. ITC Ltd (1996)
222 ITR 551 (SC) has held that when an assessee does not dispute
an addition during assessment and accepts it voluntarily, they are
deemed to have waived their right to appeal .
Sterling Machine Tools vs Commissioner Of Income-Tax on 15 November, 1979
The Hon'ble Delhi High
Court in the case of Sterling Machine Tools vs. CIT (1980) 123 ITR
181 (Del) has ruled that when an assessee has agreed to a particular
addition during assessment, they cannot later turn around and contest
it in appeal unless they prove that their acceptance was under
S. Sundaram Pillai, Etc vs V.R. Pattabiraman Etc on 24 January, 1985
coercion, mistake of law or misrepresentation. The Hon'ble Supreme
Court in the case of Sundaram Pillai vs Pattabiraman (1985) 1 SCC
591 (SC) has explained that estoppels applies when a party makes a
representation by words or conduct and induces another party to act
upon it. In taxation matters, a taxpayer who has voluntary accepted an
addition cannot later take a contrary position. Therefore, once
assessee has accepted the addition and has not contested it before
the CIT(A) they cannot raise the issue at ITAT stage.
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