Apex Court in the
case of CIT v. Kelvinator of India Ltd. (320 ITR 561) which, according
to him, upheld the decision of full Bench ... Delhi High Court in the
case of CIT v. Kelvinator of India Ltd. (256 ITR 1). Ld. CIT(Appeals)
was appreciative of these contentions. According
decision of the Supreme Court in the
case of CIT V. Kelvinator India Limited , reported in 320 ITR
561 (SC).
3. The Commissioner ... decision of Hon'ble Supreme Court in the
case of Kelvinator India limited, reported in 320 ITR 561(SC). wherein,
it has been held
view of the judgement of Delhi High Court in the case of Kelvinator India
Ltd. reported in 256 ITR 1 (Del.) and Usha International ... full Bench of Delhi High Court in the case of
Kelvinator of India Ltd., 256 ITR 1 by following circular no.549
of CBDT held
brought out by the Supreme Court in the case of CIT v. Kelvinator in 320
ITR 561 as follows:-
"However, one needs to give ... wholly
vague, indefinite, far-fetched or remote."
9. In CIT v. Kelvinator India Ltd. (320 ITR 561) the Supreme Court
observed as under (page
Supreme Court in the case of CIT vs. Kelvinator of
India Ltd. [2010] 320 ITR 561 (SC) was also considered by Hon'ble
Madras ... Assessing Officer, both strongly deprecated by the Supreme Court in
CIT v. Kelvinator (supra)."
ITA No.2334/Chny/2019
order is to be quashed as being without jurisdiction.
CIT Vs.Kelvinator of India Ltd- 320 ITR 561 (SC).
2.3. The appellant relies ... Supreme Court in the case of CIT vs.
Kelvinator of India Ltd. , 320 ITR 561 (SC) on change of opinion and
has also cited
Supreme Court in the case of M/s. Kelvinator
India Ltd, when no change of opinion could be alleged
on a factual situation ... Supreme Court in
the case of CIT Vs Kelvinator of India Ltd (2010) 320 ITR 561
and also the decision
Supreme Court Of India in the case of C.I.T vs KELVINATOR
OF INDIA (2010 320 ITR 561) has clearly held that the power ... Brokers P.Ltd
[2007] 291 ITR 500 (SC)", "CIT- Vs-Kelvinator India Ltd (2010) 320 ITR 561
(SC)" and "Income
upon the decision
of Hon'ble Supreme Court in CIT vs. Kelvinator of India Ltd. (320 ITR
561). Similar was stated ... including the decision of Hon'ble Supreme Court in CIT vs.
Kelvinator of India Ltd. (320 ITR 561). The adjudication
Supreme Court in the case of CIT v. Kelvinator
of India Ltd. 320 ITR 561 (SC) applies.
6.2 In similar facts and circumstances, in assessee ... Supreme Court in the case of CIT v. Kelvinator of India Ltd. (supra)
applies. In the appellate order, the ld. CIT(A) has reproduced
