Sumati Dayal vs Commissioner Of Income-Tax, Bangalore on 28 March, 1995
Equivalent citations: 1995 AIR 2109, 1995 SCC SUPL. (2) 453, AIR 1995 SUPREME ... Agrawal
Bench: S.C. Agrawal , B.L Hansaria
PETITIONER:
SUMATI DAYAL
Vs.
RESPONDENT:
COMMISSIONER OF INCOME-TAX, BANGALORE
DATE OF JUDGMENT28/03/1995
BENCH
Tribunal has relied upon a decision of the Supreme Court in Sumati Dayal
reported in (1995) 214 ITR 801 (SC) without any party ... laid down by the Supreme Court in the matter of Sumati
Dayal (supra) to the effect that the evidence produced must be analyzed by
applying
Supreme Court in the case of Sumati Dayal Vs CIT
[1995] 214 ITR 801, [which has been relied on by learned ... learned CIT(A) has further relied on the case law of Sumati Dayal vs.
CIT (supra) wherein the human probability of preponderance of the
transaction
door will be left wide open to evade tax.
( iii) Sumati Dayal v. Commissioner of Income-tax [1995] 80 TAXMAN 89 (SC):
" Section ... pertinent here to mention that in the case of Sumati Dayal, the revenue had taken
an adverse view and the Apex Court had confirmed
Supreme Court of India in case of Sumati Dayal v/s
CIT reported in 1995 AIR 2019, wherein it was held as under ... Supreme Court in Sumati Dayal vs. Commissioner
of Income Tax in 1995 AIR 2109 has held that "This raises the
question whether the apparent
reality such recitals. " Similarly in the case of
Sumati Dayal vs. CIT (1995) 214 ITR 801 (SC), their Lordships held as under ... Supreme Court in the case of
Sumati Dayal Vs. CIT (214 ITR 801) (SC) that the true nature of transaction have to be
ascertained
nature, the department cannot act unreasonably in rejecting the explanation. In Sumati Dayal v. CIT (1995) 214 ITR 801, the Supreme Court again reiterated that ... those documents."
The Supreme Court again, in the judgment in Sumati Dayal v. CIT (1995) 214 ITR 801, had reiterated the law laid down
upon by the Assessing Officer in terms of the decisions in Sumati Dayal v. CIT 214 ITR-80 and CIT v. Durga Prasad More ... considered by applying the test of Human Probabilities (214 ITR 801, Sumati Dayal v. CIT SC and 82 ITR 540 CIT v. Durga Prasad More
reality such recitals. " Similarly in the case of
Sumati Dayal vs. CIT (1995) 214 ITR 801 (SC), their Lordships held as under ... Supreme Court in the case of
Sumati Dayal Vs. CIT (214 ITR 801) (SC) that the true nature of transaction have to be
ascertained
reality such recitals. " Similarly in the case of
Sumati Dayal vs. CIT (1995) 214 ITR 801 (SC), their Lordships held as under ... Supreme Court in the case of
Sumati Dayal Vs. CIT (214 ITR 801) (SC) that the true nature of transaction have to be
ascertained
