Home / Supreme Court / Judgments / 2012 / Diary 10254

DY.COMMR.OF I.T v. MARUTI FINANCE

Supreme Court of India | Diary 10254/2012

Status

Judgment - of Main Case

Decided On

12-03-2014

Bench

Petitioner

DY.COMMR.OF I.T

Respondent

MARUTI FINANCE

Primary Holding

Under Section 158BD of the Income Tax Act, 1961, the Assessing Officer's satisfaction that undisclosed income belongs to a person other than the searched person must be recorded before or at the time of transmitting seized documents, and such satisfaction can be recorded at any stage during the Chapter XIV-B proceedings, not necessarily before completion of block assessment under Section 158BC.

PDF 1 PDF 2 PDF 3 PDF 4 PDF 5 PDF 6 PDF 7 PDF 8 PDF 9 PDF 10 PDF 11 PDF 12 PDF 13 PDF 14 PDF 15 PDF 16 PDF 17 PDF 18 PDF 19 PDF 20 PDF 21 PDF 22 PDF 23 PDF 24 PDF 25 PDF 26 PDF 27 PDF 28 PDF 29 PDF 30 PDF 31 PDF 32 PDF 33 PDF 34 PDF 35 PDF 36 PDF 37 PDF 38 PDF 39 PDF 40 PDF 41 PDF 42 PDF 43 PDF 44 PDF 45 PDF 46 PDF 47 PDF 48 Check another SC case

Full Judgment Text

1 REPORTABLE IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NO. 3958 OF 2014 (SPECIAL LEAVE PETITION(C.)NO.10542 OF 2011) COMMISSIONER OF INCOME TAX - III APPELLANT VERSUS M/S.CALCUTTA KNITWEARS, LUDHIANA RESPONDENT WITH C.A.NO.3959 OF 2014 @ S.L.P.(C)NO.11943 of 2011 WITH C.A.NO.3960 OF 2014 @ S.L.P.(C)NO.17662 of 2011 WITH C.A.NO.3961 OF 2014 @ S.L.P.(C)NO.17656 of 2011 WITH C.A.NO.3962 OF 2014 @ S.L.P.(C)NO.17661 of 2011 WITH C.A.NO.3963 OF 2014 @ S.L.P.(C)NO.2804 of 2012 WITH C.A.NO.3964 OF 2014 @ S.L.P.(C)NO.2805 of 2012 WITH C.A.NO.3965 OF 2014 @ S.L.P.(C)NO.5264 of 2012 WITH C.A.NO.3966 OF 2014 @ S.L.P.(C)NO.5265 of 2012 WITH C.A.NO.3967 OF 2014 @ S.L.P.(C)NO.5266 of 2012 WITH C.A.NO.3968 OF 2014 @ S.L.P.(C)NO.7574 of 2012 WITH C.A.NO.3969 OF 2014 @ S.L.P.(C)NO.7575 of 2012 WITH C.A.NO.3970 OF 2014 @ S.L.P.(C)NO.7576 of 2012 WITH C.A.NO.3971 OF 2014 @ S.L.P.(C)NO.7577 of 2012 WITH C.A.NO.3972 OF 2014 @ S.L.P.(C)NO.9721 of 2012 WITH C.A.NO.3973 OF 2014 @ S.L.P.(C)NO.11460 of 2012 WITH C.A.NO.3974 OF 2014 @ S.L.P.(C)NO.12111 of 2012 WITH C.A.NO.3975 OF 2014 @ S.L.P.(C)NO.12886 of 2012 WITH C.A.NO.3976 OF 2014 @ S.L.P.(C)NO.12887 of 2012 WITH C.A.NO.3977 OF 2014 @ S.L.P.(C)NO.15207 of 2012 WITH C.A.NO.3978 OF 2014 @ S.L.P.(C)NO.15209 of 2012 WITH C.A.NO.3979 OF 2014 @ S.L.P.(C)NO.16266 of 2012 WITH C.A.NO.3980 OF 2014 @ S.L.P.(C)NO.16265 of 2012 WITH C.A.NO.3981 OF 2014 @ S.L.P.(C)NO.16319 of 2012 WITH C.A.NO.3982 OF 2014 @ S.L.P.(C)NO.16782 of 2012 WITH C.A.NO.3983 OF 2014 @ S.L.P.(C)NO.19491 of 2012 WITH C.A.NO.3984 OF 2014 @ S.L.P.(C)NO.19492 of 2012 WITH C.A.NO.3985 OF 2014 @ S.L.P.(C)NO.20626 of 2012 WITH C.A.NO.3986 OF 2014 @ S.L.P.(C)NO.21459 of 2012 WITH C.A.NO.3987 OF 2014 @ S.L.P.(C)NO.21460 of 2012 WITH C.A.NO.3988 OF 2014 @ S.L.P.(C)NO.30192 of 2012

2 WITH C.A.NO.3989 OF 2014 @ S.L.P.(C)NO.36559 of 2012 WITH C.A.NO.3990 OF 2014 @ S.L.P.(C)NO.12130 of 2013 WITH C.A.NO.3991 OF 2014 @ S.L.P.(C)NO.15368 of 2013 AND WITH S.L.P.(C)NO.7741 of 2013 O R D E R 1. Delay, if any, in filing and refiling the Special Leave Petitions is condoned. 2. Leave granted. 3. The issue that falls for our consideration and decision in all these appeals is: at what stage of the proceedings under Chapter XIV-B does the assessing authority require to record his satisfaction for issuing a notice under Section 158BD of the Income Tax Act, 1961 ('the Act' for short). 4. Since the issue is common in all these appeals, after hearing the learned counsel for the parties to the lis , we dispose of all these appeals by this common order. 5. For the purpose of disposal of these appeals, we take the Civil Appeal@ Special Leave Petition (Civil)

3 No.10542 of 2011 as the lead case. Civil Appeal No.3958 of 2014 @S.L.P.(C)No.10542/2011: 6. The respondent in this appeal is a firm engaged in manufacturing hosiery goods in the name and style of M/s. Calcutta Knitwears. 7. A search operation under Section 132 of the Act was carried out in two premises of the Bhatia Group, namely, M/s. Swastik Trading Company and M/s. Kavita International Company on 05.02.2003 and certain incriminating documents pertaining to the assessee firm were traced in the said search. 8. After completion of the investigation by the investigating agency and handing over of the documents to the assessing authority, the assessing authority had completed the block assessments in the case of Bhatia Group. Since certain other documents did not pertain to the person searched under Section 132 of the Act, the assessing authority thought it fit to transmit those documents, which according to him, pertain to the “undisclosed income” on account of investment element and profit element of the assessee firm and require to be assessed under Section 158BC

4 read with Section 158BD of the Act to another assessing authority in whose jurisdiction the assessments could be completed. In doing so, the assessing authority had recorded his satisfaction note dated 15.07.2005. 9. The jurisdictional assessing authority for the respondent-assessee had issued the show cause notice under Section 158BD for the block period 01.04.1996 to 05.02.2003, dated 10.02.2006 to the assessee inter alia directing the assessee to show cause as to why should the proceedings under Section 158BC not be completed. After receipt of the said notice, the assessee firm had filed its return under Section 158BD for the said block period declaring its total income as Nil and further filed its reply to the said notice challenging the validity of the said notice under Section 158BD, dated 08.03.2006. The assessee had taken the stand that the notice issued to the assessee is (a) in violation of the provisions of Section 158BD as the conditions precedent have not been complied with by the assessing officer and (b) beyond the period of limitation as provided for under Section

5 158BE read with Section 158BD and therefore, no action could be initiated against the assessee and accordingly, requested the assessing officer to drop the proceedings. 10. The assessing authority, after due consideration of the reply filed to the show cause notice, has rejected the aforesaid stand of the assessee and assessed the undisclosed income as Rs. 21,76,916/- (Rs.16,05,744/- (unexplained investment) and Rs.5,71,172/- (profit element)) by order dated 08.02.2008. The assessing officer is of the view that Section 158BE of the Act does not provide for any limitation for issuance of notice and completion of the assessment proceedings under Section 158BD of the Act and therefore a notice could be issued even after completion of the proceedings of the searched person under Section 158BC of the Act. 11. Disturbed by the orders passed by the assessing officer, the assessee firm had carried the matter in appeal before the Commissioner of Income Tax (Appeal- II) (for short 'the CIT(A)’). The CIT(A), while rejecting the stand of the assessee in respect of

6 validity of notice issued under Section 158BD, has partly allowed the appeal filed by the assessee firm and deleted the additions made by the assessing officer in its assessments, by his order dated 27.08.2008. 12. The Revenue had carried the matter further by filing appeal before the Income Tax Appellate Tribunal (for short 'the Tribunal') and the assessee has filed cross objections therein. The Tribunal, after hearing the parties to the lis, has rejected the appeal of the Revenue and observed that recording of satisfaction by the assessing officer as contemplated under Section 158BD was on a date subsequent to the framing of assessment under Section 158BC in case of the searched person, that is, beyond the period prescribed under Section 158BE(1)(b) and thereby the notice issued under Section 158BD was belated and consequently the assumption of jurisdiction by the assessing authority in the impugned block assessment would be invalid, by order dated 23.04.2009. 13. Aggrieved by the order so passed by the Tribunal, the Revenue had carried the matter in appeal under

7 Section 260A of the Act before the High Court. The High Court, by its impugned judgment and order dated 20.07.2010, has rejected the Revenue's appeal and confirmed the order passed by the Tribunal. 14. That is how the Revenue is before us in this appeal. 15. We have heard Shri Rupesh Kumar learned counsel for the Revenue and Shri R.P.Bhatt, Shri Ajay Vohra, Shri Santosh Krishan, learned counsel and other learned counsel for the respective assessees-respondents. 16. Shri Rupesh Kumar, learned counsel for the Revenue would contend that the assessing authority, after completion of the assessment proceedings against the searched person under Section 158BC, being of the opinion that the other documents which have surfaced at the time of the search under Section 132 of the Act belong to a person other than the searched person had recorded his satisfaction in the said respect and transmitted the papers to the jurisdictional assessing officer for the assessments of such person other than the searched person. Further, he would submit that the

8 assessing officer has complied with the requirements of Section 158BD of the Act in its entirety while preparing the satisfaction note and transmitting the documents to the jurisdictional assessing officer and therefore, the Tribunal and the High Court were not justified in holding that the satisfaction note ought to have been prepared by the assessing officer before the completion of the assessment proceedings of the searched person under Section 158BC of the Act and that the notice issued under Section 158BD was belated. 17. Per contra, Shri Bhatt, learned senior counsel and Shri Ajay Vohra and Shri Santosh Krishan learned counsel for the assessees would state that a satisfaction note requires to be made by the assessing officer before the seized documents were transmitted to another assessing officer in whose jurisdiction the person other than the searched person is assessed and submit that the said satisfaction note should be recorded before the assessment proceedings of the searched person are completed under Section 158BC of the Act and not later in time. By saying so, the

9 learned counsel would justify the reasoning and the conclusion reached by the Tribunal as well as the High Court. 18. In order to resolve the controversy, certain provisions of the Act require to be noticed by us. 19. Chapter XIV-B of the Act is a special provision carved out by the legislature for the purpose of the assessments in cases pertaining to Sections 132 and 132A of the Act. The said chapter was introduced by the Finance Act, 1995 with effect from 01.07.1995 and comprises Sections 158B to 158BH of the Act. The provisions under this Chapter were made inapplicable in case of search initiated under Section 132 or Section 132A after 31.05.2003 by introduction of an amendment to the Chapter as Section 158BI vide the Finance Act, 2003 with effect from 01.06.2003. The lis before us requires examination of the provisions of the said Chapter, particularly Section 158BD. 20. Section 158B of the Act is the dictionary clause. It provides for the definition of “block period” and “undisclosed income”. For the purpose of this case, a

10 reference to the definition of the “undisclosed income” as provided for in Section 158B(b) is necessary and, therefore, it is noticed. The same reads as under: “ Undisclosed income" includes any money, bullion, jewellery or other valuable article or thing or any income based on any entry in the books of account or other documents or transactions, where such money, bullion, jewellery, valuable article, thing, entry in the books of account or other document or transaction represents wholly or partly income or property which has not been or would not have been disclosed for the purposes of this Act [or any expense, deduction or allowance claimed under this Act which is found to be false]”. 21. Sections 158BC and 158BD of the Act are machinery provisions. Section 158BC of the Act provides the procedure for block assessment and Section 158BD of the Act provides for assessments in the case of an undisclosed income of any other person. The said sections are relevant for the purpose of this case and, therefore, they are extracted. They read as under:

11 “ Section 158BC. PROCEDURE FOR BLOCK ASSESSMENT. Where any search has been conducted under section 132 or books of account, other documents or assets are requisitioned under section 132A, in the case of any person, then, - [(a) The Assessing Officer shall, (i) In respect of search initiated or books of account or other documents or any assets requisitioned after the 30th day of June, 1995 but before the 1st day of January, 1997 serve a notice to such person requiring him to furnish within such time not being less than fifteen days; (ii) In respect of search initiated or books of account or other documents or any assets requisitioned on or after the 1st day of January, 1997, serve a notice to such person requiring him to furnish within such time not being less than fifteen days but not more than forty-five days, as may be specified in the notice a return in the prescribed form and verified in the same manner as a return under clause (i) of sub-section (1) of section 142, setting forth his total income including the undisclosed income for the block period: Provided that no notice under section 148 is required to be issued for the purpose of proceeding under this Chapter: Provided further that a person who has furnished a return

12 under this clause shall not be entitled to file a revised return;] (b) The Assessing Officer shall proceed to determine the undisclosed income of the block period in the manner laid down in section 158BB and the provisions of section 142, sub-sections (2) and (3) of section 143 [section 144 and section 145]shall, so far as may be, apply; (c) The Assessing Officer, on determination of the undisclosed income of the block period in accordance with this Chapter, shall pass an order of assessment and determine the tax payable by him on the basis of such assessment; (d) The assets seized under section 132 or requisitioned under section 132A shall be dealt with in accordance with the provisions of section 132B.] *** *** *** Section 158BD. UNDISCLOSED INCOME OF ANY OTHER PERSON. Where the Assessing Officer is satisfied that any undisclosed income belongs to any person, other than the person with respect to whom search was made under section 132 or whose books of account or other documents or any assets were requisitioned under section 132A then, the books of account, other documents or assets seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person and that Assessing Officer shall proceed [under section 158 BC] against such other person and the provisions of this

13 Chapter shall apply accordingly.” 22. Section 158BC speaks of procedure for assessment of a person searched under Section 132 of the Act or books of accounts, other documents or assets are requisitioned under section 132A. The limitation for the purpose of completion of the block assessments for the purpose of Section 158BC of the Act is as provided under Section 158BE(1)(a) of the Act, that is the time limit for completion of block assessment. 23. Section 158BD of the Act provides for “undisclosed income” of any other person. Before we proceed to explain the said provision, we intend to remind ourselves of the first or the basic principles of interpretation of a fiscal legislation. It is time and again reiterated that the courts, while interpreting the provisions of a fiscal legislation should neither add nor subtract a word from the provisions of instant meaning of the sections. It may be mentioned that the foremost principle of interpretation of fiscal statutes in every system of interpretation is the rule of strict interpretation which provides that where the

14 words of the statute are absolutely clear and unambiguous, recourse cannot be had to the principles of interpretation other than the literal rule (Swedish Match AB v. Securities and Exchange Board, India , AIR 2004 SC 4219, CIT v. Ajax Products Ltd. [1965] 55 ITR 741 (SC) ). 24. We may gainfully refer to The Cape Brandy Syndicate v. Inland Revenue Commissioners [1921] 1 KB 64 at 71 which involved the Finance (No. 2) Act 1915 which imposed excess profits duty on trade or businesses commenced after the outbreak of the First World War in 1914. By subjecting the legislation to a strict literal interpretation, Rowlatt J. held that the Finance (No. 2) Act 1915, in isolation, did not apply to businesses that commenced after the outbreak of war in 1914 and observed as follows: “… the principle in favour of a strict literal approach … simply means that in a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used.”

15 25. In Commissioner of Stamp Duties (NSW) v. Simpson , (1917) 24 CLR 209 Barton J., citing Viscount Haldane in Lumsden v Inland Revenue Commissioners, [1914] AC 877 , stated the following: “ The duty of Judges in construing Statutes is to adhere to the literal construction unless the context renders it plain that such a construction cannot be put on the words. This rule is especially important in cases of Statutes which impose taxation.” The Court in Simpson case (supra) sought to determine whether a deed poll constituted a settlement for the purposes of Section 49 of the Stamp Duties Act, 1898 (NSW). Section 3 which defined the word ‘settlement’ as meaning ‘any contract or agreement’ was examined. The Court by adopting a strict literal approach held that only a contract or an agreement could constitute a settlement and that Section 49 providing for deed poll was not applicable and therefore, the taxpayer did not have to pay any stamp duty. 26. Lord Granworth in Grundy v. Pinniger, (1852) 1 LJ Ch 405 has observed that: “ To adhere as closely as possible to the literal meaning of the words used, is a cardinal rule from which if we de -

16 part we launch into a sea of difficulties which it is not easy to fathom.” That is to say, once the literal rule is departed, then any number of interpretations can be put to a statutory provision, each Judge having a free play to put his own interpretation as he likes. This would be destructive of the edifice of fiscal legislations which impose economic duties and sanctions. 27. In taxing statutes, even if the literal interpretation results in hardship or inconvenience, it has to be followed (G.P. Singh's Principles of Statutory Interpretations, 12 th Ed, 2010, Lexis Nexis Butterworths Wadhwa Nagpur; Bennion on Statutory Interpretation, 5 th Ed., Lexis Nexis, p. 863; Vepa P. Sarathi, Interpretation of Statutes, 5 th Ed., Easter Book Company, Chapter VIII, Taxing Statutes). This Court in CIT v. Keshab Chandra Mandal , AIR 1950 SC 265 has held that hardship or inconvenience cannot alter the meaning of the language employed by the legislature if such meaning is clear and apparent. Hence departure from the literal rule should only be done in very rare cases, and ordinarily there should

17 be judicial restraint to do so. (Pandian Chemicals Ltd. v. C.I.T. , 2003(5) SCC 590, Narsiruddin v. Sita Ram Agarwal , AIR 2003 SC 1543, Bhaiji v. Sub-Divisional Officer, Thandla , 2003(1) SCC 692, J.P. Bansal v. State of Rajasthan and Anr., AIR 2003 SC 1405, State of Jharkhand and Anr. v. Govind Singh : JT 2004(10) SC 349, Jinia Keotin v. K.S. Manjhi, 2003 (1) SCC 730, Shiv Shakti Co-operative Housing Society v. Swaraj Developers , AIR 2003 SC 2434, Grasim Industries Limited v. Collector of Customs , 2002 (4) SCC 297 and Union of India v. Hamsoli Devi , 2002 (7) SCC 273) 28. The Australian High Court in Federal Commissioner of Taxation v. Westraders Pty Ltd , (1980) 144 CLR 55 considered the scope of Section 36A of the Income Tax Assessment Act, 1936(Cth), which on a literal interpretation allowed the taxpayer to make a profit and still claim a loss for tax purposes. The Commissioner argued the taxpayer’s conduct amounted to a tax avoidance scheme and should therefore be disallowed under Section 260 of the Income Tax Assessment Act, 1936(Cth). The Court held that under a literal interpretation Section 36A could apply to

18 allow the taxpayer to claim a loss. Barwick CJ, speaking for the majority relied on the decision in Inland Revenue Commissioners v. Westminster (Duke) , [1936] AC 1 which advocated the literal approach be applied when interpreting taxation legislation and stated the following: “ It is for the Parliament to specify, and to do so, in my opinion, as far as language will permit, with unambiguous clarity, the circumstances which will attract an obligation on the part of the citizen to pay tax. The function of the court is to interpret and apply the language in which the Parliament has specified those circumstances. The court is to do so by determining the meaning of the words employed by the Parliament according to the intention of the Parliament which is discoverable from the language used by the Parliament. It is not for the court to mould or to attempt to mould the language of the statute so as to produce some result which it might be thought the Parliament may have intended to achieve, though not expressed in the actual language employed” 29. In Cooper Brookes (Wollongong) Pty Ltd v. Federal Commissioner of Taxation (1981) 147 CLR 297 it is held that in a taxing statute if the language is unambiguous, departing from the literal approach ‘may lead judges to put their own ideas of justice or social policy in place of the words of the statute’. Similar view was espoused in C & J Clark Ltd v. Inland Revenue Commissioners, [1975] 1 WLR 413 and BP Refinery (Westernport) Pty Ltd v. Hastings Shire, (1977) 180 CLR 266.

19 30. In Hepples v. FCT , (1991) 173 CLR 492, the High Court of Australia unequivocally favoured the principle that taxation legislation should be subject to a strict literal interpretation and opined that such an approach was supported by ‘common sense’. Therein, the taxpayer, on ceasing to be employed, was paid $40,000 by his employer in exchange for the taxpayer agreeing that he would not carry on or be interested in certain businesses and would not divulge any trade secrets. The issue before the Court was whether or not such payment would form part of the taxpayer’s assessable income for the purposes of the Income Tax Assessment Act, 1936 (Cth). It was held that since the Act did not provide for such payments to form part of a taxpayer’s assessable income, the payment would not be assessable. 31. This Court in Tata Consultancy Services v. State of Andhra Pradesh has ascribed plain meaning to the terms computer and computer programme in a fiscal statute and reiterating the proposition laid

20 down in Inland Revenue Commissioner case (supra), observed that a court should not be over zealous in searching ambiguities or obscurities in words which are plain. 32. In Prakash Nath Khanna v. C.I.T. , 2004 (9) SCC 686 , this Court has explained that the language employed in a statute is the determinative factor of the legislative intent. The legislature is presumed to have made no mistake. The presumption is that it intended to say what it has said. Assuming there is a defect or an omission in the words used by the legislature, the Court cannot correct or make up the deficiency. Where the legislative intent is clear from the language, the Court should give effect to it (Delhi Financial Corporation v. Rajiv Anand , 2004 (11) SCC 625; Government of Andhra Pradesh v. Road Rollers Owners Welfare Association , 2004(6) SCC 210). 33. In B. Premanand and Ors.v. Mohan Koikal and Ors., (2011)4 SCC 266 this Court has observed as follows: “ 32. The literal rule of interpretation really means that there should be no interpretation. In other words, we

21 should read the statute as it is, without distorting or twisting its language. 33. We may mention here that the literal rule of inter - pretation is not only followed by Judges and lawyers, but it is also followed by the lay man in his ordinary life. To give an illustration, if a person says "this is a pen - cil", then he means that it is a pencil; and it is not that when he says that the object is a pencil, he means that it is a horse, donkey or an elephant. In other words, the literal rule of interpretation simply means that we mean what we say and we say what we mean. If we do not follow the literal rule of interpretation, social life will become impossible, and we will not understand each other. If we say that a certain object is a book, then we mean it is a book. If we say it is a book, but we mean it is a horse, table or an elephant, then we will not be able to communicate with each other. Life will become im - possible. Hence, the meaning of the literal rule of inter - pretation is simply that we mean what we say and we say what we mean.” 34. Thus, the language of a taxing statute should ordinarily be read understood in the sense in which it is harmonious with the object of the statute to effectuate the legislative animation. A taxing statute should be strictly construed; common sense approach, equity, logic, ethics and morality have no role to

22 play. Nothing is to be read in, nothing is to be implied; one can only look fairly at the language used and nothing more and nothing less. ( J. Srinivasa Rao v. Govt. of A.P. and Anr. 2006(13) SCALE 27 , Raja Jagadambika Pratap Narain Singh v. C.B.D.T., [1975] 100 ITR 698(SC) ) 35. It is also trite that while interpreting a machinery provision, the courts would interpret a provision in such a way that it would give meaning to the charging provisions and that the machinery provisions are liberally construed by the courts. In Mahim Patram Private Ltd. v . Union of India (UOI) and Ors., (2007) 3 SCC 668 this Court has observed that: “ 20. A taxing statute indisputably is to be strictly con - strued. [See J. Srinivasa Rao v. Govt. of Andhra Pradesh and Anr., 2006(13)SCALE 27 ]. It is, however, also well- settled that the machinery provisions for calculating the tax or the procedure for its calculation are to be con - strued by ordinary rule of construction. Whereas a liabil - ity has been imposed on a dealer by the charging section, it is well-settled that the court would construe the stat - ute in such a manner so as to make the machinery workable.

23 21. In J. Srinivasa Rao (supra), this Court noticed the de - cisions of this Court in Gursahai Saigal v. Commissioner of Income- tax, Punjab, [1963] 1 ITR 48(SC) and Ispat Indus - tries Ltd. v. Commissioner of Customs, Mumbai, 2006(202)ELT561(SC).In Gursahai Saigal (supra), the ques - tion which fell for consideration before this Court was construction of the machinery provisions vis-à-vis the charging provisions. Schedule appended to the Motor Vehicles Act is not machinery provision. It is a part of the charging provision. By giving a plain meaning to the Schedule appended to the Act, the machinery provision does not become unworkable. It did not prevent the clear inten - tion of the legislature from being defeated. It can be given an appropriate meaning.” 36. A reference to the observations of this Court in J.K. Synthetics Limited and Birla Cement Works and another v. Commercial Taxes Officer and another,(1994) 4 SCC 276 would be apposite: “ 13. It is well-known that when a statute levies a tax it does so by inserting a charging section by which a liabil - ity is created or fixed and then proceeds to provide the machinery to make the liability effective. It, there - fore, provides the machinery for the assessment of the li - ability already fixed by the charging section, and then provides the mode for the recovery and collection of tax, including penal provisions meant to deal with defaulters. … Ordinarily the charging section which fixes the liabil -

24 ity is strictly construed but that rule of strict con - struction is not extended to the machinery provisions which are construed like any other statute. The ma - chinery provisions must, no doubt, be so construed as would effectuate the object and purpose of the statute and not defeat the same. (Whitney v. Commissioners of Inland Revenue 1926 A C 37, CIT v. Mahaliram Ramjidas (1940) 8 ITR 442 , Indian United Mills Ltd. v. Commissioner of Ex - cess Profits Tax, Bombay, [1955] 27 ITR 20(SC) and Gursa - hai Saigal v. CIT, Punjab, [1963] 1 ITR 48(SC).” 37. It is the duty of the court while interpreting the machinery provisions of a taxing statute to give effect to its manifest purpose. Wherever the intention to impose liability is clear, the Courts ought not be hesitant in espousing a commonsense interpretation to the machinery provisions so that the charge does not fail. The machinery provisions must, no doubt, be so construed as would effectuate the object and purpose of the statute and not defeat the same ( Whitney v. Commissioners of Inland Revenue 1926 A C 37 , CIT v. Mahaliram Ramjidas (1940) 8 ITR 442 , Indian United Mills Ltd. v. Commissioner of Excess Profits Tax, Bombay [1955] 27 ITR 20(SC) , and Gursahai Saigal v. CIT, Punjab [1963] 1 ITR 48(SC) ; C ommissioner of

25 Wealth Tax, Meerut v. Sharvan Kumar Swarup & Sons, (1994) 6 SCC 623; CIT v. National Taj Traders, (1980) 1 SCC 370; Associated Cement Company Ltd. v. Commercial Tax Officer, Kota and Ors. , (48) STC 466) . Francis Bennion in Bennion on Statutory Interpretation, 5 th Ed., Lexis Nexis in support of the aforesaid proposition put forth as an illustration that since charge made by the legislator in procedural provisions is excepted to be for the general benefit of litigants and others, it is presumed that it applies to pending as well as future proceedings. 38. Having said that, let us revert to discussion of Section 158BD of the Act. The said provision is a machinery provision and inserted in the statute book for the purpose of carrying out assessments of a person other than the searched person under Sections 132 or 132A of the Act. Under Section 158BD of the Act, if an officer is satisfied that there exists any undisclosed income which may belong to a other person other than the searched person under Sections 132 or 132A of the Act, after recording such satisfaction,

26 may transmit the records/documents/chits/papers etc to the assessing officer having jurisdiction over such other person. After receipt of the aforesaid satisfaction and upon examination of the said other documents relating to such other person, the jurisdictional assessing officer may proceed to issue a notice for the purpose of completion of the assessments under Section 158BD of the Act, the other provisions of XIV-B shall apply. 39. The opening words of Section 158BD of the Act are that the assessing officer must be satisfied that “undisclosed income” belongs to any other person other than the person with respect to whom a search was made under Section 132 of the Act or a requisition of books were made under Section 132A of the Act and thereafter, transmit the records for assessment of such other person. Therefore, the short question that falls for our consideration and decision is at what stage of the proceedings should the satisfaction note be prepared by the assessing officer: whether at the time of initiating proceedings under Section 158BC for the completion of the assessments of the searched

27 person under Section 132 and 132A of the Act or during the course of the assessment proceedings under Section 158BC of the Act or after completion of the proceedings under Section 158BC of the Act. 40. The Tribunal and the High Court are of the opinion that it could only be prepared by the assessing officer during the course of the assessment proceedings under Section 158BC of the Act and not after the completion of the said proceedings. The Courts below have relied upon the limitation period provided in Section 158BE(2)(b) of the Act in respect of the assessment proceedings initiated under Section 158BD, i.e., two years from the end of the month in which the notice under Chapter XIV-B was served on such other person in respect of search initiated or books of account or other documents or any assets are requisitioned on or after 01.01.1997. We would examine whether the Tribunal or the High Court are justified in coming to the aforesaid conclusion. 41. We would certainly say that before initiating proceedings under Section 158BD of the Act, the

28 assessing officer who has initiated proceedings for completion of the assessments under Section 158BC of the Act should be satisfied that there is an undisclosed income which has been traced out when a person was searched under Section 132 or the books of accounts were requisitioned under Section 132A of the Act. This is in contrast to the provisions of Section 148 of the Act where recording of reasons in writing are a sine qua non. Under Section 158BD the existence of cogent and demonstrative material is germane to the assessing officers’ satisfaction in concluding that the seized documents belong to a person other than the searched person is necessary for initiation of action under Section 158BD. The bare reading of the provision indicates that the satisfaction note could be prepared by the assessing officer either at the time of initiating proceedings for completion of assessment of a searched person under Section 158BC of the Act or during the stage of the assessment proceedings. It does not mean that after completion of the assessment, the assessing officer cannot prepare the satisfaction note to the effect that there exists income tax belonging to any person other than the searched person

29 in respect of whom a search was made under Section 132 or requisition of books of accounts were made under Section 132A of the Act. The language of the provision is clear and unambiguous. The legislature has not imposed any embargo on the assessing officer in respect of the stage of proceedings during which the satisfaction is to be reached and recorded in respect of the person other than the searched person. 42. Further, Section 158BE(2)(b) only provides for the period of limitation for completion of block assessment under section 158BD in case of the person other than the searched person as two years from the end of the month in which the notice under this Chapter was served on such other person in respect of search carried on after 01.01.1997. The said section does neither provides for nor imposes any restrictions or conditions on the period of limitation for preparation the satisfaction note under Section 158BD and consequent issuance of notice to the other person. 43. In the lead case, the assessing officer had prepared a satisfaction note on 15.07.2005 though the assessment proceedings in the case of a searched

30 person, namely, S.K. Bhatia were completed on 30.03.2005. As we have already noticed, the Tribunal and the High Court are of the opinion that since the satisfaction note was prepared after the proceedings were completed by the assessing officer under Section 158BC of the Act which is contrary to the provisions of Section 158BD read with Section 158BE(2)(b) and therefore, have dismissed the case of the Revenue. In our considered opinion, the reasoning of the learned Judges of the High Court is contrary to the plain and simple language employed by the legislature under Section 158BD of the Act which clearly provides adequate flexibility to the assessing officer for recording the satisfaction note after the completion of proceedings in respect of the searched person under Section 158BC. Further, the interpretation placed by the Courts below by reading into the plain language of Section 158BE(2)(b) such as to extend the period of limitation to recording of satisfaction note would run counter to the avowed object of introduction of Chapter to provide for cost-effective, efficient and expeditious completion of search assessments and avoiding or reducing long drawn proceedings.

31 44. In the result, we hold that for the purpose of Section 158BD of the Act a satisfaction note is sine qua non and must be prepared by the assessing officer before he transmits the records to the other assessing officer who has jurisdiction over such other person. The satisfaction note could be prepared at either of the following stages: (a) at the time of or along with the initiation of proceedings against the searched person under Section 158BC of the Act; (b) along with the assessment proceedings under Section 158BC of the Act; and (c) immediately after the assessment proceedings are completed under Section 158BC of the Act of the searched person. 45. We are informed by Shri Santosh Krishan, who is appearing in seven of the appeals that the assessing officer had not recorded the satisfaction note as required under Section 158BD of the Act, therefore, the Tribunal and the High Court were justified in setting aside the orders of assessment and the orders passed by the first appellate authority. We do not intend to examine the aforesaid contention canvassed

32 by the learned counsel since we are remanding the matters to the High Court for consideration of the individual cases herein in light of the observations made by us on the scope and possible interpretation of Section 158BD of the Act. 46. With these observations, the appeals are disposed of. The matters are remanded to the respective High Courts for deciding the matters afresh after affording an opportunity of hearing to the parties. Ordered accordingly. In C.A.NO.3959 OF 2014 @ S.L.P.(C)NO.11943 of 2011 C.A.NO.3960 OF 2014 @ S.L.P.(C)NO.17662 of 2011 C.A.NO.3961 OF 2014 @ S.L.P.(C)NO.17656 of 2011 C.A.NO.3962 OF 2014 @ S.L.P.(C)NO.17661 of 2011 C.A.NO.3963 OF 2014 @ S.L.P.(C)NO.2804 of 2012 C.A.NO.3964 OF 2014 @ S.L.P.(C)NO.2805 of 2012 C.A.NO.3965 OF 2014 @ S.L.P.(C)NO.5264 of 2012 C.A.NO.3966 OF 2014 @ S.L.P.(C)NO.5265 of 2012 C.A.NO.3967 OF 2014 @ S.L.P.(C)NO.5266 of 2012 C.A.NO.3968 OF 2014 @ S.L.P.(C)NO.7574 of 2012 C.A.NO.3969 OF 2014 @ S.L.P.(C)NO.7575 of 2012 C.A.NO.3970 OF 2014 @ S.L.P.(C)NO.7576 of 2012 C.A.NO.3971 OF 2014 @ S.L.P.(C)NO.7577 of 2012 C.A.NO.3972 OF 2014 @ S.L.P.(C)NO.9721 of 2012 C.A.NO.3973 OF 2014 @ S.L.P.(C)NO.11460 of 2012 C.A.NO.3974 OF 2014 @ S.L.P.(C)NO.12111 of 2012 C.A.NO.3975 OF 2014 @ S.L.P.(C)NO.12886 of 2012 C.A.NO.3976 OF 2014 @ S.L.P.(C)NO.12887 of 2012 C.A.NO.3977 OF 2014 @ S.L.P.(C)NO.15207 of 2012 C.A.NO.3978 OF 2014 @ S.L.P.(C)NO.15209 of 2012

33 C.A.NO.3979 OF 2014 @ S.L.P.(C)NO.16266 of 2012 C.A.NO.3980 OF 2014 @ S.L.P.(C)NO.16265 of 2012 C.A.NO.3981 OF 2014 @ S.L.P.(C)NO.16319 of 2012 C.A.NO.3982 OF 2014 @ S.L.P.(C)NO.16782 of 2012 C.A.NO.3983 OF 2014 @ S.L.P.(C)NO.19491 of 2012 C.A.NO.3984 OF 2014 @ S.L.P.(C)NO.19492 of 2012 C.A.NO.3985 OF 2014 @ S.L.P.(C)NO.20626 of 2012 C.A.NO.3986 OF 2014 @ S.L.P.(C)NO.21459 of 2012 C.A.NO.3987 OF 2014 @ S.L.P.(C)NO.21460 of 2012 C.A.NO.3988 OF 2014 @ S.L.P.(C)NO.30192 of 2012 C.A.NO.3989 OF 2014 @ S.L.P.(C)NO.36559 of 2012 C.A.NO.3990 OF 2014 @ S.L.P.(C)NO.12130 of 2013 AND WITH C.A.NO.3991 OF 2014 @ S.L.P.(C)NO.15368 of 2013: In view of the order passed in Civil Appeal @ S.L.P. (C)No.10542 of 2011, these appeals are also disposed of in the same terms, conditions, observations and directions contained therein. Ordered accordingly.

34 S.L.P.(C)No.7741/2013: De-tag and list separately. Ordered accordingly. .......................J. (H.L. DATTU) .......................J. (S.A. BOBDE) NEW DELHI; MARCH 12, 2014

^} REPORTABLE IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NO. 3958 OF 2014 (SPECIAL LEAVE PETITION(C.)NO.10542 OF 2011)COMMISSIONER OF INCOME TAX - III APPELLANT VERSUSM/S.CALCUTTA KNITWEARS, LUDHIANA RESPONDENTWITH C.A.NO.3959 OF 2014 @ S.L.P.(C)NO.11943 of 2011WITH C.A.NO.3960 OF 2014 @ S.L.P.(C)NO.17662 of 2011WITH C.A.NO.3961 OF 2014 @ S.L.P.(C)NO.17656 of 2011WITH C.A.NO.3962 OF 2014 @ S.L.P.(C)NO.17661 of 2011WITH C.A.NO.3963 OF 2014 @ S.L.P.(C)NO.2804 of 2012WITH C.A.NO.3964 OF 2014 @ S.L.P.(C)NO.2805 of 2012WITH C.A.NO.3965 OF 2014 @ S.L.P.(C)NO.5264 of 2012WITH C.A.NO.3966 OF 2014 @ S.L.P.(C)NO.5265 of 2012WITH C.A.NO.3967 OF 2014 @ S.L.P.(C)NO.5266 of 2012WITH C.A.NO.3968 OF 2014 @ S.L.P.(C)NO.7574 of 2012WITH C.A.NO.3969 OF 2014 @ S.L.P.(C)NO.7575 of 2012WITH C.A.NO.3970 OF 2014 @ S.L.P.(C)NO.7576 of 2012WITH C.A.NO.3971 OF 2014 @ S.L.P.(C)NO.7577 of 2012WITH C.A.NO.3972 OF 2014 @ S.L.P.(C)NO.9721 of 2012WITH C.A.NO.3973 OF 2014 @ S.L.P.(C)NO.11460 of 2012WITH C.A.NO.3974 OF 2014 @ S.L.P.(C)NO.12111 of 2012WITH C.A.NO.3975 OF 2014 @ S.L.P.(C)NO.12886 of 2012WITH C.A.NO.3976 OF 2014 @ S.L.P.(C)NO.12887 of 2012WITH C.A.NO.3977 OF 2014 @ S.L.P.(C)NO.15207 of 2012WITH C.A.NO.3978 OF 2014 @ S.L.P.(C)NO.15209 of 2012WITH C.A.NO.3979 OF 2014 @ S.L.P.(C)NO.16266 of 2012WITH C.A.NO.3980 OF 2014 @ S.L.P.(C)NO.16265 of 2012WITH C.A.NO.3981 OF 2014 @ S.L.P.(C)NO.16319 of 2012WITH C.A.NO.3982 OF 2014 @ S.L.P.(C)NO.16782 of 2012WITH C.A.NO.3983 OF 2014 @ S.L.P.(C)NO.19491 of 2012WITH C.A.NO.3984 OF 2014 @ S.L.P.(C)NO.19492 of 2012WITH C.A.NO.3985 OF 2014 @ S.L.P.(C)NO.20626 of 2012WITH C.A.NO.3986 OF 2014 @ S.L.P.(C)NO.21459 of 2012WITH C.A.NO.3987 OF 2014 @ S.L.P.(C)NO.21460 of 2012WITH C.A.NO.3988 OF 2014 @ S.L.P.(C)NO.30192 of 2012WITH C.A.NO.3989 OF 2014 @ S.L.P.(C)NO.36559 of 2012WITH C.A.NO.3990 OF 2014 @ S.L.P.(C)NO.12130 of 2013WITH C.A.NO.3991 OF 2014 @ S.L.P.(C)NO.15368 of 2013 AND WITH S.L.P.(C)NO.7741 of 2013 O R D E R

1. Delay, if any, in filing and refiling the Special Leave Petitions is condoned. 2. Leave granted. 3. The issue that falls for our consideration and decision in all these appeals is: at what stage of the proceedings under Chapter XIV-B does the assessing authority require to record his satisfaction for issuing a notice under Section 158BD of the Income Tax Act, 1961 ('the Act' for short). 4. Since the issue is common in all these appeals, after hearing the learned counsel for the parties to the lis, we dispose of all these appeals by this common order. 5. For the purpose of disposal of these appeals, we take the Civil Appeal@ Special Leave Petition (Civil) No.10542 of 2011 as the lead case.Civil Appeal No.3958 of 2014 @S.L.P.(C)No.10542/2011: 6. The respondent in this appeal is a firm engaged in manufacturing hosiery goods in the name and style of M/s. Calcutta Knitwears. 7. A search operation under Section 132 of the Act was carried out in two premises of the Bhatia Group, namely, M/s. Swastik Trading Company and M/s. Kavita International Company on 05.02.2003 and certain incriminating documents pertaining to the assessee firm were traced in the said search. 8. After completion of the investigation by the investigating agency and handing over of the documents to the assessing authority, the assessing authority had completed the block assessments in the case of Bhatia Group. Since certain other documents did not pertain to the person searched under Section 132 of the Act, the assessing authority thought it fit to transmit those documents, which according to him, pertain to the "undisclosed income" on account of investment element and profit element of the assessee firm and require to be assessed under Section 158BC read with Section 158BD of the Act to another assessing authority in whose jurisdiction the assessments could be completed. In doing so, the assessing authority had recorded his satisfaction note dated 15.07.2005. 9. The jurisdictional assessing authority for the respondent-assessee had issued the show cause notice under Section 158BD for the block period 01.04.1996 to 05.02.2003, dated 10.02.2006 to the assessee inter alia directing the assessee to show cause as to why should the proceedings under Section 158BC not be completed. After receipt of the said notice, the assessee firm had filed its return under Section 158BD for the said block period declaring its total income as Nil and further filed its reply to the said notice challenging the validity of the said notice under Section 158BD, dated 08.03.2006. The assessee had taken the stand that the notice issued to the assessee is (a) in violation of the provisions of Section 158BD as the conditions precedent have not been complied with by the assessing officer and (b) beyond the period of limitation as provided for under Section 158BE read with Section 158BD and therefore, no action could be initiated against the assessee and accordingly, requested the assessing officer to drop the proceedings. 10. The assessing authority, after due consideration of the reply filed to the show cause notice, has rejected the aforesaid stand of the assessee and assessed the undisclosed income as Rs. 21,76,916/-

(Rs.16,05,744/- (unexplained investment) and Rs.5,71,172/- (profit element)) by order dated 08.02.2008. The assessing officer is of the view that Section 158BE of the Act does not provide for any limitation for issuance of notice and completion of the assessment proceedings under Section 158BD of the Act and therefore a notice could be issued even after completion of the proceedings of the searched person under Section 158BC of the Act. 11. Disturbed by the orders passed by the assessing officer, the assessee firm had carried the matter in appeal before the Commissioner of Income Tax (Appeal-II) (for short 'the CIT(A)'). The CIT(A), while rejecting the stand of the assessee in respect of validity of notice issued under Section 158BD, has partly allowed the appeal filed by the assessee firm and deleted the additions made by the assessing officer in its assessments, by his order dated 27.08.2008. 12. The Revenue had carried the matter further by filing appeal before the Income Tax Appellate Tribunal (for short 'the Tribunal') and the assessee has filed cross objections therein. The Tribunal, after hearing the parties to the lis, has rejected the appeal of the Revenue and observed that recording of satisfaction by the assessing officer as contemplated under Section 158BD was on a date subsequent to the framing of assessment under Section 158BC in case of the searched person, that is, beyond the period prescribed under Section 158BE(1)(b) and thereby the notice issued under Section 158BD was belated and consequently the assumption of jurisdiction by the assessing authority in the impugned block assessment would be invalid, by order dated 23.04.2009. 13. Aggrieved by the order so passed by the Tribunal, the Revenue had carried the matter in appeal under Section 260A of the Act before the High Court. The High Court, by its impugned judgment and order dated 20.07.2010, has rejected the Revenue's appeal and confirmed the order passed by the Tribunal. 14. That is how the Revenue is before us in this appeal. 15. We have heard Shri Rupesh Kumar learned counsel for the Revenue and Shri R.P.Bhatt, Shri Ajay Vohra, Shri Santosh Krishan, learned counsel and other learned counsel for the respective assessees-respondents. 16. Shri Rupesh Kumar, learned counsel for the Revenue would contend that the assessing authority, after completion of the assessment proceedings against the searched person under Section 158BC, being of the opinion that the other documents which have surfaced at the time of the search under Section 132 of the Act belong to a person other than the searched person had recorded his satisfaction in the said respect and transmitted the papers to the jurisdictional assessing officer for the assessments of such person other than the searched person. Further, he would submit that the assessing officer has complied with the requirements of Section 158BD of the Act in its entirety while preparing the satisfaction note and transmitting the documents to the jurisdictional assessing officer and therefore, the Tribunal and the High Court were not justified in holding that the satisfaction note ought to have been prepared by the assessing officer before the completion of the assessment proceedings of the searched person under Section 158BC of the Act and that the notice issued under Section 158BD was belated. 17. Per contra, Shri Bhatt, learned senior counsel and Shri Ajay Vohra and Shri Santosh Krishan learned counsel for the assessees would state that a satisfaction note requires to be made by the assessing officer before the seized documents were transmitted to another assessing officer in whose jurisdiction the person other than the searched

person is assessed and submit that the said satisfaction note should be recorded before the assessment proceedings of the searched person are completed under Section 158BC of the Act and not later in time. By saying so, the learned counsel would justify the reasoning and the conclusion reached by the Tribunal as well as the High Court. 18. In order to resolve the controversy, certain provisions of the Act require to be noticed by us. 19. Chapter XIV-B of the Act is a special provision carved out by the legislature for the purpose of the assessments in cases pertaining to Sections 132 and 132A of the Act. The said chapter was introduced by the Finance Act, 1995 with effect from 01.07.1995 and comprises Sections 158B to 158BH of the Act. The provisions under this Chapter were made inapplicable in case of search initiated under Section 132 or Section 132A after 31.05.2003 by introduction of an amendment to the Chapter as Section 158BI vide the Finance Act, 2003 with effect from 01.06.2003. The lis before us requires examination of the provisions of the said Chapter, particularly Section 158BD. 20. Section 158B of the Act is the dictionary clause. It provides for the definition of "block period" and "undisclosed income". For the purpose of this case, a reference to the definition of the "undisclosed income" as provided for in Section 158B(b) is necessary and, therefore, it is noticed. The same reads as under:"Undisclosed income" includes any money, bullion, jewellery or othervaluable article or thing or any income based on any entry in the books ofaccount or other documents or transactions, where such money, bullion,jewellery, valuable article, thing, entry in the books of account or otherdocument or transaction represents wholly or partly income or propertywhich has not been or would not have been disclosed for the purposes ofthis Act [or any expense, deduction or allowance claimed under this Actwhich is found to be false]". 21. Sections 158BC and 158BD of the Act are machinery provisions. Section 158BC of the Act provides the procedure for block assessment and Section 158BD of the Act provides for assessments in the case of an undisclosed income of any other person. The said sections are relevant for the purpose of this case and, therefore, they are extracted. They read as under:"Section 158BC. PROCEDURE FOR BLOCK ASSESSMENT.Where any search has been conducted under section 132 or books of account,other documents or assets are requisitioned under section 132A, in the caseof any person, then, -[(a) The Assessing Officer shall,(i) In respect of search initiated or books of account or other documentsor any assets requisitioned after the 30th day of June, 1995 but before the1st day of January, 1997 serve a notice to such person requiring him tofurnish within such time not being less than fifteen days;(ii) In respect of search initiated or books of account or other documents

or any assets requisitioned on or after the 1st day of January, 1997, servea notice to such person requiring him to furnish within such time not beingless than fifteen days but not more than forty-five days,as may be specified in the notice a return in the prescribed form andverified in the same manner as a return under clause (i) of sub-section (1)of section 142, setting forth his total income including the undisclosedincome for the block period:Provided that no notice under section 148 is required to be issued for thepurpose of proceeding under this Chapter:Provided further that a person who has furnished a return under this clauseshall not be entitled to file a revised return;](b) The Assessing Officer shall proceed to determine the undisclosed incomeof the block period in the manner laid down in section 158BB and theprovisions of section 142, sub-sections (2) and (3) of section 143 [section144 and section 145]shall, so far as may be, apply;(c) The Assessing Officer, on determination of the undisclosed income ofthe block period in accordance with this Chapter, shall pass an order ofassessment and determine the tax payable by him on the basis of suchassessment;(d) The assets seized under section 132 or requisitioned under section 132Ashall be dealt with in accordance with the provisions of section 132B.]*** *** ***Section 158BD. UNDISCLOSED INCOME OF ANY OTHER PERSON.Where the Assessing Officer is satisfied that any undisclosed incomebelongs to any person, other than the person with respect to whom searchwas made under section 132 or whose books of account or other documents orany assets were requisitioned under section 132A then, the books ofaccount, other documents or assets seized or requisitioned shall be handedover to the Assessing Officer having jurisdiction over such other personand that Assessing Officer shall proceed [under section 158 BC] againstsuch other person and the provisions of this Chapter shall applyaccordingly." 22. Section 158BC speaks of procedure for assessment of a person searched under Section 132 of the Act or books of accounts, other documents or assets are requisitioned under section 132A. The limitation for the purpose of completion of the block assessments for the purpose of Section 158BC of the Act is as provided under Section 158BE(1)(a) of the Act, that is the time limit for completion of block assessment. 23. Section 158BD of the Act provides for "undisclosed income" of any

other person. Before we proceed to explain the said provision, we intend to remind ourselves of the first or the basic principles of interpretation of a fiscal legislation. It is time and again reiterated that the courts, while interpreting the provisions of a fiscal legislation should neither add nor subtract a word from the provisions of instant meaning of the sections. It may be mentioned that the foremost principle of interpretation of fiscal statutes in every system of interpretation is the rule of strict interpretation which provides that where the words of the statute are absolutely clear and unambiguous, recourse cannot be had to the principles of interpretation other than the literal rule (Swedish Match AB v. Securities and Exchange Board, India, AIR 2004 SC 4219, CIT v. Ajax Products Ltd. [1965] 55 ITR 741 (SC)). 24. We may gainfully refer to The Cape Brandy Syndicate v. Inland Revenue Commissioners [1921] 1 KB 64 at 71 which involved the Finance (No. 2) Act 1915 which imposed excess profits duty on trade or businesses commenced after the outbreak of the First World War in 1914. By subjecting the legislation to a strict literal interpretation, Rowlatt J. held that the Finance (No. 2) Act 1915, in isolation, did not apply to businesses that commenced after the outbreak of war in 1914 and observed as follows:"... the principle in favour of a strict literal approach ... simply meansthat in a taxing Act one has to look merely at what is clearly said. Thereis no room for any intendment. There is no equity about a tax. There is nopresumption as to a tax. Nothing is to be read in, nothing is to beimplied. One can only look fairly at the language used." 25. In Commissioner of Stamp Duties (NSW) v. Simpson, (1917) 24 CLR 209 Barton J., citing Viscount Haldane in Lumsden v Inland Revenue Commissioners, [1914] AC 877, stated the following: "The duty of Judges in construing Statutes is to adhere to the literalconstruction unless the context renders it plain that such a constructioncannot be put on the words. This rule is especially important in cases ofStatutes which impose taxation."The Court in Simpson case (supra) sought to determine whether a deed pollconstituted a settlement for the purposes of Section 49 of the Stamp DutiesAct, 1898 (NSW). Section 3 which defined the word 'settlement' as meaning'any contract or agreement' was examined. The Court by adopting a strictliteral approach held that only a contract or an agreement could constitutea settlement and that Section 49 providing for deed poll was not applicableand therefore, the taxpayer did not have to pay any stamp duty. 26. Lord Granworth in Grundy v. Pinniger, (1852) 1 LJ Ch 405 has observed that:"To adhere as closely as possible to the literal meaning of the words used,is a cardinal rule from which if we depart we launch into a sea ofdifficulties which it is not easy to fathom."That is to say, once the literal rule is departed, then any number ofinterpretations can be put to a statutory provision, each Judge having afree play to put his own interpretation as he likes. This would bedestructive of the edifice of fiscal legislations which impose economicduties and sanctions.

27. In taxing statutes, even if the literal interpretation results in hardship or inconvenience, it has to be followed (G.P. Singh's Principles of Statutory Interpretations, 12th Ed, 2010, Lexis Nexis Butterworths Wadhwa Nagpur; Bennion on Statutory Interpretation, 5th Ed., Lexis Nexis, p. 863; Vepa P. Sarathi, Interpretation of Statutes, 5th Ed., Easter Book Company, Chapter VIII, Taxing Statutes). This Court in CIT v. Keshab Chandra Mandal, AIR 1950 SC 265 has held that hardship or inconvenience cannot alter the meaning of the language employed by the legislature if such meaning is clear and apparent. Hence departure from the literal rule should only be done in very rare cases, and ordinarily there should be judicial restraint to do so.(Pandian Chemicals Ltd. v. C.I.T., 2003(5) SCC 590, Narsiruddin v. Sita Ram Agarwal, AIR 2003 SC 1543, Bhaiji v. Sub-Divisional Officer, Thandla, 2003(1) SCC 692, J.P. Bansal v. State of Rajasthan and Anr., AIR 2003 SC 1405, State of Jharkhand and Anr. v. Govind Singh : JT 2004(10) SC 349, Jinia Keotin v. K.S. Manjhi, 2003 (1) SCC 730, Shiv Shakti Co-operative Housing Society v. Swaraj Developers, AIR 2003 SC 2434, Grasim Industries Limited v. Collector of Customs, 2002 (4) SCC 297 and Union of India v. Hamsoli Devi, 2002 (7) SCC 273) 28. The Australian High Court in Federal Commissioner of Taxation v. Westraders Pty Ltd, (1980) 144 CLR 55 considered the scope of Section 36A of the Income Tax Assessment Act, 1936(Cth), which on a literal interpretation allowed the taxpayer to make a profit and still claim a loss for tax purposes. The Commissioner argued the taxpayer's conduct amounted to a tax avoidance scheme and should therefore be disallowed under Section 260 of the Income Tax Assessment Act, 1936(Cth). The Court held that under a literal interpretation Section 36A could apply to allow the taxpayer to claim a loss. Barwick CJ, speaking for the majority relied on the decision in Inland Revenue Commissioners v. Westminster (Duke), [1936] AC 1 which advocated the literal approach be applied when interpreting taxation legislation and stated the following:"It is for the Parliament to specify, and to do so, in my opinion, as faras language will permit, with unambiguous clarity, the circumstances whichwill attract an obligation on the part of the citizen to pay tax. Thefunction of the court is to interpret and apply the language in which theParliament has specified those circumstances. The court is to do so bydetermining the meaning of the words employed by the Parliament accordingto the intention of the Parliament which is discoverable from the languageused by the Parliament. It is not for the court to mould or to attempt tomould the language of the statute so as to produce some result which itmight be thought the Parliament may have intended to achieve, though notexpressed in the actual language employed" 29. In Cooper Brookes (Wollongong) Pty Ltd v. Federal Commissioner of Taxation (1981) 147 CLR 297 it is held that in a taxing statute if the language is unambiguous, departing from the literal approach 'may lead judges to put their own ideas of justice or social policy in place of the words of the statute'. Similar view was espoused in C & J Clark Ltd v. Inland Revenue Commissioners, [1975] 1 WLR 413 and BP Refinery (Westernport) Pty Ltd v. Hastings Shire, (1977) 180 CLR 266. 30. In Hepples v. FCT, (1991) 173 CLR 492, the High Court of Australia unequivocally favoured the principle that taxation legislation should be subject to a strict literal interpretation and opined that such an approach was supported by 'common sense'. Therein, the taxpayer, on

ceasing to be employed, was paid $40,000 by his employer in exchange for the taxpayer agreeing that he would not carry on or be interested in certain businesses and would not divulge any trade secrets. The issue before the Court was whether or not such payment would form part of the taxpayer's assessable income for the purposes of the Income Tax Assessment Act, 1936(Cth). It was held that since the Act did not provide for such payments to form part of a taxpayer's assessable income, the payment would not be assessable. 31. This Court in Tata Consultancy Services v. State of Andhra Pradesh has ascribed plain meaning to the terms computer and computer programme in a fiscal statute and reiterating the proposition laid down in Inland Revenue Commissioner case (supra), observed that a court should not be over zealous in searching ambiguities or obscurities in words which are plain. 32. In Prakash Nath Khanna v. C.I.T., 2004 (9) SCC 686, this Court has explained that the language employed in a statute is the determinative factor of the legislative intent. The legislature is presumed to have made no mistake. The presumption is that it intended to say what it has said. Assuming there is a defect or an omission in the words used by the legislature, the Court cannot correct or make up the deficiency. Where the legislative intent is clear from the language, the Court should give effect to it (Delhi Financial Corporation v. Rajiv Anand, 2004 (11) SCC 625; Government of Andhra Pradesh v. Road Rollers Owners Welfare Association, 2004(6) SCC 210). 33. In B. Premanand and Ors.v. Mohan Koikal and Ors.,(2011)4 SCC 266 this Court has observed as follows:"32. The literal rule of interpretation really means that there should beno interpretation. In other words, we should read the statute as it is,without distorting or twisting its language.33. We may mention here that the literal rule of interpretation is not onlyfollowed by Judges and lawyers, but it is also followed by the lay man inhis ordinary life. To give an illustration, if a person says "this is apencil", then he means that it is a pencil; and it is not that when he saysthat the object is a pencil, he means that it is a horse, donkey or anelephant. In other words, the literal rule of interpretation simply meansthat we mean what we say and we say what we mean. If we do not follow theliteral rule of interpretation, social life will become impossible, and wewill not understand each other. If we say that a certain object is a book,then we mean it is a book. If we say it is a book, but we mean it is ahorse, table or an elephant, then we will not be able to communicate witheach other. Life will become impossible. Hence, the meaning of the literalrule of interpretation is simply that we mean what we say and we say whatwe mean." 34. Thus, the language of a taxing statute should ordinarily be read understood in the sense in which it is harmonious with the object of the statute to effectuate the legislative animation. A taxing statute should be strictly construed; common sense approach, equity, logic, ethics and morality have no role to play. Nothing is to be read in, nothing is to be implied; one can only look fairly at the language used and nothing more and nothing less. (J. Srinivasa Rao v. Govt. of A.P. and Anr. 2006(13) SCALE 27, Raja Jagadambika Pratap Narain Singh v. C.B.D.T., [1975] 100 ITR 698(SC))

35. It is also trite that while interpreting a machinery provision, the courts would interpret a provision in such a way that it would give meaning to the charging provisions and that the machinery provisions are liberally construed by the courts. In Mahim Patram Private Ltd. v. Union of India (UOI) and Ors., (2007) 3 SCC 668 this Court has observed that: "20. A taxing statute indisputably is to be strictly construed. [SeeJ. Srinivasa Rao v. Govt. of Andhra Pradesh and Anr., 2006(13)SCALE 27 ].It is, however, also well-settled that the machinery provisions forcalculating the tax or the procedure for its calculation are to beconstrued by ordinary rule of construction. Whereas a liability has beenimposed on a dealer by the charging section, it is well-settled that thecourt would construe the statute in such a manner so as to make themachinery workable.21. In J. Srinivasa Rao (supra), this Court noticed the decisions of thisCourt in Gursahai Saigal v.Commissioner of Income-tax, Punjab, [1963] 1ITR 48(SC) and Ispat Industries Ltd. v. Commissioner of Customs, Mumbai,2006(202)ELT561(SC).In Gursahai Saigal (supra), the question which fell forconsideration before this Court was construction of the machineryprovisions vis-`-vis the charging provisions. Schedule appended to theMotor Vehicles Act is not machinery provision. It is a part of the chargingprovision. By giving a plain meaning to the Schedule appended to the Act,the machinery provision does not become unworkable. It did not prevent theclear intention of the legislature from being defeated. It can be given anappropriate meaning." 36. A reference to the observations of this Court in J.K. Synthetics Limited and Birla Cement Works and another v. Commercial Taxes Officer and another,(1994) 4 SCC 276 would be apposite:"13. It is well-known that when a statute levies a tax it does so byinserting a charging section by which a liability is created or fixed andthen proceeds to provide the machinery to make the liability effective. It,therefore, provides the machinery for the assessment of the liabilityalready fixed by the charging section, and then provides the mode for therecovery and collection of tax, including penal provisions meant to dealwith defaulters. ... Ordinarily the charging section which fixes theliability is strictly construed but that rule of strict construction is notextended to the machinery provisions which are construed like any otherstatute. The machinery provisions must, no doubt, be so construed as wouldeffectuate the object and purpose of the statute and not defeat the same.(Whitney v. Commissioners of Inland Revenue 1926 A C 37, CIT v. MahaliramRamjidas (1940) 8 ITR 442 , Indian United Mills Ltd. v. Commissioner ofExcess Profits Tax, Bombay, [1955] 27 ITR 20(SC) and Gursahai Saigalv. CIT, Punjab, [1963] 1 ITR 48(SC)." 37. It is the duty of the court while interpreting the machinery provisions of a taxing statute to give effect to its manifest purpose. Wherever the intention to impose liability is clear, the Courts ought not be hesitant in espousing a commonsense interpretation to the machinery provisions so that the charge does not fail. The machinery provisions must, no doubt, be so construed as would effectuate the object and purpose of the statute and not defeat the same (Whitney v. Commissioners of Inland Revenue 1926 A C 37 , CIT v. Mahaliram Ramjidas (1940) 8 ITR 442, Indian United Mills Ltd. v. Commissioner of Excess Profits Tax, Bombay [1955] 27 ITR 20(SC), and Gursahai Saigal v. CIT, Punjab [1963] 1 ITR 48(SC); Commissioner of Wealth Tax, Meerut v. Sharvan Kumar Swarup & Sons, (1994) 6 SCC 623;

CIT v. National Taj Traders, (1980) 1 SCC 370; Associated Cement Company Ltd. v. Commercial Tax Officer, Kota and Ors., (48) STC 466). Francis Bennion in Bennion on Statutory Interpretation, 5th Ed., Lexis Nexis in support of the aforesaid proposition put forth as an illustration that since charge made by the legislator in procedural provisions is excepted to be for the general benefit of litigants and others, it is presumed that it applies to pending as well as future proceedings. 38. Having said that, let us revert to discussion of Section 158BD of the Act. The said provision is a machinery provision and inserted in the statute book for the purpose of carrying out assessments of a person other than the searched person under Sections 132 or 132A of the Act. Under Section 158BD of the Act, if an officer is satisfied that there exists any undisclosed income which may belong to a other person other than the searched person under Sections 132 or 132A of the Act, after recording such satisfaction, may transmit the records/documents/chits/papers etc to the assessing officer having jurisdiction over such other person. After receipt of the aforesaid satisfaction and upon examination of the said other documents relating to such other person, the jurisdictional assessing officer may proceed to issue a notice for the purpose of completion of the assessments under Section 158BD of the Act, the other provisions of XIV-B shall apply. 39. The opening words of Section 158BD of the Act are that the assessing officer must be satisfied that "undisclosed income" belongs to any other person other than the person with respect to whom a search was made under Section 132 of the Act or a requisition of books were made under Section 132A of the Act and thereafter, transmit the records for assessment of such other person. Therefore, the short question that falls for our consideration and decision is at what stage of the proceedings should the satisfaction note be prepared by the assessing officer: whether at the time of initiating proceedings under Section 158BC for the completion of the assessments of the searched person under Section 132 and 132A of the Act or during the course of the assessment proceedings under Section 158BC of the Act or after completion of the proceedings under Section 158BC of the Act. 40. The Tribunal and the High Court are of the opinion that it could only be prepared by the assessing officer during the course of the assessment proceedings under Section 158BC of the Act and not after the completion of the said proceedings. The Courts below have relied upon the limitation period provided in Section 158BE(2)(b) of the Act in respect of the assessment proceedings initiated under Section 158BD, i.e., two years from the end of the month in which the notice under Chapter XIV-B was served on such other person in respect of search initiated or books of account or other documents or any assets are requisitioned on or after 01.01.1997. We would examine whether the Tribunal or the High Court are justified in coming to the aforesaid conclusion. 41. We would certainly say that before initiating proceedings under Section 158BD of the Act, the assessing officer who has initiated proceedings for completion of the assessments under Section 158BC of the Act should be satisfied that there is an undisclosed income which has been traced out when a person was searched under Section 132 or the books of accounts were requisitioned under Section 132A of the Act. This is in contrast to the provisions of Section 148 of the Act

where recording of reasons in writing are a sine qua non. Under Section 158BD the existence of cogent and demonstrative material is germane to the assessing officers' satisfaction in concluding that the seized documents belong to a person other than the searched person is necessary for initiation of action under Section 158BD. The bare reading of the provision indicates that the satisfaction note could be prepared by the assessing officer either at the time of initiating proceedings for completion of assessment of a searched person under Section 158BC of the Act or during the stage of the assessment proceedings. It does not mean that after completion of the assessment, the assessing officer cannot prepare the satisfaction note to the effect that there exists income tax belonging to any person other than the searched person in respect of whom a search was made under Section 132 or requisition of books of accounts were made under Section 132A of the Act. The language of the provision is clear and unambiguous. The legislature has not imposed any embargo on the assessing officer in respect of the stage of proceedings during which the satisfaction is to be reached and recorded in respect of the person other than the searched person. 42. Further, Section 158BE(2)(b) only provides for the period of limitation for completion of block assessment under section 158BD in case of the person other than the searched person as two years from the end of the month in which the notice under this Chapter was served on such other person in respect of search carried on after 01.01.1997. The said section does neither provides for nor imposes any restrictions or conditions on the period of limitation for preparation the satisfaction note under Section 158BD and consequent issuance of notice to the other person. 43. In the lead case, the assessing officer had prepared a satisfaction note on 15.07.2005 though the assessment proceedings in the case of a searched person, namely, S.K. Bhatia were completed on 30.03.2005. As we have already noticed, the Tribunal and the High Court are of the opinion that since the satisfaction note was prepared after the proceedings were completed by the assessing officer under Section 158BC of the Act which is contrary to the provisions of Section 158BD read with Section 158BE(2)(b) and therefore, have dismissed the case of the Revenue. In our considered opinion, the reasoning of the learned Judges of the High Court is contrary to the plain and simple language employed by the legislature under Section 158BD of the Act which clearly provides adequate flexibility to the assessing officer for recording the satisfaction note after the completion of proceedings in respect of the searched person under Section 158BC. Further, the interpretation placed by the Courts below by reading into the plain language of Section 158BE(2)(b) such as to extend the period of limitation to recording of satisfaction note would run counter to the avowed object of introduction of Chapter to provide for cost- effective, efficient and expeditious completion of search assessments and avoiding or reducing long drawn proceedings. 44. In the result, we hold that for the purpose of Section 158BD of the Act a satisfaction note is sine qua non and must be prepared by the assessing officer before he transmits the records to the other assessing officer who has jurisdiction over such other person. The satisfaction note could be prepared at either of the following stages: (a) at the time of or along with the initiation of proceedings against the searched person under Section 158BC of the Act; (b) along with the assessment proceedings under Section 158BC of the Act; and (c) immediately after the assessment proceedings are completed under Section 158BC of the Act of the searched person.

45. We are informed by Shri Santosh Krishan, who is appearing in seven of the appeals that the assessing officer had not recorded the satisfaction note as required under Section 158BD of the Act, therefore, the Tribunal and the High Court were justified in setting aside the orders of assessment and the orders passed by the first appellate authority. We do not intend to examine the aforesaid contention canvassed by the learned counsel since we are remanding the matters to the High Court for consideration of the individual cases herein in light of the observations made by us on the scope and possible interpretation of Section 158BD of the Act. 46. With these observations, the appeals are disposed of. The matters are remanded to the respective High Courts for deciding the matters afresh after affording an opportunity of hearing to the parties. Ordered accordingly.In C.A.NO.3959 OF 2014 @ S.L.P.(C)NO.11943 of 2011C.A.NO.3960 OF 2014 @ S.L.P.(C)NO.17662 of 2011C.A.NO.3961 OF 2014 @ S.L.P.(C)NO.17656 of 2011C.A.NO.3962 OF 2014 @ S.L.P.(C)NO.17661 of 2011C.A.NO.3963 OF 2014 @ S.L.P.(C)NO.2804 of 2012C.A.NO.3964 OF 2014 @ S.L.P.(C)NO.2805 of 2012C.A.NO.3965 OF 2014 @ S.L.P.(C)NO.5264 of 2012C.A.NO.3966 OF 2014 @ S.L.P.(C)NO.5265 of 2012C.A.NO.3967 OF 2014 @ S.L.P.(C)NO.5266 of 2012C.A.NO.3968 OF 2014 @ S.L.P.(C)NO.7574 of 2012C.A.NO.3969 OF 2014 @ S.L.P.(C)NO.7575 of 2012C.A.NO.3970 OF 2014 @ S.L.P.(C)NO.7576 of 2012C.A.NO.3971 OF 2014 @ S.L.P.(C)NO.7577 of 2012C.A.NO.3972 OF 2014 @ S.L.P.(C)NO.9721 of 2012C.A.NO.3973 OF 2014 @ S.L.P.(C)NO.11460 of 2012C.A.NO.3974 OF 2014 @ S.L.P.(C)NO.12111 of 2012C.A.NO.3975 OF 2014 @ S.L.P.(C)NO.12886 of 2012C.A.NO.3976 OF 2014 @ S.L.P.(C)NO.12887 of 2012C.A.NO.3977 OF 2014 @ S.L.P.(C)NO.15207 of 2012C.A.NO.3978 OF 2014 @ S.L.P.(C)NO.15209 of 2012C.A.NO.3979 OF 2014 @ S.L.P.(C)NO.16266 of 2012C.A.NO.3980 OF 2014 @ S.L.P.(C)NO.16265 of 2012C.A.NO.3981 OF 2014 @ S.L.P.(C)NO.16319 of 2012C.A.NO.3982 OF 2014 @ S.L.P.(C)NO.16782 of 2012C.A.NO.3983 OF 2014 @ S.L.P.(C)NO.19491 of 2012C.A.NO.3984 OF 2014 @ S.L.P.(C)NO.19492 of 2012C.A.NO.3985 OF 2014 @ S.L.P.(C)NO.20626 of 2012C.A.NO.3986 OF 2014 @ S.L.P.(C)NO.21459 of 2012C.A.NO.3987 OF 2014 @ S.L.P.(C)NO.21460 of 2012C.A.NO.3988 OF 2014 @ S.L.P.(C)NO.30192 of 2012C.A.NO.3989 OF 2014 @ S.L.P.(C)NO.36559 of 2012C.A.NO.3990 OF 2014 @ S.L.P.(C)NO.12130 of 2013 AND WITH C.A.NO.3991 OF 2014 @ S.L.P.(C)NO.15368 of 2013: In view of the order passed in Civil Appeal @ S.L.P.(C)No.10542 of2011, these appeals are also disposed of in the same terms, conditions,observations and directions contained therein.Ordered accordingly.

S.L.P.(C)No.7741/2013: De-tag and list separately. Ordered accordingly. .......................J. (H.L. DATTU) .......................J. (S.A. BOBDE)NEW DELHI;MARCH 12, 2014ITEM NO.2(P.H.) COURT NO.3 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011(From the judgement and order dated 20/07/2010 in ITA No.154/2010 of theHIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH)COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITH SLP(C) NO. 11460 of 2012SLP(C) NO. 12111 of 2012SLP(C) NO. 12886 of 2012SLP(C) NO. 12887 of 2012SLP(C) NO. 15207 of 2012SLP(C) NO. 15209 of 2012SLP(C) NO. 16319 of 2012SLP(C) NO. 16782 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 11943 of 2011(With office report)

SLP(C) NO. 15368 of 2013(With office report)SLP(C) NO. 16265 of 2012(With office report)SLP(C) NO. 16266 of 2012SLP(C) NO. 21459 of 2012SLP(C) NO. 30192 of 2012SLP(C) NO. 36559 of 2012SLP(C) NO. 12130 of 2013(With appln.(s) for c/delay in filing and refiling SLP and office report)SLP(C) NO. 17656 of 2011SLP(C) NO. 19491 of 2012SLP(C) NO. 19492 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 17661 of 2011SLP(C) NO. 20626 of 2012SLP(C) NO. 21460 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 2804 of 2012(With office report)SLP(C) NO. 2805 of 2012(With office report)SLP(C) NO. 5264 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 5265 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 5266 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 7574 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 7575 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 7576 of 2012SLP(C) NO. 7577 of 2012SLP(C) NO. 9721 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 7741 of 2013(With appln.(s) for permission to file addl.documents and office report)Date: 12/03/2014 These Petitions were called on for hearing today.

CORAM : HON'BLE MR. JUSTICE H.L. DATTU HON'BLE MR. JUSTICE S.A. BOBDEFor Petitioner(s) Mr.Rupesh Kumar, Adv. Mr.Arijit Prasad, Adv. Ms.Gargi Khanna, Adv. Mrs Anil Katiyar, Adv. For Mr. B.V. Balaram Das,Adv. Mr.Ajay Vohra, Adv. Mr.Rishi Kr.Duggar, Adv. Ms. Kavita Jha,Adv. Mr.Mahesh Agarwal, Adv. Mr.Abhinav Agrawal, Adv. For Mr. E.C. Agrawala, Adv.For Respondent(s) Ms. Sandhya Goswami, Adv. Mr.Divya Suri, Adv. Mr.D.K.GOyal, Adv. Mr.M.K.Choudhary, Adv. For Ms. Namita Choudhary, Adv. Mr.P.N.Monga, Adv. Mr.Manu Monga, Adv. Mr.S.S.Ray, Adv. Mr.Vaibhav G., Adv. For Ms. Rakhi Ray, Adv. Mr.Salil Kapoor, Adv. Mr.Vikas Jain, Adv. Ms.Hardeep Kaur, Adv. For Mr. Kamal Mohan Gupta, Adv. Dr.Rakesh Gupta, Adv. Mr.Rishabh Kapoor, Adv. Ms.Rani Kiyala, Adv. Mr. Ambhoj Kumar Sinha, Adv. Mrs Anil Katiyar, Adv. Mr.R.P.Bhatt, Sr.Adv. Mr. H.Raghavendra Rao, Adv. Mr.Anupam Tripathi, Adv. Mr.Puneet Kapur, Adv. Mr.Govind K.Chaturvedi, Adv. For Mr. Nikhil Jain, Adv. UPON hearing counsel the Court made the following O R D E R

SLP(C)No.7741/2013: De-tag and list separately.Rest of the matters: Delay, if any, in filing and refiling the Special Leave Petitions iscondoned. Leave granted. Appeals are disposed of, in terms of the reportable signed order. (G.V.Ramana) (Vinod Kulvi) Court Master Asstt.Registrar (Reportable signed order is placed on the file)

È, ITEM NO. 4 COURT NO.3 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS Petition(s) for Special Leave to Appeal (Civil) No(s).10542/2011 (From the judgement and order dated 20/07/2010 in ITA No.154/2010 of The HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH) COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUS M/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s) WITHSLP(C)No.11943/2011 (WITH OFFICE REPORT)SLP(C)No.17662/2011 (WITH OFFICE REPORT)SLP(C)No.17656/2011(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.17661/2011(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.2804/2012 (WITH OFFICE REPORT)SLP(C)No.2805/2012 (WITH OFFICE REPORT)SLP(C)No.5264/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.5265/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.5266/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.7574/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.7575/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.7576/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.7577/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.9721/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.11460/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.12111/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.12886/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.12887/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.15207/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.15209/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.16266/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND C/DELAY INREFILING SLP AND OFFICE REPORT)

SLP(C)No.16265/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.16319/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.16782/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.19491/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.19492/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.20626/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.21459/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND C/DELAY INREFILING SLP AND OFFICE REPORT)SLP(C)No.21460/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND OFFICE REPORT)SLP(C)No.30192/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND C/DELAY INREFILING SLP AND OFFICE REPORT)SLP(C)No.36559/2012(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND C/DELAY INREFILING SLP AND OFFICE REPORT)SLP(C)No.12130/2013(WITH APPLN.(S) FOR C/DELAY IN FILING SLP AND C/DELAY INREFILING SLP AND OFFICE REPORT)SLP(C)No.15368/2013 (WITH OFFICE REPORT)SLP(C)No.7741/2013(WITH APPLN.(S) FOR PERMISSION TO FILE ADDITIONAL DOCUMENTS ANDOFFICE REPORT) Date: 06/03/2014 This Petition was called on for hearing today. CORAM : HON'BLE MR. JUSTICE H.L. DATTU HON'BLE MR. JUSTICE S.A. BOBDE For Petitioner(s)/ Mr. Rupesh Kumar, Adv. Respondent(s) Mr. Arijit Prasad, Adv. Mr. B.V. Balaram Das,Adv. Mrs. Anil Katiyar, Adv. For Petitioner(s) Mr. Ajay Vohra, Adv. Mr. Rishi Kumar, Adv. Mr. Ankur Saigal, Adv. Mr. Mahesh Agarwal, Adv. Mr. Rishi Agrawala, Adv. Mr. E.C. Agrawala, Adv. Mr. Abhinav Agrawal, Adv. For Respondent(s) Mr. Ajay Vohra, Adv. Ms. Kavita Jha,Adv. Ms. Sandhya Goswami, Adv. Mr. Pankaj Jain, Sr. Adv. Mr. Divya Suri, Adv.

Ms. Namita Choudhary, Adv. Mr. D.K. Goyal, Adv. Mr. M.K. Chaudhary, Adv. Mr. Anupam Tripathi, Adv. Mr. Puneet Kapur, Adv. Mr. Nikhil Jain, Adv. Mr. Kamal Mohan Gupta, Adv. Mr. Ambhoj Kumar Sinha, Adv. Mr. P.N. Monga, Adv. Mr. Manu Monga, Adv. Mr. S.s. Ray, Adv. Mr. Vaibhav, Adv. Ms. Rakhi Ray, Adv. Mr. H.Raghavendra Rao, Adv. Mr. Salil Kapoor, Adv. Mr. Sanat Kapoor, Adv. Mr. Vikas Jain, Adv. Mr. Ankit Gupta, Adv. UPON hearing counsel the Court made the following O R D E R List the matter on 12.03.2014 as part heard. To be listed as a first case. | [ Charanjeet Kaur ] | | [ Vinod Kulvi ] ||Court Master | |Asstt. Registrar |

<"ITEM NO.3 COURT NO.3 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011(From the judgement and order dated 20/07/2010 in ITA No.154/2010 of theHIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH)COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITH SLP(C) NO. 11460 of 2012SLP(C) NO. 12111 of 2012SLP(C) NO. 12886 of 2012SLP(C) NO. 12887 of 2012SLP(C) NO. 15207 of 2012SLP(C) NO. 15209 of 2012SLP(C) NO. 16319 of 2012SLP(C) NO. 16782 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 11943 of 2011(With office report)SLP(C) NO. 15368 of 2013(With office report)SLP(C) NO. 16265 of 2012(With office report)SLP(C) NO. 16266 of 2012SLP(C) NO. 21459 of 2012SLP(C) NO. 30192 of 2012SLP(C) NO. 36559 of 2012SLP(C) NO. 12130 of 2013(With appln.(s) for c/delay in filing and refiling SLP and office report)SLP(C) NO. 17656 of 2011SLP(C) NO. 19491 of 2012SLP(C) NO. 19492 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 17661 of 2011SLP(C) NO. 20626 of 2012SLP(C) NO. 21460 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 2804 of 2012(With office report)SLP(C) NO. 2805 of 2012(With office report)SLP(C) NO. 5264 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 5265 of 2012(With appln.(s) for c/delay in filing SLP and office report)

SLP(C) NO. 5266 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 7574 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 7575 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 7576 of 2012SLP(C) NO. 7577 of 2012SLP(C) NO. 9721 of 2012(With appln.(s) for c/delay in filing SLP and office report)SLP(C) NO. 7741 of 2013(With appln.(s) for permission to file addl.documents and office report)Date: 25/02/2014 These Petitions were called on for hearing today.CORAM : HON'BLE MR. JUSTICE H.L. DATTU HON'BLE MR. JUSTICE S.A. BOBDEFor Petitioner(s) Mr.Rupesh Kumar, Adv. Mr.Arijit Prasad, Adv. Ms.Gargi Khanna, Adv. Mrs Anil Katiyar, Adv. For Mr. B.V. Balaram Das,Adv. Mr.Ajay Vohra, Adv. Mr.Rishi Kr.Duggar, Adv. Ms. Kavita Jha,Adv. Mr.Mahesh Agarwal, Adv. Mr.Abhinav Agrawal, Adv. For Mr. E.C. Agrawala, Adv.For Respondent(s) Ms. Sandhya Goswami, Adv. Mr.Divya Suri, Adv. Mr.D.K.GOyal, Adv. Mr.M.K.Choudhary, Adv. For Ms. Namita Choudhary, Adv. Mr.P.N.MOnga, Adv. Mr.Manu Monga, Adv. Mr.S.S.Ray, Adv. Mr.Vaibhav G., Adv. For Ms. Rakhi Ray, Adv. Mr.Salil Kapoor, Adv. Mr.Vikas Jain, Adv. Ms.Hardeep Kaur, Adv. For Mr. Kamal Mohan Gupta, Adv. Dr.Rakesh Gupta, Adv. Mr.Rishabh Kapoor, Adv. Ms.Rani Kiyala, Adv. Mr. Ambhoj Kumar Sinha, Adv. Mrs Anil Katiyar, Adv. Mr.R.P.Bhatt, Sr.Adv. Mr. H.Raghavendra Rao, Adv. Mr.Anupam Tripathi, Adv.

Mr.Puneet Kapur, Adv. Mr.Govind K.Chaturvedi, Adv. For Mr. Nikhil Jain, Adv. UPON hearing counsel the Court made the following O R D E R At the request of learned counsel for the Revenue, call the matterson 6th March, 2014. (G.V.Ramana) (Vinod Kulvi) Court Master Asstt.Registrar

jITEM NO.15 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.K.HANJURAPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITH SLP(C) NO. 11460 of 2012(With office report)SLP(C) NO. 11943 of 2011(With office report)SLP(C) NO. 12111 of 2012(With office report)SLP(C) NO. 12130 of 2013(With office report)SLP(C) NO. 12886 of 2012(With office report)SLP(C) NO. 12887 of 2012(With office report)SLP(C) NO. 15207 of 2012(With office report)SLP(C) NO. 15209 of 2012(With office report)SLP(C) NO. 15368 of 2013(With office report)SLP(C) NO. 16265 of 2012(With office report)SLP(C) NO. 16266 of 2012(With office report)SLP(C) NO. 16319 of 2012(With office report)SLP(C) NO. 16782 of 2012(With office report)SLP(C) NO. 17656 of 2011(With office report)SLP(C) NO. 17661 of 2011(With office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 19491 of 2012(With office report)SLP(C) NO. 19492 of 2012(With office report)SLP(C) NO. 20626 of 2012(With office report)SLP(C) NO. 21459 of 2012(With office report) -2-Item No.15SLP(C) NO. 21460 of 2012(With office report)SLP(C) NO. 2804 of 2012(With office report)SLP(C) NO. 2805 of 2012

(With office report)SLP(C) NO. 30192 of 2012(With office report)SLP(C) NO. 36559 of 2012(With office report)SLP(C) NO. 5264 of 2012(With office report)SLP(C) NO. 5265 of 2012(With office report)SLP(C) NO. 5266 of 2012(With office report)SLP(C) NO. 7574 of 2012(With office report)SLP(C) NO. 7575 of 2012(With office report)SLP(C) NO. 7576 of 2012(With office report)SLP(C) NO. 7577 of 2012(With office report)SLP(C) NO. 7741 of 2013(With office report)SLP(C) NO. 9721 of 2012(With office report)Date: 13/12/2013 This Petition was called on for hearing today.For Petitioner(s) Mr. B.V. Balaram Das,Adv. Ms Neha Agarwal, Adv. Mr. E.C. Agrawala,Adv. Mr Y.P.Mahajan, Adv. Mrs Anil Katiyar,Adv.For Respondent(s) Ms. Kavita Jha,Adv. Ms. Sandhya Goswami,Adv. Ms. Namita Choudhary,Adv. Ms. Rakhi Ray,Adv. Mr. Kamal Mohan Gupta,Adv. Mr. Ambhoj Kumar Sinha,Adv. Mrs Anil Katiyar,Adv. Mr. H.Raghavendra Rao,Adv. Mr. Nikhil Jain,Adv. -3-Item No.15 UPON hearing counsel the Court made the following O R D E RSLP(C) NO.2804/2012 The ld. Counsel for the petitioner is present. He seeks two weeks'time to file the process fee and the spare copies of the SLP. Time asprayed for is granted as last chance. In case the requisites are filed within the period stipulatedabove, in that event appropriate steps for the service of notice to thesole respondent shall be taken by the registry. List again on 28.1.2014.REMAINING MATTERS Deleted.| | |(M.K.HANJURA) |

| | |REGISTRAR |hj

ITEM NO.16 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).15368/2013C.I.T DELHI-XVII Petitioner(s) VERSUSRASHMI MONGA Respondent(s)(With office report)Date: 13/11/2013 This Petition was called on for hearing today.For Petitioner(s) Mr. Anil Kumar Sharma, Adv. Mrs Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R For want of process fee and spare copies, notice could not be issuedto the sole respondent. The office report in default be placed before the Hon'ble Judge inChambers for necessary orders/directions.| | | (M.A. SAYEED) || | |REGISTRAR || | | |rd

üITEM NO.21 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).15368/2013C.I.T DELHI-XVII Petitioner(s) VERSUSRASHMI MONGA Respondent(s)(With office report )Date: 25/09/2013 This Petition was called on for hearing today.For Petitioner(s) Ms Sudha Pal, Adv. Mrs Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Notice be reissued to the sole respondent through the concernedDistrict Court in addition to postal service. List again on 15.11.2013.| | |(M.A.SAYEED) || | |REGISTRAR |hj

¼ITEM NO.15 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).17662/2011C.I.T KOLHAPUR Petitioner(s) VERSUSRAMCHANDRA MAHADEO PATIL Respondent(s)(With office report )WITHSLP(C) NO.17656/2011SLP(C) NO.2805/2012SLP(C) NO.5264/2012SLP(C) NO.5265/2012SLP(C) NO.5266/2012SLP(C) NO.7574/2012SLP(C) NO.7575/2012SLP(C) NO.7576/2012SLP(C) NO.7577/2012SLP(C) NO.9721/2012SLP(C) NO.11460/2012SLP(C) NO.12111/2012SLP(C) NO.12886/2012SLP(C) NO.12887/2012SLP(C) NO.15207/2012SLP(C) NO.15209/2012SLP(C) NO.16266/2012SLP(C) NO.16265/2012SLP(C) NO.16319/2012SLP(C) NO.16782/2012SLP(C) NO.19491/2012SLP(C) NO.19492/2012SLP(C) NO.20626/2012SLP(C) NO.21459/2012SLP(C) NO.21460/2012SLP(C) NO.30192/2012SLP(C) NO.36559/2012SLP(C) NO.15368/2013Date: 23/09/2013 This Petition was called on for hearing today.For Petitioner(s) Mr Arvind Kumar Tiwary, Adv. Mr. B.V. Balaram Das,Adv. Mrs Anil Katiyar, Adv.For Respondent(s) Mr Nikhil Jain, Adv. Mr Pramod Kr Singh, Adv. Mr Kamal Mohan Gupta, Adv. -2-Item No.15 Mr Jabar Singh, Adv. Ms Sandhya Goswami, Adv. Mr Ambhoj Kumar Sinha, Adv. Ms Rakhi Ray, Adv. Mr H Raghavendra Rao, Adv.

UPON hearing counsel the Court made the following O R D E RSLP(C) NO.17662,17656 of 2011, 5264, 5265, 7575, 12111,12887,16265,16266,21459,36559 of 2012 In these batch of matters, sole respondent is reported to be dulyserved but none appeared on his behalf. However further necessary orders would be passed as and when otherconnected matters would become ready.SLP(C) NO.9721,12886,15207,15209,16319,19491,19492,20626, 30192 of 2012 Sole respondent has failed to file counter affidavit despite finalchance granted on the last date. However further necessary orders would be passed as and when otherconnected matters would become ready.SLP(C) NO.2805,5266,7574,7576,11460,16782, 21460,7577 of 2012 Matters are complete in all respects. However further necessary orders would be passed as and when otherconnected matters would become ready.SLP(C) NO.15368/2013 Notice be re issued to the sole respondent through the concernedDistrict Court in addition to postal service. List again on 13.11.2013.| | |(M.A.SAYEED) || | |REGISTRAR |hj

ÎITEM NO.22 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).17662/2011C.I.T KOLHAPUR Petitioner(s) VERSUSRAMCHANDRA MAHADEO PATIL Respondent(s)(With office report )WITHSLP(C) NO.17656/2011SLP(C) NO.2805/2012SLP(C) NO.5264/2012SLP(C) NO.5265/2012SLP(C) NO.5266/2012SLP(C) NO.7574/2012SLP(C) NO.7575/2012SLP(C) NO.7576/2012SLP(C) NO.7577/2012SLP(C) NO.9721/2012SLP(C) NO.11460/2012SLP(C) NO.12111/2012SLP(C) NO.12886/2012SLP(C) NO.12887/2012SLP(C) NO.15207/2012SLP(C) NO.15209/2012SLP(C) NO.16266/2012SLP(C) NO.16265/2012SLP(C) NO.16319/2012SLP(C) NO.16782/2012SLP(C) NO.19491/2012SLP(C) NO.19492/2012SLP(C) NO.20626/2012SLP(C) NO.21459/2012SLP(C) NO.21460/2012SLP(C) NO.30192/2012SLP(C) NO.36559/2012SLP(C) NO.12130/2013SLP(C) NO.15368/2013Date: 21/08/2013 This Petition was called on for hearing today.For Petitioner(s) Mr Soumen Talukdar, Adv. Mr. B.V. Balaram Das,Adv. Mrs Anil Katiyar, Adv. -2-Item No.22For Respondent(s) Mr Kamal Mohan Gupta, Adv. Mr Jabar Singh, Adv. Ms Sandhya Goswami, Adv.

Ms Rakhi Ray, Adv. Mr H Raghavendra Rao, Adv. Mr Ambhoj Kumar Sinha, Adv. Mr Nikhil Jain, Adv. UPON hearing counsel the Court made the following O R D E RSLP(C) NO.12130/2013 Sole respondent is reported to be duly served through post but noneappeared on his behalf. However, further necessary orders would be passed as and when otherconnected matters would become ready.SLP(C) NO.15368/2013 Service report in respect of the sole respondent is awaited (issuedon 13.5.2013).REMAINING MATTERS In these batch of matters, status/position of the respondents havebeen shown in the tabular chart. In all these batch of matters, service is complete on the solerespondent. Counter affidavit in some of the matters has been filed while insome matters, they are reported to have not been filed on record. In all these batch of matters, sole respondent is granted threeweeks' time as final chance for filing counter affidavit. -3-Item No.22 The ld. Counsel, Mr Ambhoj Kumar Sinha has made a submission at Barthat in SLP(C) No.7577/2012 though the office report indicates that nocounter affidavit has been filed but in fact he has filed the same about ayear back i.e., on 11.9.2012 and that he has the necessary proof withhim. Registry to ascertain, verify and submit a proper report by next date. List again on 23.9.2013.| | |(M.A.SAYEED) || | |REGISTRAR |hj

\200ITEM NO.50 COURT NO.12 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil) No(s).2804/2012(From the judgement and order dated 30/05/2011 in ITA No.777/2010 of TheHIGH COURT OF DELHI AT N. DELHI)C.I.T.,NEW DELHI-VIII Petitioner(s) VERSUSGALLARI DEVI Respondent(s)(Office Report on Default)Date: 24/07/2013 This Petition was called on for hearing today.CORAM : HON'BLE MR. JUSTICE VIKRAMAJIT SEN (IN CHAMBERS)For Petitioner(s) Ms. Shilpi Satyapriya Satyam, Adv. Mrs Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue fresh notice to the respondent, returnable after four weeks.|(Sheetal Dhingra) | |(Usha Sharma) ||AR-cum-PS | |Court Master |

fITEM NO.18 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).17662/2011C.I.T KOLHAPUR Petitioner(s) VERSUSRAMCHANDRA MAHADEO PATIL Respondent(s)(With office report)withSLP(C) Nos.17656/2011,2805,5264 to 5266,7574 to 7577/2012,9721,11460,12111,12886,12887,15207,15209,16265,16266,16319,16782,19491,19492,20626,21459-60,30192,36559/2012 and 12130/2013(with office report)Date: 18/07/2013 This Petition was called on for hearing today.For Petitioner(s) Mr. B.V. Balaram Das,Adv. Ms. Anil Katiyar, Adv.For Respondent(s) Ms. Ruchi Kohli, Adv. Mr. Mohd. Zahid Hussain, Adv. Mr. Kamal Mohan Gupta, Adv. Mr. Jabar Singh, Adv. Ms. Sandhya Goswami, Adv. Mr. Vaibhav Gulia, Adv. Ms. Rakhi Ray, Adv. Mr. Bijendra Singh, Adv. Mr. H. Raghavendra Rao, Adv. Mr. Ambhoj Kr. Sinha, Adv. UPON hearing counsel the Court made the following O R D E R In these batch of matters, as per the status shown in the TabularChart in the office report, counter affidavit on behalf of the solerespondent has not been filed on record, despite final chance granted onthe last date, barring SLP(C)Item No.18 -2-Nos.15207, 15209, 16319, 19491, 19492, 20626 and 30192, wherein the learnedAdvocate, Mr.Bijendra Singh, appearing on behalf of Mr.H.Raghavendra Raofor the sole respondent has made a submission at Bar that no counteraffidavit is required to be filed on record. It would not be out of place to mention here that counter affidavithas been filed only in SLP(C) No.7574/2012. Further necessary orders, in these batch of matters, to be passed asand when the other connected matters would become ready.SLP(C) No.12130/2013 Sole respondent is reported to be duly and properly served throughpost but no one has put appearance on his behalf. List again on 21.8.2013.| | | (M.A. SAYEED) || | |REGISTRAR || | | |rd

ØITEM NO.17 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).17661/2011C.I.T Petitioner(s) VERSUSMRIDULA PROP.M/S DHRUV FABRICS Respondent(s)(With appln(s) for c/delay in filing SLP and office report )WITHSLP(C) NO.2805/2012SLP(C) NO.5264/2012SLP(C) NO.5265/2012SLP(C) NO.5266/2012SLP(C) NO.7574/2012SLP(C) NO.7575/2012SLP(C) NO.7576/2012SLP(C) NO.7577/2012SLP(C) NO.9721/2012SLP(C) NO.11460/2012SLP(C) NO.12111/2012SLP(C) NO.12886/2012SLP(C) NO.12887/2012SLP(C) NO.15207/2012SLP(C) NO.15209/2012SLP(C) NO.16266/2012SLP(C) NO.16265/2012SLP(C) NO.16319/2012SLP(C) NO.16782/2012SLP(C) NO.19491/2012SLP(C) NO.19492/2012SLP(C) NO.20626/2012SLP(C) NO.21459/2012SLP(C) NO.21460/2012SLP(C) NO.30192/2012SLP(C) NO.36559/2012SLP(C) NO.12130/2013SLP(C) NO.15368/2013SLP(C) NO.17662/2011SLP(C) NO.17656/2011Date: 10/05/2013 This Petition was called on for hearing today.For Petitioner(s) Mr. B.V. Balaram Das,Adv. Ms D Geetha, Adv. Mrs Anil Katiyar, Adv. -2-Item No.17For Respondent(s) Ms. Kavita Jha,Adv. Mr Jabar Singh, Adv. Ms Sandhya Goswami, Adv. Mr Mohd. Zahid Hussain, Adv. Mr Kamal Mohan Gupta, Adv.

Mr Ambhoj Kumar Sinha, Adv. Ms Ruchi Kohli, Adv. Mr Vaibhav Gulia, Adv. Ms Rakhi Ray, Adv. Mr H Raghavendra Rao, Adv. UPON hearing counsel the Court made the following O R D E RSLP(C) NO.17661/2011, 15368/2013 Deleted.SLP(C) NO.36559/2012, 12130/2013 In these two matters, service report in respect of the solerespondent is awaited from the concerned District court. Reminder beissued. As per status given in the office report in the matters of theyears 2011 and 2012, service is complete and the sole respondent have notyet filed counter affidavit. Three weeks' time is granted as final chance. List again on 18.7.2013.| | |(M.A.SAYEED) || | |REGISTRAR |hj

.ITEM NO.1 COURT NO.5 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012 CC 20449/2012(From the judgement and order dated 30/05/2011 in ITA No.1145/2010 of TheHIGH COURT OF DELHI AT N. DELHI)C.I.T DELHI-XVII Petitioner(s) VERSUSRASHMI MONGA Respondent(s)With IA 1 ( c/delay in filing SLP,c/delay in refiling SLP and office report)Date: 16/04/2013 This Petition was called on for hearing today.CORAM : HON'BLE MR. JUSTICE R.M. LODHA HON'BLE MR. JUSTICE MADAN B. LOKUR HON'BLE MR JUSTICE KURIAN JOSEPHFor Petitioner(s) Mr. Mohan Parasaran, SG Mr. Gaurav Dhingra, Adv. Ms. A. Subashini, Adv. for Mrs Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Delay condoned. Issue notice. Connect with S.L.P. (C) No. 2804 of 2012 - C.I.T., New Delhi-VIII vs. Gallari Devi.|(Pardeep Kumar) | |(Renu Diwan) ||Court Master | |Court Master |

vITEM NO.8 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).17662/2011C.I.T KOLHAPUR Petitioner(s) VERSUSRAMCHANDRA MAHADEO PATIL Respondent(s)(With office report )WITHSLP(C) NO.17656/2011SLP(C) NO.2805/2012SLP(C) NO.5264/2012SLP(C) NO.5265/2012SLP(C) NO.5266/2012SLP(C) NO.7574/2012SLP(C) NO.7575/2012SLP(C) NO.7576/2012SLP(C) NO.7577/2012SLP(C) NO.9721/2012SLP(C) NO.11460/2012SLP(C) NO.12111/2012SLP(C) NO.12886/2012SLP(C) NO.12887/2012SLP(C) NO.15207/2012SLP(C) NO.15209/2012SLP(C) NO.16266/2012SLP(C) NO.16265/2012SLP(C) NO.16319/2012SLP(C) NO.16782/2012SLP(C) NO.19491/2012SLP(C) NO.19492/2012SLP(C) NO.20626/2012SLP(C) NO.21459/2012SLP(C) NO.21460/2012SLP(C) NO.30192/2012SLP(C) NO.36559/2012SLP(C) NO.12130/2013Date: 11/04/2013 This Petition was called on for hearing today.For Petitioner(s) Mr. B.V. Balaram Das,Adv. Mrs Anil Katiyar, Adv.For Respondent(s) Mr Bijender Singh, Adv. Mr H Raghavendra Rao, Adv. Ms Ruchi Kohli, Adv. -2-Item No.8 Mr Mohd. Zahid Hussain, Adv. Mr Kamal Mohan Gupta, Adv. Ms Sandhya Goswami, Adv. Mr Ambhoj Kumar Sinha, Adv. Mr Vaibhav Gulia, Adv. Ms Rakhi Ray, Adv.

UPON hearing counsel the Court made the following O R D E R In the first group of matters of the year 2011, sole respondenthave failed to file counter affidavit within the time granted by the Courtas reflected from the office report. However, further necessary orders would be passed as and when otherconnected matters would become ready. In the second batch of matters of the year 2012, barring SLP(C) No.11460/2012, counter affidavits have not been filed in all other matters.Four weeks' time is granted to the sole respondents for the same. SLP(C) no. 2804/2012 is to be placed before the Hon'ble Judge inChambers for necessary orders. Registry to take necessary steps.SLP(C) NO.36559/2012, 12130/2012 Office report indicates that process fee and spare copies are to befiled. The ld. Counsel for the petitioner to do the needful within a weekand on compliance notices be issued forthwith through the concernedDistrict Court in addition to postal service. List again on 10.5.2013.| | |(M.A.SAYEED) || | |REGISTRAR |hj

\216 ITEM NO. 29 COURT NO.5 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS Petition(s) for Special Leave to Appeal (Civil)....../2013 CC 5855/2013 (From the judgement and order dated 30/05/2011 in ITA No.857/2009, of The HIGH COURT OF DELHI AT N. DELHI) C.I.T. Petitioner(s) VERSUS H.P. GOEL Respondent(s) WITH I.A. 1 (C/Delay in filing SLP,c/delay in refiling SLP and office report) Date: 18/03/2013 This Petition was called on for hearing today. CORAM : HON'BLE MR. JUSTICE H.L. DATTU HON'BLE MR. JUSTICE JAGDISH SINGH KHEHAR For Petitioner(s) Mr. Gourab Banerji, ASG Mr. Rahul Kaushik, Adv. Mr. T.M. Singh, Adv. Mrs Anil Katiyar,Adv. For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue Notice on the application for condonation of delay as well as on the special leave petition. Tag with SLP(C) No, 21459 of 2012. | [ Charanjeet Kaur ] | | [ Vinod Kulvi ] ||Court Master | |Court Master |

´ITEM NO.19 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).17662/2011C.I.T KOLHAPUR Petitioner(s) VERSUSRAMCHANDRA MAHADEO PATIL Respondent(s)(With office report)withSLP(C) No.17656/2011,2805,5264,5265,5266,7574 to 7577,9721,11460,12111,12886,12887.15207,15209,16265-66,16319,16782,19491-92,20626,21459-60,30192,36559/2012(with office report)Date: 13/03/2013 This Petition was called on for hearing today.For Petitioner(s) Mr. B.V. Balaram Das,Adv. Mr. Ajay Singh, Adv. Ms. Anil Katiyar, Adv.For Respondent(s) Ms. Ruchi Kohli, Adv. Mr. Mohd. Zahid Hussain, Adv. Mr. Kamal Mohan Gupta, Adv. Ms. Sandhya Goswami, Adv. Mr. Ambhoj Kr. Sinha, Adv. Mr. S.S. Ray, Adv. Ms. Rakhi Rey, Adv. Mr. Bijender Singh, Adv. Mr. H. Raghvendra Rao, Adv. Mr. Jabar Singh, Adv. UPON hearing counsel the Court made the following O R D E R The office report indicates that the position of all the batch ofmatters has been given in the Tabular FormItem No.19 -2-wherein in the last column all the matters are shown as complete exceptSLP(C) No.36559/2012, but however, report does not indicate whether counteraffidavit has been filed by the respondents in all the matters. Registry to submit a clear and specific report by the next date. In the meanwhile, respondent in SLP(C) Nos.7577 and 9721 are grantedfinal chance for filing counter affidavit. In SLP(C) No.36559/2012, fresh notice be issued to the solerespondent through the concerned District Court in addition to postalservice. List all the matters again on 11.4.2013.| | | (M.A. SAYEED) || | |REGISTRAR || | | |

rd

˜ITEM NO.99 COURT NO.3 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition for Special Leave to Appeal (Civil) No.2804/2012(From the judgment and order dated 30/05/2011 in ITA No.777/2010 of TheHIGH COURT OF DELHI AT N. DELHI)C.I.T., NEW DELHI-VIII Petitioner(s) VERSUSGALLARI DEVI Respondent(s)(Office Report on Default)Date: 05/02/2013 This Petition was called on for hearing today.CORAM : HON'BLE MR. JUSTICE H.L. GOKHALE (IN CHAMBERS)For Petitioner(s) Mr. Aditya Kr. Choudhary, Adv. Mrs Anil Katiyar, Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Two weeks' more time is granted to the petitioner to file the proof of service.|(VINOD LAKHINA) | |(PHOOLAN WATI ARORA) ||COURT MASTER | |COURT MASTER |

j"ITEM NO.12 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITH SLP(C) NO. 11460 of 2012(With office report)SLP(C) NO. 11943 of 2011(With office report)SLP(C) NO. 12111 of 2012(With office report)SLP(C) NO. 12886 of 2012(With office report)SLP(C) NO. 12887 of 2012(With office report)SLP(C) NO. 15207 of 2012(With office report)SLP(C) NO. 15209 of 2012(With office report)SLP(C) NO. 16265 of 2012(With office report)SLP(C) NO. 16266 of 2012(With office report)SLP(C) NO. 16319 of 2012(With office report)SLP(C) NO. 16782 of 2012(With office report)SLP(C) NO. 17656 of 2011(With office report)SLP(C) NO. 17661 of 2011(With office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 19491 of 2012(With office report)SLP(C) NO. 19492 of 2012(With office report)SLP(C) NO. 20626 of 2012(With office report)SLP(C) NO. 21459 of 2012(With office report)SLP(C) NO. 21460 of 2012(With office report) -2-Item No.12SLP(C) NO. 2805 of 2012(With office report)SLP(C) NO. 30192 of 2012(With office report)SLP(C) NO. 36559 of 2012(With office report)

SLP(C) NO. 5264 of 2012(With office report)SLP(C) NO. 5265 of 2012(With office report)SLP(C) NO. 5266 of 2012(With office report)SLP(C) NO. 7574 of 2012(With office report)SLP(C) NO. 7575 of 2012(With office report)SLP(C) NO. 7576 of 2012(With office report)SLP(C) NO. 7577 of 2012(With office report)SLP(C) NO. 9721 of 2012(With office report)Date: 01/02/2013 This Petition was called on for hearing today.For Petitioner(s) Ms Ritu Bhardwaj, Adv. Mr. B.V. Balaram Das,Adv. Mrs Anil Katiyar, Adv.For Respondent(s) Ms. Kavita Jha,Adv. Mr. H.Raghavendra Rao, Adv. Mr Jabar Singh, Adv. Ms. Sandhya Goswami, Adv. Mr. Ambhoj Kumar Sinha, Adv. Mr Mohd. Zahid Hussain, Adv. Mr. Kamal Mohan Gupta, Adv. Ms. Rakhi Ray, Adv. Ms. Kavita Jha, Adv. Ms. Ruchi Kohli, Adv. Mr Aldanish Rein, Adv. Ms. Namita Choudhary, Adv. UPON hearing counsel the Court made the following O R D E RSLP(C) NO.10542,11943,17661 OF 2011 In these batch of matters, sole respondent has failed to filecounter affidavit within the time granted by the Court. -3-Item No.12 No further steps required to be taken in the matter. However,further necessary orders would be passed as and when other connectedmatters would become ready.SLP(C) NO.17662/2011 Respondent-in-person has appeared but has not filed his memo ofappearance till date. Needful be done by next date.SLP(C) NO.17656/2011 It appears that the respondent has been duly served but none hasappeared on his behalf. Office to submit specific report in this regard onthe next date.SLP(C) NO.2805, 5264, 5265, 5266, 7574, 7575, 7576, 7577,9721,11460,12111,12886,12887,15207,15209,16266,16265,16319,16782,19491,19492,20626,21459,21460,30192 OF 2012 Service is complete. Duly represented respondents in all these batch of matters aregranted four weeks' time for filing counter affidavit.SLP(C) NO.36559/2012 Fresh notice be issued to the sole respondent through the concernedDistrict Court in addition to the postal mode. Necessary steps be taken. List again on 13.3.2013.

| | |(M.A.SAYEED) || | |REGISTRAR |hj

\206!ITEM NO.6 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR M.A. SAYEEDPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITH SLP(C) NO. 11460 of 2012(With office report)SLP(C) NO. 11943 of 2011(With office report)SLP(C) NO. 12111 of 2012(With office report)SLP(C) NO. 12886 of 2012(With office report)SLP(C) NO. 12887 of 2012(With office report)SLP(C) NO. 15207 of 2012(With office report)SLP(C) NO. 15209 of 2012(With office report)SLP(C) NO. 16265 of 2012(With office report)SLP(C) NO. 16266 of 2012(With office report)SLP(C) NO. 16319 of 2012(With office report)SLP(C) NO. 16782 of 2012(With office report)SLP(C) NO. 17656 of 2011(With office report)SLP(C) NO. 17661 of 2011(With office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 19491 of 2012(With office report)SLP(C) NO. 19492 of 2012(With office report)SLP(C) NO. 20626 of 2012(With office report)SLP(C) NO. 21459 of 2012(With office report)SLP(C) NO. 21460 of 2012(With office report)SLP(C) NO. 2804 of 2012(With office report) -2-Item No.6SLP(C) NO. 2805 of 2012(With office report)SLP(C) NO. 30192 of 2012(With office report)SLP(C) NO. 36559 of 2012(With office report)

SLP(C) NO. 5264 of 2012(With office report)SLP(C) NO. 5265 of 2012(With office report)SLP(C) NO. 5266 of 2012(With office report)SLP(C) NO. 7574 of 2012(With office report)SLP(C) NO. 7575 of 2012(With office report)SLP(C) NO. 7576 of 2012(With office report)SLP(C) NO. 7577 of 2012(With office report)SLP(C) NO. 9721 of 2012(With office report)Date: 02/01/2013 This Petition was called on for hearing today.For Petitioner(s) Mr. B.V. Balaram Das,Adv. Ms Anjali Chauhan, Adv. Mrs Anil Katiyar, Adv.For Respondent(s) Ms. Kavita Jha,Adv. Mr Bijendra Singh, Adv. Mr. H.Raghavendra Rao, Adv. Mr Jabar Singh, Adv. Ms. Sandhya Goswami, Adv. Mr. Ambhoj Kumar Sinha, Adv. Mr Siddharth Jain, Adv. Mr. Kamal Mohan Gupta, Adv. Mr S.S.Ray, Adv. Ms. Rakhi Ray, Adv. Ms. Ruchi Kohli, Adv. Mr Manish Kr Choudhary, Adv. Ms. Namita Choudhary, Adv. UPON hearing counsel the Court made the following O R D E RSLP(C) NO.10542/2011 Three weeks' time is granted as final chance to the sole respondentfor filing counter affidavit. -3-Item No.6SLP(C) NO.11943,17661 of 2011 Three weeks' time is granted as final chance for filing counteraffidavit on record.SLP(C) NO.17662/2011 Respondent though appeared in person, has failed to file memo onrecord. Needful be done by next date.SLP(C) NO.17656/2011 Respondent is reported to be duly served through dasti but noneappeared.SLP(C) NO.2804/2012 As per office report, matter be placed before the Hon'ble Judge inChambers for necessary orders/directions.SLP(C) NO.2805, 5264, 5265, 5266,7574,7575, 7576, 7577,9721,11460,12111,12886,12887,15207,15209,16266,16265,16319,16782,19491,19492,20626,21459,21460,30192 of 2012 As per office report, service is complete. Four weeks' time is granted for filing counter affidavit on record.SLP(C) NO.36559/2012 Service report is awaited.

List again on 1.2.2013.| | |(M.A.SAYEED) || | |REGISTRAR |hj

\202ITEM NO.27 COURT NO.2 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition for Special Leave to Appeal (Civil)....../2012 CC 20406/2012(From the judgment and order dated 30/05/2011 in ITA No.196/2010 of TheHIGH COURT OF DELHI AT N. DELHI)C.I.T., NEW DELHI Petitioner(s) VERSUSANU AGGARWAL Respondent(s)WITH I.A. 1 (C/DELAY IN FILING SLP AND C/DELAY IN REFILING SLP AND OFFICEREPORT)Date: 23/11/2012 This Petition was called on for hearing today.CORAM : HON'BLE MR. JUSTICE D.K. JAIN HON'BLE MR. JUSTICE MADAN B. LOKURFor Petitioner(s) Mr. Mohan Jain, ASG Mr. Prabhat Kumar, Adv. Mr. Deepak Jain, Adv. Mr. Arijit Prasad, Adv. Mrs Anil Katiyar, Adv. Mr. Shubham Agarwal, Adv. Mr. Alakh Srivastava, Adv. Mr. Vishnu Sankar, Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on application seeking condonation of delay as well as in the Special Leave Petition. Tag with Special Leave Petition (Civil) No.21459 of 2012. |(VINOD LAKHINA) | |(KUSUM GULATI) ||COURT MASTER | |COURT MASTER |

|ITEM NO.18 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR S.G. SHAHPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITHSLP(C) NO. 11460 of 2012(With office report)SLP(C) NO. 11943 of 2011(With office report)SLP(C) NO. 12111 of 2012(With office report)SLP(C) NO. 12886 of 2012(With office report)SLP(C) NO. 12887 of 2012(With office report)SLP(C) NO. 15207 of 2012(With office report)SLP(C) NO. 15209 of 2012(With office report)SLP(C) NO. 16265 of 2012(With office report)SLP(C) NO. 16266 of 2012(With office report)SLP(C) NO. 16319 of 2012(With office report)SLP(C) NO. 16782 of 2012(With office report)SLP(C) NO. 17656 of 2011(With office report)SLP(C) NO. 17661 of 2011(With office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 19491 of 2012(With office report)SLP(C) NO. 19492 of 2012(With office report)SLP(C) NO. 20626 of 2012(With office report)SLP(C) NO. 21459 of 2012(With office report)SLP(C) NO. 21460 of 2012(With office report) -2-Item No.18SLP(C) NO. 2804 of 2012(With office report)SLP(C) NO. 2805 of 2012(With office report)SLP(C) NO. 30192 of 2012(With office report)

SLP(C) NO. 5264 of 2012(With office report)SLP(C) NO. 5265 of 2012(With office report)SLP(C) NO. 5266 of 2012(With office report)SLP(C) NO. 7574 of 2012(With office report)SLP(C) NO. 7575 of 2012(With office report)SLP(C) NO. 7576 of 2012(With office report)SLP(C) NO. 7577 of 2012(With office report)SLP(C) NO. 9721 of 2012(With office report)Date: 07/11/2012 This Petition was called on for hearing today.For Petitioner(s) Mr Pawan Kumar Shukla, Adv. Mr. B.V. Balaram Das,Adv. Mrs Anil Katiyar, Adv.For Respondent(s) Ms. Kavita Jha,Adv. Mr. H.Raghavendra Rao, Adv. Mr Jabar Singh, Adv. Ms. Sandhya Goswami, Adv. Mr. Ambhoj Kumar Sinha, Adv. Mr. Kamal Mohan Gupta, Adv. Mr Vaibhav Gulia, Adv. Ms. Rakhi Ray, Adv. Ms. Kavita Jha, Adv. Ms. Ruchi Kohli, Adv. Mr Yudhister Bhardwaj, Adv. Ms. Namita Choudhary,Adv. Mr Mohd. Zahid Hussain, Adv. UPON hearing counsel the Court made the following O R D E R In SLP(C) no. 2804/2012, if petitioner pays process fee andrequisite sets of pleadings on or before 10.11.2012, issue -3-Item No.18notice with additional dasti service, else list before the Hon'ble Judge inChambers for non-prosecution as per previous order.SLP(C) No. 30192/2012 Petitioner is permitted to pay process fee and spare copies till24.11.2012 if proof of service is not received till then for fresh dastinotice. Served respondents in all connected SLPs may file counteraffidavit. List again on 2.1.2013.| | |(S.G.SHAH) || | |REGISTRAR |hj

DITEM NO.103 COURT NO.10 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil) No(s).2804/2012(From the judgement and order dated 30/05/2011 in ITA No.777/2010 of TheHIGH COURT OF DELHI AT N. DELHI)C.I.T.,NEW DELHI-VIII Petitioner(s) VERSUSGALLARI DEVI Respondent(s)(Office report on default)Date: 07/11/2012 This Petition was called on for hearing today.CORAM : HON'BLE MRS. JUSTICE GYAN SUDHA MISRA (In Chambers)For Petitioner(s) Mrs. Mansa Singh, Adv. Mrs. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R At the request of learned counsel for the petitioner, two weeks' further time is granted to her to take appropriate steps for confirming service on the respondent. | (Sanjay Kumar) Court Master | (Veena Khera) || |Court Master |

rITEM NO.3 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 16469/2012)(From the judgement and order dated 26/07/2011 in ITA No.404/2010of The HIGH COURT OF GUJARAT AT AHMEDABAD)C.I.T Petitioner(s) VERSUSANMOL & CO. Respondent(s)(With appln(s) for c/delay in filing SLP, c/delay in refiling SLP,exemption from filing c/c of the impugned order and office report)Date: 28/09/2012 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE ALTAMAS KABIRFor Petitioner(s) Mr. Mohan Parasaran,ASG. Mr. Arijit Prasad,Adv. Mr. Gaurav Dhingra,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Exemption allowed. Issue notice on the applications for condonation of delay as also on the special leave petition. Dasti service, in addition, is permitted. Tag this petition with S.L.P. (C) No.15209 of 2012. [ Alka Dudeja ] [ Indu Satija ] A.R.-cum-P.S. Court Master

ÊITEM NO.14 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR S.G. SHAHPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITHSLP(C) NO. 11460 of 2012(With office report)SLP(C) NO. 11943 of 2011(With office report)SLP(C) NO. 12111 of 2012(With office report)SLP(C) NO. 12886 of 2012(With office report)SLP(C) NO. 12887 of 2012(With office report)SLP(C) NO. 15207 of 2012(With office report)SLP(C) NO. 15209 of 2012(With office report)SLP(C) NO. 16265 of 2012(With office report)SLP(C) NO. 16266 of 2012(With office report)SLP(C) NO. 16319 of 2012(With office report)SLP(C) NO. 16782 of 2012(With office report)SLP(C) NO. 17656 of 2011(With office report)SLP(C) NO. 17661 of 2011(With office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 19491 of 2012(With office report)SLP(C) NO. 19492 of 2012(With office report)SLP(C) NO. 20626 of 2012(With office report)SLP(C) NO. 21459 of 2012(With office report) -2-Item No.14SLP(C) NO. 21460 of 2012(With office report)SLP(C) NO. 2804 of 2012(With office report)SLP(C) NO. 2805 of 2012

(With office report)SLP(C) NO. 5264 of 2012(With office report)SLP(C) NO. 5265 of 2012(With office report)SLP(C) NO. 5266 of 2012(With office report)SLP(C) NO. 7574 of 2012(With office report)SLP(C) NO. 7575 of 2012(With office report)SLP(C) NO. 7576 of 2012(With office report)SLP(C) NO. 7577 of 2012(With office report)SLP(C) NO. 9721 of 2012(With office report)Date: 08/08/2012 This Petition was called on for hearing today.For Petitioner(s) Mr. B.V. Balaram Das,Adv. Mrs Anil Katiyar, Adv.For Respondent(s) Mr Vaibhav Kulkarni, Adv. Ms. Kavita Jha,Adv. Mr. H.Raghavendra Rao, Adv. Ms Nikhar Beery, Adv. Ms. Sandhya Goswami, Adv. Mr. Ambhoj Kumar Sinha, Adv. Mr Mohd. Zahid Hussain, Adv. Mr. Kamal Mohan Gupta, Adv. Mr Vaibhav Gulia, Adv. Ms. Rakhi Ray, Adv. Mr M.K.Choudhary, Adv. Ms. Namita Choudhary, Adv. UPON hearing counsel the Court made the following O R D E R Nobody is present for the petitioner in SLP(C) No. 21459/2012 wherepetitioner has failed to pay process fee -3-Item No.14and file spare copies. If petitioner fails to pay process fee and filespare copies for issuance of notice on or before 14.8.2012, list before theHon'ble Judge in Chambers for non-prosecution. If paid, issue notice with additional dasti service on unservedrespondent. The litigant has to confirm dasti notice directly upon thelitigant-respondent. However, they are permitted to serve through thenearest Civil Court/Trial Court. If notice is issued, list again on 7.11.2012. The ld. Counsel for the respondent in SLP(C) No. 10542 and 17661 of2011 confirms that they do not want to file counter affidavit. Served respondents in all concerned SLPs may file counter affidavittill then.| | |(S.G.SHAH) || | |REGISTRAR |hj

\210ITEM NO.25 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 11202/2012)(From the judgement and order dated 30/05/2011 in ITA No.287/2009of The HIGH COURT OF DELHI AT N. DELHI)C.I.T.,NEW DELHI Petitioner(s) VERSUSSUDHIR DHINGRA Respondent(s)(With appln(s) for c/delay in filing and re-filing SLP andoffice report)With S.L.P. (C) No......./2012 (CC 11692/2012)(With appln(s) for c/delay in filing SLP and office report)Date: 16/07/2012 These Matters were called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE JAGDISH SINGH KHEHARFor Petitioner(s) Mr. Rajiv Dutta,Sr.Adv. Ms. Anita Sahni,Adv. Mr. Anandh Kannan,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the applications for condonation of delay as alsoon the special leave petitions. Dasti service, in addition, is permitted. Tag these petitions with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Indu Satija ] A.R.-cum-P.S. Court Master

ITEM NO.11 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 10921/2012)(From the judgement and order dated 26/07/2011 in ITA No.399/2010of The HIGH COURT OF GUJARAT AT AHMEDABAD)DY. C.I.T.-III, BARODA Petitioner(s) VERSUSM/S AMBER ENTERPRISES Respondent(s)(With appln(s) for c/delay in filing SLP and exemption fromfiling c/c of the impugned order)Date: 13/07/2012 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE JAGDISH SINGH KHEHARFor Petitioner(s) Mr. Harin P. Raval,ASG. Mr. Gautam Jha,Adv. Ms. Anita Sahani,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Exemption allowed. Issue notice on the application for condonation of delay as alsoon the special leave petition. Dasti service, in addition, is permitted. Tag this petition with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Indu Satija ] A.R.-cum-P.S. Court Master

jITEM NO.36 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR S.G. SHAHPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITH SLP(C) NO. 11460 of 2012(With office report)SLP(C) NO. 11943 of 2011(With office report)SLP(C) NO. 12111 of 2012(With office report)SLP(C) NO. 12886 of 2012(With office report)SLP(C) NO. 12887 of 2012(With office report)SLP(C) NO. 15207 of 2012(With office report)SLP(C) NO. 15209 of 2012(With office report)SLP(C) NO. 16265 of 2012(With office report)SLP(C) NO. 16266 of 2012(With office report)SLP(C) NO. 16319 of 2012(With office report)SLP(C) NO. 16782 of 2012(With office report)SLP(C) NO. 17656 of 2011(With office report)SLP(C) NO. 17661 of 2011(With office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 2804 of 2012(With office report)SLP(C) NO. 2805 of 2012(With office report)SLP(C) NO. 5264 of 2012(With office report)Item No.36 -2-SLP(C) NO. 5265 of 2012(With office report)SLP(C) NO. 5266 of 2012(With office report)SLP(C) NO. 7574 of 2012(With office report)SLP(C) NO. 7575 of 2012(With office report)SLP(C) NO. 7576 of 2012(With office report)SLP(C) NO. 7577 of 2012(With office report)SLP(C) NO. 9721 of 2012(With office report)

Date: 05/07/2012 This Petition was called on for hearing today.For Petitioner(s) Mr. Ravindra S. Garia, Adv. Mr. B.V. Balaram Das,Adv. Mr. Yogesh Kr. Sharma, Adv. Mrs Anil Katiyar, Adv.For Respondent(s) Mr. Ansar Ali, Adv. Ms. Kavita Jha,Adv. Ms. Sandhya Goswami, Adv. Mr. Ram Kishore Singh Yadav, Adv. Mr. Ambhoj Kumar Sinha, Adv. Mr. Kamal Mohan Gupta, Adv. Ms. Namita Choudhary, Adv. Mr. Javed Ali, Adv. UPON hearing counsel the Court made the following O R D E R In SLP(C) No.11460/2012, petitioner has to provide spare copiesbefore 31.7.2012. If it is not done, list before the Hon'ble Judge in Chambers for non-prosecution.Item No.36 -3- In SLP(C) No.2804/2012, if petitioner fails to take appropriate stepsto confirm service before 31.7.2012, list this SLP before the Hon'ble Judgein Chambers for non-prosecution. In rest of the SLPs, served respondents may file counter affidavitbefore 8.8.2012. The learned Advocate, Mr. Javed Ali for the sole respondent in SLP(C)No.10542/2011 and 17661/2011 confirms that he does not want to file counteraffidavit.| | | (S.G. SHAH) || | |REGISTRAR || | | |rd

,ITEM NO.16 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 9837/2012)(From the judgement and order dated 26/07/2011 in ITA No.356/2010of The HIGH COURT OF GUJARAT AT AHMEDABAD)DY. C.I.T-III BARODA Petitioner(s) VERSUSM/S AVISHKAR ENTERPRISES Respondent(s)(With appln(s) for c/delay in filing SLP, exemption from filingc/c of the impugned order and office report)With S.L.P. (C) No......./2012 (CC 10309/2012)(With appln(s) for c/delay in filing SLP, exemption from filingc/c of the impugned order and office report)Date: 04/07/2012 These Matters were called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE JAGDISH SINGH KHEHARFor Petitioner(s) Mr. Mohan Parasaran,ASG. Mr. Gaurav Dhingra,Adv. Ms. A. Subhashini,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Exemption allowed. Issue notice on the applications for condonation of delay as also on the special leave petitions. Dasti service, in addition, is permitted. Tag these petitions with S.L.P. (C) No.10542 of 2011. [ T.I. Rajput ] [ Indu Satija ] A.R.-cum-P.S. Court Master

ITEM NO.7 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 8983/2012)(From the judgement and order dated 30/05/2011 in ITA No.1326/2010of The HIGH COURT OF DELHI AT N. DELHI)COMMISSIONER OF INCOME TAX, NEW DELHI Petitioner(s) VERSUSMONIKA SAXENA Respondent(s)(With appln(s) for c/delay in filing SLP and office report)Date: 11/05/2012 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Mohan Parasaran,ASG. Mr. D.L. Chidananda,Adv. Mr. C.V.S. Rao,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the application for condonation of delay as also on the special leave petition. Dasti service, in addition, is permitted. Tag this petition with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

`ITEM NO.9 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 8302/2012)(From the judgement and order dated 30/05/2011 in ITA No.198/2010of The HIGH COURT OF DELHI AT N. DELHI)C.I.T.,NEW DELHI Petitioner(s) VERSUSGAURI SHANKAR AGGARWAL (HUF) Respondent(s)(With appln(s) for c/delay in filing SLP, c/delay in refiling SLPand office report)Date: 08/05/2012 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Mohan Parasaran,ASG. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the applications for condonation of delay as also on the special leave petition. Dasti service, in addition, is permitted. Tag this petition with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

(ITEM NO.6 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 8026/2012)(From the judgement and order dated 09/08/2011 in ITA No.669/2009of The HIGH COURT OF DELHI AT N. DELHI)C.I.T Petitioner(s) VERSUSANIL KUMAR BANSAL Respondent(s)(With appln(s) for c/delay in filing SLP and office report)Date: 08/05/2012 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Gaurab Banerji,ASG. Mr. Arijit Prasad,Adv. Mr. S.A. Haseeb,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the application for condonation of delay as also on the special leave petition. Dasti service, in addition, is permitted. Tag this petition with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

\224ITEM NO.21 COURT NO.8 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS CC 8268/2012Petition(s) for Special Leave to Appeal (Civil)....../2012(From the judgement and order dated 26/07/2011 in ITANo.363/2010 of The HIGH COURT OF GUJARAT AT AHMEDABAD)C.I.T-III BARODA Petitioner(s) VERSUSM/S SHREE KRUPA BUILDERS Respondent(s)(With appln(s) for c/delay in filing SLP and office report )Date: 08/05/2012 This Petition was called on for hearingtoday.CORAM : HON'BLE MR. JUSTICE H.L. DATTU HON'BLE MR. JUSTICE CHANDRAMAULI KR. PRASADFor Petitioner(s) Mr.Rajiv Dutta, Sr.Adv. Mr.Yatinder Chaudhary, Adv. Mr.C.V.S.Rao, Adv. For Mrs Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Notice on the application for condonation of delay asalso on the Special Leave Petition. Tag with SLP(C)No.17662/2011 @ CC 10191/2011. (G.V.Ramana) (Sharda Kapoor) Court Master Court Master

ÌITEM NO.19 COURT NO.9 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS CC 7208/2012Petition(s) for Special Leave to Appeal (Civil)....../2012(From the judgement and order dated 26/07/2011 in ITANo.360/2010, of The HIGH COURT OF GUJARAT AT AHMEDABAD)DY.COMMR.OF I.T Petitioner(s) VERSUSMARUTI FINANCE Respondent(s)(With appln(s) for c/delay in filing SLP and office report )WITH S.L.P.(C)...CC NO. 7627 of 2012(With appln.(s) for c/delay in filing SLP and office report)Date: 30/04/2012 These Petitions were called on for hearingtoday.CORAM : HON'BLE MR. JUSTICE H.L. DATTU HON'BLE MR. JUSTICE CHANDRAMAULI KR. PRASADFor Petitioner(s) Mr.Rajeev Dutta, Sr.Adv Mr.Rahul Kaushik, Adv. Mr.S.K.Sahajpal, Adv. for Mrs Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Notice on the application(s) for condonation of delayas also on the Special Leave petitions. Tag with SLP(C)No.10191/2011. (G.V.Ramana) (Sharda Kapoor) Court Master Court Master

ITEM NO.5 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 6039/2012)(From the judgement and order dated 30/05/11 in ITA No.711/2009of The HIGH COURT OF DELHI AT N. DELHI)C.I.T-XIII Petitioner(s) VERSUSSADHU RAM AGGARWAL Respondent(s)(With appln(s) for c/delay in filing SLP and office report)With S.L.P. (C) No........./2012 (CC 6230/2012)(With appln(s) for c/delay in filing SLP and office report)Date: 13/04/2012 These Petitions were called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Gaurab Banerji,ASG. Mr. Imtiaz Ahmed,Adv. Mr. Vikas Malhotra,Adv. Ms Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the applications for condonation of delay as also on the special leave petitions. Dasti service, in addition, is permitted. Tag these petitions with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

ITEM NO.28 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR S.G. SHAHPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITH SLP(C) NO. 11943 of 2011(With office report)SLP(C) NO. 17656 of 2011(With office report)SLP(C) NO. 17661 of 2011(With office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 2804 of 2012(With office report)SLP(C) NO. 2805 of 2012(With office report)SLP(C) NO. 5264 of 2012(With office report)SLP(C) NO. 5265 of 2012(With office report)SLP(C) NO. 5266 of 2012(With office report)SLP(C) NO. 7574 of 2012(With office report)SLP(C) NO. 7575 of 2012(With office report)SLP(C) NO. 7576 of 2012(With office report)SLP(C) NO. 7577 of 2012(With office report)SLP(C) NO. 9721 of 2012(With office report)Date: 04/04/2012 This Petition was called on for hearing today.For Petitioner(s) Mr. B.V. Balaram Das,Adv. Mr. Kailash Pandey, Adv. Mrs Anil Katiyar, Adv.Item No.28 -2-For Respondent(s) Mr. Vijay Kr. Punha, Adv. Ms. Kavita Jha,Adv. Ms. Namita Choudhary, Adv. UPON hearing counsel the Court made the following O R D E R Let there be a fresh notice with dasti service uponthe unserved respondents in all the concerned SLPs, which ispermitted to be served through the nearest Civil Court/Trialcourt, where private parties are concerned and throughstanding counsel, where state authorities are concerned, if

process fee and spare copies are paid/filed before 16.4.2012,else list before the Hon'ble Judge in Chambers for non-prosecution. If notices are issued, list again on 5.7.2012. Served respondents in all the SLPs may file counteraffidavit till then. (S.G. SHAH) REGISTRARrd

$ITEM NO.8 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 5453/2012)(From the judgement and order dated 30/05/2011 in ITA No.1329/2009of The HIGH COURT OF DELHI AT N. DELHI)C.I.T.,NEW DELHI Petitioner(s) VERSUSRENU VERMA Respondent(s)(With appln(s) for c/delay in filing SLP and office report)Date: 02/04/2012 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Gaurab Banerji,ASG. Mr. Imtiaz Ahmed,Adv. Mr. T.M. Singh,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the application for condonation of delay as also on the special leave petition. Dasti service, in addition, is permitted. Tag this petition with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

\236ITEM NO.7 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 5168/2012)(From the judgement and order dated 30/05/2011 in ITA No.1064/2009of The HIGH COURT OF DELHI AT N. DELHI)C.I.T VIII NEW DELHI Petitioner(s) VERSUSV.K.NARANG Respondent(s)(With appln(s) for c/delay in filing SLP and office report)Date: 30/03/2012 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Goolam E. Vahanvati,AG. Mr. Gaurab Banerji,ASG. Mr. Anoopam N. Prasad,Adv. Mr. Syed Abdul Haseeb,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the application for condonation of delay as also on the special leave petition. Dasti service, in addition, is permitted. Tag this petition with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

&ITEM NO.5 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 4382/2012)(From the judgement and order dated 30/05/2011 in ITA No.583/2008of The HIGH COURT OF DELHI AT N. DELHI)C.I.T-XIII Petitioner(s) VERSUSSUKESH KUMAR GUPTA Respondent(s)(With appln(s) for c/delay in filing SLP and office report)Date: 19/03/2012 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Gaurab Banerji,ASG. Mr. Imtiaz Ahmed,Adv. Mr. S. Madhusudhan Babu,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the application for condonation of delay as also on the special leave petition. Dasti service, in addition, is permitted. Tag this petition with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

ÎITEM NOS.4 & 23 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 3323/2012)(From the judgement and order dated 30/05/2011 in ITA No.1313/2010of The HIGH COURT OF DELHI AT N. DELHI)C.I.T Petitioner(s) VERSUSMONIKA SAXENA Respondent(s)(With appln(s) for c/delay in filing SLP and office report)With S.L.P. (C) No........../2012 (CC 3768/2012)(With appln(s) for c/delay in filing SLP and office report)S.L.P. (C) No........../2012 (CC 3977/2012)(With appln(s) for c/delay in filing SLP and office report)S.L.P. (C) No........../2012 (CC 4145/2012)(With appln(s) for c/delay in filing SLP and office report)Date: 24/02/2012 These Matters were called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Gaurab Banerji,ASG. Mr. Arjun Krishnan,Adv. Ms. Bhakti Pasrija,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) ....2/- - 2 - UPON hearing counsel the Court made the following O R D E R Issue notice on the applications forcondonation of delay as also on the special leavepetitions. Dasti service, in addition, is permitted. Tag these petitions with S.L.P. (C)No.10542 of 2011 [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

îITEM NO.20 REGISTRAR COURT.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS BEFORE THE REGISTRAR S.G. SHAHPetition(s) for Special Leave to Appeal (Civil) No(s).10542/2011COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)WITHSLP(C) NO. 11943 of 2011(With office report)SLP(C) NO. 17656 of 2011(With office report)SLP(C) NO. 17661 of 2011(With office report)SLP(C) NO. 17662 of 2011(With office report)SLP(C) NO. 2804 of 2012(With office report)SLP(C) NO. 2805 of 2012(With office report)SLP(C) NO. 5264 of 2012(With office report)SLP(C) NO. 5265 of 2012(With office report)SLP(C) NO. 5266 of 2012(With office report)Date: 15/02/2012 This Petition was called on for hearing today.For Petitioner(s) Mr Anil V Katarki, Adv. Mr. B.V. Balaram Das,Adv. Mr Aakash D Pratap, Adv. Mrs Anil Katiyar, ADv.For Respondent(s) Mr Vijay Kumar Punna, ADv. Ms. Kavita Jha,Adv. Ms. Namita Choudhary, ADv. -2-Item No.20 UPON hearing counsel the Court made the following O R D E R In SLP(C) No. 5264,5265,5266 of 2012, petitioner hasto pay process fee and spare copies before 24.2.2012. On

payment of process fee and spare copies, issue notice withadditional dasti service on unserved respondents as perorder dated 6.2.2012, which is permitted to be servedthrough the nearest Civil Court/Trial Court where privateparties are concerned and through standing counsel whereState authorities are concerned, if process fee and sparecopies are paid before 24.2.2012, else list before theHon'ble Judge in Chamber for non-prosecution. In SLP(C) Nos. 2804,2805 of 2012, petitioner has todisclose outcome of dasti service. Served respondents in remaining SLPs may file counteraffidavit. If notices are issued, list again on 4.4.2012. (S.G.SHAH) REGISTRARhj

¸ITEM NO.4 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 1882/2012)(From the judgement and order dated 30/05/2011 in ITA No.1075/2009of The HIGH COURT OF DELHI AT N. DELHI)C.I.T XIII Petitioner(s) VERSUSBHARAT BHUSHAN JAIN Respondent(s)(With appln(s) for c/delay in filing SLP and office report)With S.L.P. (C) No......../2012 (CC 1883/2012)(With appln(s) for c/delay in filing SLP and office report)S.L.P. (C) No........./2012 (CC 2585/2012)(With appln(s) for c/delay in filing SLP and office report)Date: 06/02/2012 These Matters were called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Gaurab Banerji,ASG. Mr. Gautam Jha,Adv. Ms. A. Subhashini,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the applications for condonation of delay as also on the special leave petitions. Dasti service, in addition, is permitted. Tag these petitions with S.L.P. (C) No.2804 of 2012. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

¸ITEM NO.4 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2012(CC 1882/2012)(From the judgement and order dated 30/05/2011 in ITA No.1075/2009of The HIGH COURT OF DELHI AT N. DELHI)C.I.T XIII Petitioner(s) VERSUSBHARAT BHUSHAN JAIN Respondent(s)(With appln(s) for c/delay in filing SLP and office report)With S.L.P. (C) No......../2012 (CC 1883/2012)(With appln(s) for c/delay in filing SLP and office report)S.L.P. (C) No........./2012 (CC 2585/2012)(With appln(s) for c/delay in filing SLP and office report)Date: 06/02/2012 These Matters were called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE A.K. PATNAIK HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Gaurab Banerji,ASG. Mr. Gautam Jha,Adv. Ms. A. Subhashini,Adv. Ms. Anil Katiyar,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the applications for condonation of delay as also on the special leave petitions. Dasti service, in addition, is permitted. Tag these petitions with S.L.P. (C) No.2804 of 2012. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

ÎITEM NO.24 COURT NO.6 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2011 CC 10191/2011(From the judgement and order dated 20/09/2010 in ITA No. 3134/2009of The HIGH COURT OF BOMBAY)C.I.T KOLHAPUR Petitioner(s) VERSUSRAMCHANDRA MAHADEO PATIL Respondent(s) With I.A. 1 (c/delay in filing SLP and office report ))Date: 08/07/2011 This Petition was called on for hearing today.CORAM : HON'BLE MR. JUSTICE MARKANDEY KATJU HON'BLE MR. JUSTICE CHANDRAMAULI KR. PRASADFor Petitioner(s) Mr. H.P. Raval, A.S.G. Mr. Rajiv Nanda, Adv. Mr. B.V. Balaram Das,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Delay condoned. Issie notice. Tag with S.L.P.(C) No. 10542/2011 (arising out of CC No. 3237/2011). ( Rajesh Dham ) ( Indu Satija ) Court Master Court Master

jITEM NO.18 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2011(CC 10312/2011)(From the judgement and order dated 04/08/2010 in ITA No.317/2010of The HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH)C.I.T., LUDHIANA Petitioner(s) VERSUSM/S RAJAN KNIT FAB(P) LTD. Respondent(s)(With appln(s) for c/delay in filing SLP and office report)With S.L.P. (C) No....../2011 (CC 10367/2011)(With appln(s) for c/delay in filing SLP and office report)Date: 08/07/2011 These Matters were called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE K.S. PANICKER RADHAKRISHNANFor Petitioner(s) Mr. Vivek Tankha,ASG. Mr. Sunil Roy,Adv. Mr. B.V. Balaram Das,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Issue notice on the applications for condonation of delay as also on the special leave petitions. Dasti service, in addition, is permitted. Tag these petitions with S.L.P. (C) No.11943 of 2011. [ T.I. Rajput ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

ÞITEM NO.11 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2011(CC 6989/2011)(From the judgement and order dated 04/08/2010 in ITA No.318/2010of The HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH)COMMR.OF I.T-I Petitioner(s) VERSUSM/S ARORA FABRICS P.LTD. Respondent(s)(With appln(s) for c/delay in filing SLP and office report)Date: 25/04/2011 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE K.S. PANICKER RADHAKRISHNAN HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. Gaurab Banerji,ASG. Mr. Sukumar Pattjoshi,Adv. Mr. Arjun Krishnan,Adv. Mr. B.V. Balaram Das,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Delay condoned. Issue notice. Dasti service, in addition, is permitted. Tag this petition with S.L.P. (C) No.10542 of 2011. [ Alka Dudeja ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

\204ITEM NO.16 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2011(CC 3237/2011)(From the judgement and order dated 20/07/2010 in ITA No.154/2010of The HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH)COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)(With appln(s) for c/delay in filing SLP)Date: 11/04/2011 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE K.S. PANICKER RADHAKRISHNAN HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. H.P. Raval,ASG. Mr. Rajiv Nanda,Adv. Mr. Anirudh Sharma,Adv. Mr. B.V. Balaram Das,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R Delay condoned. Issue notice. [ T.I. Rajput ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

2ITEM NO.11 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2011(CC 3237/2011)(From the judgement and order dated 20/07/2010 in ITA No.154/2010of The HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH)COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)(With appln(s) for c/delay in filing SLP)Date: 28/03/2011 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE K.S. PANICKER RADHAKRISHNAN HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. H.P. Raval,ASG. Mr. Rajiv Nanda,Adv. Mr. Anirudh Sharma,Adv. Mr. B.V. Balaram Das,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R The special leave petition shall stand over for two weeks to enable the Department to file additional affidavit. [ T.I. Rajput ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

êITEM NO.8 COURT NO.1 SECTION IIIA S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGSPetition(s) for Special Leave to Appeal (Civil)....../2011(CC 3237/2011)(From the judgement and order dated 20/07/2010 in ITA No.154/2010of The HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH)COMMISSIONER OF INCOME TAX-III Petitioner(s) VERSUSM/S. CALCUTTA KNITWEARS, LUDHIANA Respondent(s)(With appln(s) for c/delay in filing SLP)Date: 28/02/2011 This Petition was called on for hearing today.CORAM : HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE K.S. PANICKER RADHAKRISHNAN HON'BLE MR. JUSTICE SWATANTER KUMARFor Petitioner(s) Mr. H.P. Raval,ASG. Mr. Rajiv Nanda,Adv. Mr. A. Sharma,Adv. Mr. B.V. Balaram Das,Adv.For Respondent(s) UPON hearing counsel the Court made the following O R D E R The special leave petition shall stand over for four weeks to file additional affidavit. [ T.I. Rajput ] [ Madhu Saxena ] A.R.-cum-P.S. Assistant Registrar

Search This Case

Indian Kanoon Google Scholar Google

Supreme Court Resources

SC Case Status by Diary Number Search by CNR Number Supreme Court of India Official SC Website (external)

High Court Case Status

Check case status for High Courts across India

Allahabad High Court

Uttar Pradesh

Andhra Pradesh High Court

Andhra Pradesh

Bombay High Court

Maharashtra

Calcutta High Court

West Bengal

Chhattisgarh High Court

Chhattisgarh

Delhi High Court

Delhi

Gauhati High Court

Assam

Gujarat High Court

Gujarat

Himachal Pradesh High Court

Himachal Pradesh

Jammu & Kashmir High Court

Jammu & Kashmir

Jharkhand High Court

Jharkhand

Karnataka High Court

Karnataka

Kerala High Court

Kerala

Madhya Pradesh High Court

Madhya Pradesh

Madras High Court

Tamil Nadu

Manipur High Court

Manipur

Meghalaya High Court

Meghalaya

Orissa High Court

Odisha

Patna High Court

Bihar

Punjab & Haryana High Court

Punjab / Haryana / Chandigarh

Rajasthan High Court

Rajasthan

Sikkim High Court

Sikkim

Telangana High Court

Telangana

Tripura High Court

Tripura

Uttarakhand High Court

Uttarakhand