Veermata Jijabai Technological Institute v. ACIT
Finin2min Judgment Intelligence is provided for general informational and educational purposes only. It is not legal, tax, accounting, investment or other professional advice and is not a substitute for advice on the user's specific facts. The Finin2min summary, Q&A, reliance profile, fact-match indicators, comparisons and practical takeaways are editorial analysis and are not part of the Court/Tribunal judgment. Before citing, filing, advising or acting on a case, read the complete official judgment/order, verify the cause title, case number, coram, date, applicable statutory text and jurisdiction, and check subsequent appellate history, review/SLP status and later amendments. A similar fact pattern does not guarantee the same outcome. No advocate-client, CA-client or other professional relationship is created by use of this page.
Case in 2 minutes
The judgment addresses the issues identified in the case record.
Case snapshot
Sections / provisions: 254; DTVSV
Questions before the Court / Tribunal
- See the source-driven case record below.
Material facts and background
The assessee has filed the present appeal challenging the impugned order dated 03.10.2023, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2017-18. 2.
In the result, the appeal filed by the assessee is dismissed as withdrawn. Order pronounced in the open Court on 29/11/2024 Sd/OM PRAKASH KANT ACCOUNTANT MEMBER
Appellant / assessee submissions
At the time of the hearing, the learned AR for the assessee filed a letter
Revenue / respondent submissions
The judgment copy does not separately set out this component in a distinct section; refer to the full order and the reasoning section below.
Court / Tribunal analysis and reasoning
The assessee has filed the present appeal challenging the impugned order dated 03.10.2023, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2017-18. 2.
dated 25.11.2024 along with a copy of Form 1 filed under Direct Tax Vivad Se Vishwas Scheme, 2024 and stated that the assessee has opted for Direct Tax Vivad Se Vishwas Scheme, 2024. In light of the above letter, we dismiss the
appeal of the assessee with the liberty to reinstate the appeal if its application under Direct Tax Vivad Se Vishwas Scheme, 2024, is not accepted. 3.
In the result, the appeal filed by the assessee is dismissed as withdrawn. Order pronounced in the open Court on 29/11/2024 Sd/OM PRAKASH KANT ACCOUNTANT MEMBER
Operative decision and relief
Assessee by : Shri Vaishvik Revenue by : Shri Ashish Heliwal, CIT-DR Date of Hearing – 28/11/2024
The assessee has filed the present appeal challenging the impugned order dated 03.10.2023, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2017-18. 2.
dated 25.11.2024 along with a copy of Form 1 filed under Direct Tax Vivad Se Vishwas Scheme, 2024 and stated that the assessee has opted for Direct Tax Vivad Se Vishwas Scheme, 2024. In light of the above letter, we dismiss the
appeal of the assessee with the liberty to reinstate the appeal if its application under Direct Tax Vivad Se Vishwas Scheme, 2024, is not accepted. 3.
In the result, the appeal filed by the assessee is dismissed as withdrawn. Order pronounced in the open Court on 29/11/2024 Sd/OM PRAKASH KANT ACCOUNTANT MEMBER
Authorities and precedents appearing in the judgment
- No reliable precedent list was extracted automatically; use the full judgment for the citation chain.
This list is machine-assisted from the judgment text and is not a substitute for checking the full citation chain in the PDF.
Ratio and legal principle
The decision turns on the statutory and factual issues recorded above. The operative result is classified as Operative order controls. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Why this judgment matters
The case is relevant to taxpayers, advisers and litigators dealing with Income Tax. Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.
Practitioner action points
- Maintain a date-and-payment matrix for transfer, agreement, possession, investment and construction; capital-gains exemptions commonly turn on this chronology.
- For litigation, attach the full judgment/order to the working paper and cite the paragraph/page supporting the proposition rather than relying on a headnote alone.
Do not over-read this case
- The packaged PDF is not yet an issuing-authority certified copy
- Apply the statutory law applicable to the relevant year; later amendments can change the result.
- Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.
How to apply this decision in practice
This ITAT Mumbai decision should be used by matching the client’s facts to the precise controversy in the case—the disputed issue—rather than by relying only on the result. Start with the statutory version applicable to the relevant year and compare it with 254, DTVSV. Amendments, notifications, later Supreme Court/High Court decisions and a different procedural stage can materially change the answer.
For an assessment or litigation file, retain the documents that prove the factual bridge on which the judgment turns: the original notice/order, replies and objections, acknowledgements of filing/service, ledger and banking trail where relevant, contracts or property instruments where relevant, and the complete appellate chronology. If the case succeeds on jurisdiction or natural justice, do not assume the same outcome where the authority cures that defect. If it succeeds on evidence, identify exactly which documents the Court or Tribunal considered persuasive.
For capital-gains/property matters, map ownership/right transferred, agreement and registration dates, possession, consideration flows, stamp valuation, investment dates and the exact nature of the asset. Small factual differences can move the case into a different charging or exemption provision.
Finin2min reliance rule: cite the case for the narrow legal proposition actually decided, record any contrary authority, and attach the full judgment to the working paper or litigation file. This reduces the risk of a headnote or short summary being used outside its factual and statutory context.
Verification before citation
Because this is a comparatively short order, the practical value lies in its precise procedural and factual setting rather than its length. Before citing it, compare the complete paper-book chronology, the statutory wording for the relevant year, the forum’s jurisdiction and any later appellate history. A short order can be decisive, but only for the proposition actually adjudicated. Finin2min therefore provides the full judgment PDF alongside this note so the primary reasoning can be checked rather than inferred from the summary alone.
Case-specific verification matrix
Proposition being tested: the issue before the forum. A practitioner should write the proposition in one sentence before citing this decision and then verify that the client’s facts engage the same statutory trigger. The relevant provisions recorded for this case are 254, DTVSV. If the client is under a different statutory version, assessment year, notification regime or appellate stage, the conclusion may not travel automatically.
Factual match: compare the documents that created the dispute, the authority’s stated reason for the adjustment/action, the taxpayer’s contemporaneous response and the evidentiary gap the forum treated as decisive. Record which facts are identical, which are only similar and which are materially different. This prevents a result-based citation from replacing the actual ratio.
Procedural match: confirm limitation, jurisdiction, service, opportunity of hearing and the stage at which the issue was decided. A writ order, remand, stay order, penalty appeal, search assessment and merits quantum appeal answer different legal questions even where they mention the same section.
Current-law check: before filing or advising, verify subsequent appellate history and later binding authority. The local full judgment supplied with this article is the starting point; the official issuing-authority copy and current statutory text remain the final reliance documents.
Finin2min Judgment Intelligence
Decision support built around the judgment: reliance, fact match, Q&A, section impact, related-case network and practical next steps.
Can I rely on this judgment?
| Authority level | ITAT |
|---|---|
| Reliance effect | Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. |
| Source integrity | A sanitized local full-text judgment copy is packaged; official-primary replacement remains pending. |
| Subsequent history | Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work. |
| Finin2min status | Later-history check open |
Does this case match your facts?
Stronger match when
- Your dispute raises the same core issue: the principal issue.
- The same statutory provisions or materially equivalent provisions apply: 254, DTVSV.
- Your matter is at a comparable the same procedural and factual stage stage.
- Your documentary/evidentiary record is materially similar to the facts the ITAT Mumbai considered: The assessee has filed the present appeal challenging the impugned order dated 03.10.2023, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2017-18.
- The same legal regime or assessment-period rules relevant to AY 2017-18 apply to your matter.
Weaker / distinguishable when
- A later Supreme Court or jurisdictional High Court ruling changes the legal position.
- The statutory provision was amended for your year or transaction.
- Your evidence, transaction structure, notice chronology or procedural stage differs on a fact the judgment treated as material.
- The case succeeded on a narrow jurisdictional/procedural defect that the authority has cured in your matter.
Questions this judgment answers
What was the main dispute in Veermata Jijabai Technological Institute?
The judgment addresses the issues identified in the case record.
Which facts mattered most to the result?
The assessee has filed the present appeal challenging the impugned order dated 03.10.2023, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2017-18. 2. In the result, the appeal filed by the assessee is dismissed as withdrawn.
What did the ITAT Mumbai ultimately decide?
Assessee by : Shri Vaishvik Revenue by : Shri Ashish Heliwal, CIT-DR Date of Hearing – 28/11/2024 The assessee has filed the present appeal challenging the impugned order dated 03.10.2023, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2017-18. 2. dated 25.11.2024 along with a copy of Form 1 filed under Direct Tax Vivad Se Vishwas Scheme, 2024 and stated that the…
What legal principle can be taken from this judgment?
The decision turns on the statutory and factual issues recorded above. The operative result is classified as Operative order controls. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Which provisions should be checked before relying on the case?
The case engages 254, DTVSV. The relevant statutory version for AY 2017-18 should be checked together with any later amendment, notification, circular and controlling higher-court authority.
When is this judgment most useful to a taxpayer or adviser?
The case is relevant to taxpayers, advisers and litigators dealing with Income Tax . Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.
What could make this judgment distinguishable or unsafe to rely on?
The packaged PDF is not yet an issuing-authority certified copy Apply the statutory law applicable to the relevant year; later amendments can change the result. Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.
Can this judgment be cited as current law without another check?
Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work. A sanitized local full-text judgment copy is packaged; official-primary replacement remains pending.
Section / provision impact
- 254 — 254 is part of the statutory framework considered in the context of the dispute. Read the exact provision applicable to the relevant year with the Court/Tribunal reasoning.
- DTVSV — DTVSV is part of the statutory framework considered in the context of the dispute. Read the exact provision applicable to the relevant year with the Court/Tribunal reasoning.
How the decision changes your analysis
Before using this authority, frame the issue under 254, DTVSV and identify the decisive facts/evidence. The result should not be assumed from the case title alone.
The decision turns on the statutory and factual issues recorded above. The operative result is classified as Operative order controls. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work.
Case network: similar and different outcomes
Closest related cases in the Finin2min repository
Related cases with a different result
Related-case links are repository similarity connections, not a claim that one judgment cites or overrules another. Use the cited-authority list and later-history check for formal precedent analysis.
Working-paper citation
Full judgment and source trail
Read / download the clean local judgment copy
| Packaged source class | SANITIZED_LOCAL_FULL_JUDGMENT_COPY_PRIMARY_PENDING |
|---|---|
| Pages | 2 |
| SHA-256 | caadc1278db16b8e58a47703f3388d558ea888c283959e3ce9619d3f18a8be25 |
| Original source URL | Not exposed publicly. Original provenance retained only in the private source-closure ledger. |
| Source authentication | Sanitized local full-text copy - official primary replacement pending |