AI Insights
The case revolves around the interpretation of Section 2(22)(e) of the Income Tax Act, 1961, concerning whether certain transactions between the assessee, Shri Ajay Virendra Arora, and D'Decor Home Fabrics Pvt. Ltd. constituted 'deemed dividend'. The revenue contended that the transactions were in the nature of loans and advances, thus falling under the purview of deemed dividend. However, the CIT(A) found that the transactions were part of a mutual, current, and running account, where the balances fluctuated between debit and credit, and were not in the nature of loans or advances. The Tribunal agreed with the CIT(A)'s decision, noting that the assessee had paid interest on the advances and that the company's Employee Loan Policy supported the nature of these transactions as commercial rather than gratuitous.
Appeal Details
Counselvise Citation
[2022] 140 COUNSELVISE.COM (IT) 124797 (ITAT-MUMBAI)
Assessee PAN
Bench
Appeal Number
CRN Number
Duration Of Justice
16 year(s) 7 month(s) 27 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
21-11-2022
Appeal Filed By
Department
Order Result
Dismissed
Bench Allotted
A
Next Hearing Date
02-10-2022
Assessment Year
misc
Appeal Filed On
25-03-2006
Judgement Text
IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JM, & SHRI S. RIFAUR RAHMAN, AM आयकरअपीलसं./ I.T.A. No. 2149/Mum/2021 (निर्धारणवर्ा / Assessment Year: 2017-18) ACIT-Cen.Circle – 6(4), R. No. 1925, 19 th floor, Air India Building, Nariman Point, Mumbai-400 021 बिधम/ Vs. Shri Ajay Virendra Arora, 6 th floor, S14, Solitaire Corporate Park, Guru Hargovindji Marg, Chakala, Andheri(East), Mumbai-400 093 स्थायीलेखासं./जीआइआरसं./PAN No. ADDPA6742R (अपीलाथी/Appellant) : (प्रत्यथी / Respondent) अपीलाथीकीओरसे/ Appellant by : Shri Salil Mishra, Ld. DR प्रत्यथीकीओरसे/Respondent by : Shri Jitendra Jain/ Shri Ravikant Pathak, Ld. ARs सुनवाईकीतारीख/ Date of Hearing : 03.10.2022 घोषणाकीतारीख / Date of Pronouncement : 22.11.2022 आदेश / O R D E R Per Amit Shukla, Judicial Member: The aforesaid appeal has been filed by the revenue against the impugned order dated 25.08.2021, passed by Ld. CIT(A)-54, Mumbai for the quantum of assessment passed u/s 153A r.w.s. 2 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora 143(3) for AY 2017-18. The revenue has taken the following grounds of appeal:- 1. "On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in not appreciating the fact that the assessee held beneficial share holding and voting power of 81% in D'Decor Home Fabrics Private Limited, whose accumulated profit as on 31.03.2017 was Rs.296,42,12,262/-, and the ledger account of the assessee in the books of D'Decor Exports Private Limited showed payments made to assessee and third parties on his behalf (by D'Decor Exports Private Limited) of Rs.23,97,43,607/-, which is nothing but 'loans and advances', hence the same ought to be treated as 'deemed dividend' as per the provisions of Section 2(22)(e) of the Income tax Act, 1963." 2. "On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in treating the account of the assessee in the books of D'Decor Exports Private Limited as shifting, current and/or running account, referring to Section 19 of the Limitation Act, 1963, and not loans and advances, however, the Limitation Act, 1963, only refers to limitations periods (of suits, appeals and applications) and its computation and does provide definition of shifting, current and/or running account." 3. "On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in relying upon Section 19 of the Limitation Act, 1963, to hold that the account of the assessee in the 3 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora books of D'Decor Exports Private Limited as shifting, current and/or running account, which does not provide definition of the same." 4. "On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in not considering the decisions of the Hon'ble Supreme Court in the case of Tarulata Shyam & Ors. Vs. CIT(SC) 108 ITR 345 and Sarada Vs. CIT (SC) 229 ITR 444." 2. The facts in brief are that, assessee has been showing salary income in the capacity of a Directors in; D‟ Decor Home Fabrics Pvt. Ltd., Home Idea Curtain Fabrics and Home Idea Upholstery Pvt. Ltd. The assessee has also shown income from house property, capital gains and other sources. The return of income was filed on 31.10.17 declaring total income of Rs. 31,04,19,290/-. Later on a search and seizure action was carried out in the case of D‟ Décor Group on 06.03.2018 in which assessee was also covered. 3. In so far as issue on deemed dividend is concerned, Ld. AO has noted that from the perusal of the ledger account of the assessee in the books of D‟ Decor Home Fabrics Pvt. Ltd., wherein assessee was holding 84.5% of shares, that the assessee has received loans and advances for some aggregating Rs. 23,97,43,607/- during the relevant year. He also noted that the 4 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora company had accumulated profits for the year was Rs. 2,96,42,12,262/-. In response to the show cause notice issued by the AO that as to why the loans and advances received from the company wherein assessee is having beneficial shareholding should not be treated as deemed dividend u/s 2(22)(e), assessee submitted that he has only one ledger account in the books of D‟ Decor Home Fabrics Pvt. Ltd. (DDHF) involving about 201 transactions which includes payments made by the assessee to DDHF at various occasions having his credit balances in the books of DDHF. At various occasions, DDHF has made direct payments to the assessee or payments made to third parties on his behalf leaving the debit balance in the books of DDHF in the name of assessee and at few instances, the payments were made to the family members of the assessee. The assessee‟s contention was that since there are regular transaction in the current or running account and not in the nature of advance loan within the meaning of section 2(22)(e). Assessee has also relied upon various decisions. Ld. AO after referring to the provision of section 2(22)(e) and how it is attracted in the case of the assessee, held that all the conditions as provided in the section are 5 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora applicable. The working of the deemed dividend based on various transactions appearing in the books of the company is as under:- Sr. No Document No. Posting Date Amount (Rs.) Cumulative (Rs.) 1 01/04/2016 (12,249,196) (12,249,196) 2 2,037,470,105 04/04/2016 67,500,000 55,250,804 3 2,037,470,309 11/04/2016 12,700,000 67,950,804 4 2,037,472,017 01/06/2016 9,200,000 77,150,804 5 2,005,180,653 09/06/2016 (3,000,000) 74,150,804 6 2,037,472,553 18/06/2016 (7,000,000). 67,150,804 7 2,005,180,937 18/06/2016 500,000 67,650,804 8 2,037,472,604 20/06/2016 4,000,000 71,650,804 9 2,004,150,638 27/06/2016 130,000,000 201,650,804 10 2,037,472,850 28/06/2016 16,800,000 218,450,804 11 2,037,473,265 30/06/2016 5,200,000 223,650,804 12 2,037,473,266 30/06/2016 600,000 224,250,804 13 2,005,180,986 16/07/2016 (5,000,000) 219,250,804 14 2,005,180,987 18/07/2016 (3,200,000) 216,050,804 15 2,037,474,270 30/07/2016 600,000 216,650,804 16 2,037,474,514 09/08/2016 500,000 217,150,804 17 2,046,966,933 24/08/2016 (3,400,000) 213,750,804 18 2,037,475,253 26/08/2016 600,000 214,350,804 19 2,037,475,265 30/08/2016 5,000,000 219,350,804 20 2,037,476,103 28/09/2016 7,700,000 227,050,804 6 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora 21 2,037,476,104 28/09/2016 5,200,000 232,250,804 22 2,037,476,105 28/09/2016 2,050,000 234,300,804 23 2,037,476,106 28/09/2016 600,000 234,900,804 24 2,005,181,979 01/10/2016 (3,400,000) 231,500,804 25 2,037,476,782 07/10/2016 100,000 231,600,804 26 2,037,476,783 13/10/2016 (77,197) 231,523,607 27 2,046,978,674 13/10/2016 80,000 231,603,607 28 2,037,476,992 17/10/2016 50,000 231,653,607 29 2,037,476,991 20/10/2016 40,000 231,693,607 30 2,037,477,082 24/10/2016 3,000,000 234,693,607 31 2,037,477,301 27/10/2016 5,000,000 239,693,607 32 2,037,477,695 28/10/2016 50,000 239,743,607 33 2,005,182,440 01/11/2016 (1,300,000) 238,443,607 34 2,005,181,985 03/11/2016 (5,000,000) 233,443,607 35 2,037,477,481 03/11/2016 50,000 233,493,607 36 2,037,477,464 04/11/2016 4,000,000 237,493,607 37 2,037,477,521 07/11/2016 400,000 237,893,607 38 2,013,060,116 12/11/2016 (3,400,000) 234,493,607 39 2,037,478,404 15/11/2016 100,000 234,593,607 40 2,013,060,123 21/11/2016 40,000 234,633,607 41 2,037,478,242 28/11/2016 40,000 234,673,607 42 2,005,182,369 06/12/2016 (10,000) 234,663,607 43 2,005,182,370 06/12/2016 (10,000) 234,653,607 7 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora 44 2,005,182,371 06/12/2016 (50,000) 234,603,607 45 2,005,182,372 06/12/2016 (50,000) 234,553,607 46 2,037,479,545 12/12/2016 10,000 234,563,607 47 2,005,182,439 15/12/2016 (3,400,000) 231,163,607 48 2,037,478,983 22/12/2016 650,000 231,813,607 49 2,037,479,301 04/01/2017 240,000 232,053,607 50 2,037,479,978 21/01/2017 42,500 232,096,107 51 2,005,182,991 24/01/2017 (3,400,000) 228,696,107 52 2,037,480,441 25/01/2017 45,000 228,741,107 53 2,037,480,442 25/01/2017 34,000 228,775,107 54 2,013,060,158 27/01/2017 15,000 228,790,107 55 2,037,480,448 01/02/2017 60,000 228,850,107 56 2,037,480,455 04/02/2017 60,000 228,910,107 57 2,037,480,531 07/02/2017 30,000 228,940,107 58 2,037,480,530 08/02/2017 800,000 229,740,107 59 2,005,183,194 13/02/2017 (50,000) 229,690,107 60 2,005,183,195 13/02/2017 (50,000) 229,640,107 61 2,005,183,196 13/02/2017 (40,000,000) 189,640,107 62 2,037,480,632 13/02/2017 (50,000) 189,590,107 63 2,037,480,710 13/02/2017 (50,000) 189,540,107 64 2,037,480,661 14/02/2017 40,000,000 229,540,107 65 2,037,480,709 14/02/2017 60,000 229,600,107 66 2,005,183,203 15/02/2017 70,000 229,670,107 67 2,037,480,716 15/02/2017 (3,400,000) 226,270,107 8 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora 68 2,037,480,806 18/02/2017 60,000 226,330,107 69 2,005,183,255 22/02/2017 (5,000,000) 221,330,107 70 2,037,481,059 23/02/2017 60,000 221,390,107 71 2,037,481,049 27/02/2017 12,500,000 233,890,107 72 2,037,481,143 28/02/2017 60,000 233,950,107 73 2,037,481,144 02/03/2017 60,000 234,010,107 74 2,037,481,505 06/03/2017 60,000 234,070,107 75 2,037,481,262 07/03/2017 30,000 234,100,107 76 2,037,481,506 08/03/2017 13,000 234,113,107 77 2,005,183,599 10/03/2017 (3,400,000) 230,713,107 78 2,037,481,504 14/03/2017 73,000 230,786,107 79 2,037,482,191 22/03/2017 73,000 230,859,107 I 80 2,005,183,602 24/03/2017 (275,000,000) (44,140,893) I 81 2,005,183,501 27/03/2017 73,000 (44,067,893) 82 2,037,482,195 27/03/2017 (190,000) (44,257,893) 83 2,013,060,190 31/03/2017 29,355,814 (14,902,079) 84 2,047,098,869 31/03/2017 13,592,465 (1,309,614) (1,309,614) 4. Accordingly, he treated an amount of Rs. 23,97,43,607/- as advance given by DDHF to the assessee as deemed dividend and taxed the same u/s 2(22)(e). 9 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora 5. Ld. CIT(A) after considering the findings given by the AO and submissions given by the assessee, deleted the said addition after observing as under:- The appellant has explained that the transaction between him and DEPL is not in the nature of loans and advances but in the nature of mutual, running current account transactions. The appellant also explained that he has not been benefitted by such transactions; hence, section 2(22)(e ) of the Act are not applicable. In order to understand the meaning of mutual, current and running account, the various judgments available on the subject. On perusal of above, it is observed that there is difference between loans or advances and mutual, running and current account transactions. Mutual, current and running account has the feature of mutuality which is not present in an advance or loan account. An account is running when transactions on one side are independent of the transactions on the other side. When an account contains numerous transactions with shifting balance i.e. favorable to one party at times and favorable to the other party at other times; such account is considered to be current and running. Current account the balance would be fluctuating debit to credit and credit to debit at regular intervals. Keeping the above principle in mind, ledger account of the appellant in the books of DEPL has been perused. On perusal of ledger account of the appellant in the books of DEPL, it is observed 10 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora that at various occasion, the DEPL owed amount to the appellant and at various other instances, the appellant owed amount to the DEPL. Thus, it is observed that the account has a shifting balance that is favourable to appellant at times and favourable to the DEPL at other times. Furthermore, in Limitation Act, 1963 various limitation is given for various transactions. As per the Schedule to the Limitation Act, 1963 and as per articles 1 and 19 thereto, the limitation period prescribed in the case of mutual, open and current account is three years from the close of the year in which the last item is admitted or proved as entered in the account. On the other hand, in the case of a loan, the limitation period is three years from the date on which the loan is made. On perusal of various judgments as well as Limitation Act, the legislature recognize loans or advances and mutual, current and running account separate and independent of each other. Keeping in view such difference between loans or advances and current account, the transaction in the case of the appellant is a mutual, current and running account and not loan. What section 2(22)(e) of the Act requires to make addition in the hand of the shareholder is receipt of loans or advances and not transaction of running account. In the present case, the transactions, as examined above, is in the nature of running account transaction. Thus, section 2(22)(e) of the Act has no application in present case. Therefore, the addition made by the AO cannot be sustained. 11 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora 6. After referring to various judgments, Ld. CIT(A) held that provision of deemed dividend u/s 2(22)(e) has no application in the case of the assessee. 7. Ld. DR submitted that here in this case there is no dispute that huge advances were given to the assessee and assessee being majority and beneficial shareholder, therefore all these advances are in the nature of deemed dividend. It is running or current account does not make difference and on various occasions, the credit balance was in the favour of the assessee, i.e., company owed more from the assessee during the year. However, at the end, there was a debited balance only. He thus, strongly relied on the order of AO. 8. Before us, Ld. Counsel for the assessee submitted that here in this case one peculiar fact which was already on record was that, as and when there was credit balance in the account of the assessee, the assessee has paid interest @ 13.1%. Even if it is treated that assessee has taken advance or loan, but he has paid interest to the company even if such advance was for a day. The opening balance was negative and so was the closing balance as on 31 st March 2017 12 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora and most of the time, the payments were due to the assessee by the company. He also pointed out that as per the company‟s policy, any loan and advance can be given to the employee, and he will be entitled for a loan up to his /her 24 months gross salary and the rate of interest shall be charged at such percentage calculated on the basis of SBI personal loan interest rate prevailing as on 1 st April of each financial year. Ld. Counsel drew our attention to „Employee Loan Policy‟ dated 01.04.2013 and submitted that assessee was employee in the company and salary of Rs. 26.24 crores from D‟ Decor Home Fabrics Pvt. Ltd. Thus, even if during the year assessee has received advances, it was in the nature of loan given to the company of employee on which assessee has actually paid interest of more than 13%. He further drew our attention to the ledger account as incorporated in the assessment order (incorporated supra) and pointed out that as on 1 st April 2016, there was negative balance of Rs. 1,22,49,196/- and thereafter it was running account and on the closing date, the negative balance was Rs. 13,09,614/-. Though, there was a positive balance during the year and most of the time, assessee has paid to the company and the company has earned substantial amount of interest from the assessee from such 13 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora advances /loans. Thus, it cannot be held that provision of deemed dividend u/s 2(22)(e) is attracted. In support of his contention, he strongly relied on the decision of ITAT Kolkata Bench in the case of Smt Sangita Jain vs. ITO (ITA No. 1817/Kol/2009 dated 11.03.2016), judgment of Hon‟ble Karnataka High Court in the case of CIT vs. N. S. Narendra (IT Appeal No. 92 of 2015 dated 29 th June 2021) and decision of Hon‟ble Kolkata High Court in the case of Pradip Kumar Malhotra vs. CIT (338 ITR 0538 Cal HC). 9. We have heard the rival submissions and also perused the relevant findings given in the impugned orders as well as material placed on record. On perusal of the ledger account of the assessee and books of the company, D‟ Decor Home Fabrics Pvt. Ltd., we find that there has been a continuous transaction whereby advances have been given to the assessee and assessee has been returning back the money to the company immediately or in the short interval. Ld. AO has treated the peak amount dated 28.10.2016 of Rs 23,97,43,607/- as deemed dividend holding that on that date there was a maximum credit balance. Even if advances have been received by the assessee from the company which can be reckoned 14 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora as loan, however it has been brought on record that there was Employee Loan Policy dated 01.04.2013 of D‟ Decor Home Fabrics Pvt. Ltd. which was available on record before the lower authorities, which provides that loan can be granted to its employees including managing directors, whole time directors and the directors who have two years or more confirmed services with the company will be entitled to a loan up to his /her 24 months of gross salary even the rate of interest of such loan were also provided which was charged from the employee including the managing directors, whole time directors and the directors. The relevant terms of the policy reads as under:- 1. The purpose of this Policy of D' Decor Home Fabrics Private Limited ("Company'') is to lay down the limits of the loan entitlement and the procedure for the same. Eligibility 2. a) All employees who have more than one year confirmed service with the Company can apply for a loan. b) This is a welfare activity; hence loan cannot be demanded as a matter of right. While recommending loan, the CEO/ CFO / HOD shall ensure that sufficient safe guards have been provided for the recovery of the money from the individual. 15 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora Types of Loans 3. There are 'two' types of loans that the Company may grant to its employees including Managing Director, Whole Time Directors and Directors: a) Interest Free Loan. An eligible employees may get a loan of up to his / her three months gross salary. b) Loan with Interest. This will have the following two limits:- (i) The employees who have less than two years of confirmed, service with the Company will be entitled to a loan (including interest) of up to his / her twelve months gross salary. (ii) The employees who have two years or more of confirmed service with the company will be entitled to a loan "(including interest) of up to his / her twenty four months gross salary. Rate of Interest 4. (a) The rate of interest shall be decided by the CFO along with Corporate HR/Admin Department every year in the month of April. (b) The rate of interest for the year 2013-14 and onwards: Interest shall be charged at such percentage basis the State Bank of India' personal loan interest rates prevailing as on April 1 of each financial year, or such higher rate as may be decided by the approving authority, on monthly reducing balance basis. 16 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora (c) The loans already sanctioned till the effective date of this policy, will conditions as sanctioned at the lime of disbursement. Recovery of Loan 5. Interest free loan (Refer paragraph 3 (a) above) will be recovered in maximum twelve equal monthly installments from the month in which the amount is paid to the employee. 6. The loan with interest will be recovered in maximum 24 equal monthly instalments from the month in which the amount is paid to the employee. 7. The HR department shall ensure that the total liability of an individual towards repayment of loan (from all sources put together) does not exceed 200% of his/her gross annual salary. 8. In case an employee resigns or ceases to be in the service of the company due to any reason. he/she will have to liquidate the loan outstanding against his/her name before full and final settlement of his/her dues. 9. The Company will have a right to adjust the loan amount from PF / Gratuity / any other dues etc. payable to an employee. 10. Further as submitted by Ld. Counsel, the assessee has paid interest to the company @ 13% on every credit balance appearing in the books of the company, i.e., if by the month end there is credit balance, the company has charged 13% interest per annum. Once the advance and loans are interest bearing advance and the 17 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora company has benefitted hugely from such advances, then it cannot be treated as company has given advances or loans to the benefit of the shareholders or to its detriment. 11. The Hon‟ble Calcutta High Court in the case of Pradip Kumar Malhotra reported in 338 ITR 538 has held that the phrase “by way of advance or loan” appearing in section 2(22)(e) must be construed to mean those advances or loans, which a shareholder enjoys for simply on account of being a partner, who is the beneficial owner of shares, but if such loan or advance is given to such shareholder as a consequence of any further consideration, which is beneficial to the Company, received from such shareholder, in such case, such advance or loan cannot be said to be deemed dividend within the meaning of the Act. It was held that gratuitous loan or advance given by a Company to those classes of shareholders thus would come within the purview of section 2(22)(e) but not the cases where the loan or advance is given in return to an advantage conferred upon the Company by such shareholder. The same principle applied by the Tribunal in the case of Sangeeta Jain (supra). Thus, here in this case, the loan and advance given to the assessee is for 18 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora consideration on which the company has benefitted and therefore, following the principle laid down by the Hon‟ble Calcutta High Court, the same cannot be termed as divided income. 12. CBDT vide circular no. 19/2017 dated 12 th June 2017 while clarifying the view to section 2(22)(e) had stated that if the advance are in the nature of commercial transaction, then same would not fall within the ambit of word „advance‟ in section 2(22)(e) of the Act. Here, the advance is in the nature of commercial transaction since that the company has received interest from such advance given. Therefore, in our view the provision of deemed dividend cannot be invoked once the company is benefitted on such transaction. On this ground, we do not find any reason for invoking deemed provision of section 2(22)(e), because there is no benefit which was given to the shareholders, i.e.,s the assessee by the company by giving such advances. Accordingly, on this reason, the addition on account of deemed dividend is deleted. 13. In the result, the appeal filed by the revenue stands dismissed. Orders pronounced in the open court on 22 nd November, 2022. 19 I . T . A . N o . 2149/ M u m / 2 0 2 1 Shri Ajay Virendra Arora Sd/- Sd/- (S. Rifaur Rahman) (Amit Shukla) Accountant Member Judicial Member मुंबई Mumbai;ददनांक Dated : 22/11/2022 Sr.PS. Dhananjay आदेशकीप्रनिनिनिअग्रेनर्ि/Copy of the Order forwarded to : 1. अपीलाथी/ The Appellant 2. प्रत्यथी/ The Respondent 3. आयकरआयुक्त(अपील) / The CIT(A) 4. आयकरआयुक्त/ CIT- concerned 5. दवभागीयप्रदतदनदध, आयकरअपीलीयअदधकरण, मुंबई/ DR, ITAT, Mumbai 6. गार्डफाईल / Guard File आदेशधिुसधर/ BY ORDER, .उि/सहधयकिंजीकधर (Dy./Asstt.Registrar) आयकरअिीिीयअनर्करण, मुंबई/ ITAT, Mumbai
Other Referred Cases
Tarulata Shyam & Ors. Vs. CIT(SC) 108 ITR 345, Sarada Vs. CIT (SC) 229 ITR 444, Smt Sangita Jain vs. ITO (ITA No. 1817/Kol/2009), CIT vs. N. S. Narendra (IT Appeal No. 92 of 2015), Pradip Kumar Malhotra vs. CIT (338 ITR 0538 Cal HC)
Laws Referred To
Income Tax Act, 1963, Limitation Act, 1963
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