AI Insights
The case involves three Miscellaneous Applications (MA No. 36, 37, and 38/SRT/2022) filed by Ravjibhai Bechabhai Dhameliya, the proprietor of M/s. Amrut Exports, against the Deputy Commissioner of Income Tax, Circle-3(3), Surat. The applications were filed seeking rectification of the Tribunal's order dated 06.01.2022, which had relied on a precedent set in the case of Pankaj K. Choudhary. The assessee contended that the facts of his case were different, particularly in terms of the Gross Profit (GP) and Net Profit (NP) ratios compared to those in the Choudhary case. The Tribunal, however, found no apparent mistake in its earlier order and dismissed the applications, citing the lack of new evidence or change in circumstances that would warrant a departure from the established precedent.
Appeal Details
Counselvise Citation
[2023] 140 COUNSELVISE.COM (IT) 301711 (ITAT-SURAT)
Assessee PAN
Bench
Appeal Number
CRN Number
Duration Of Justice
1 year(s) 1 month(s) 7 day(s)
Appellant
Respondent
Appeal Type
Miscellaneous Application
Pronouncement Date
16-07-2023
Appeal Filed By
Assessee
Order Result
Dismissed
Bench Allotted
DB
Next Hearing Date
01-06-2023
Assessment Year
2007-2008
Appeal Filed On
09-06-2022
Judgement Text
IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JM & DR. A. L. SAINI, AM Miscellaneous Application No.36/SRT/2022 [Arising in ITA No. 1239/AHD/2017] Assessment Year: (2007-08) (Physical Hearing) Ravjibhai Bechabhai Dhameliya, Prop. M/s. Amrut Exports, Vrajshila Nr. Gajjar Petrol Pump, Kapodara Char Rasta, Varachha Road, Surat. Vs. The DCIT, Circle-3(3), Surat. (Appellant) (Respondent) èथायीलेखासं./जीआइआरसं./PAN/GIR No.: ACCPD5423C Miscellaneous Application No.37/SRT/2022 [Arising in ITA No. 1240/AHD/2017] Assessment Year: (2008-09) Ravjibhai Bechabhai Dhameliya, Prop. M/s. Amrut Exports, Vrajshila Nr. Gajjar Petrol Pump, Kapodara Char Rasta, Varachha Road, Surat. Vs. The DCIT, Circle-3(3), Surat. (Appellant) (Respondent) èथायीलेखासं./जीआइआरसं./PAN/GIR No.: ACCPD5423C Miscellaneous Application No.38/SRT/2022 [Arising in ITA No. 1241/AHD/2017] Assessment Year: (2013-14) Ravjibhai Bechabhai Dhameliya, Prop. M/s. Amrut Exports, Vrajshila Nr. Gajjar Petrol Pump, Kapodara Char Rasta, Varachha Road, Surat. Vs. The DCIT, Circle-3(3), Surat. (Appellant) (Respondent) èथायीलेखासं./जीआइआरसं./PAN/GIR No.: ACCPD5423C Appellant by Shri Sapnesh Sheth, CA Respondent by Shri Vinod Kumar, Sr. DR Date of Hearing 02/06/2023 Date of Pronouncement 17/07/2023 आदेश / O R D E R Page | 2 MA.36 to 38/SRT/2022 Ravjibhai B. Dhameliya PER DR. A. L. SAINI, AM: By way of these three Miscellaneous Applications, the assessee has sought to point out that a mistake apparent from record within the meaning of section 254(2) of the Income Tax Act, 1961 (in short ‘the Act’) has crept in the order of the Tribunal dated 06.01.2022. 2. Since, the issue involved in all these Miscellaneous Applications, are common and identical, therefore these Miscellaneous Application have been clubbed and heard together and a consolidated order is being passed for the sake of convenience and brevity. The facts as well as contention raised by the assessee in Miscellaneous Application No.36/SRT/2022, have been taken into consideration for deciding these three Miscellaneous Applications. 3. The facts as well as contention raised by the assessee in lead Miscellaneous Application No.36/SRT/2022, are as follows: “1. In the above case, assessee filed an appeal before Honourable ITAT against the order of CIT (A) dated 21.03.2017. In the said order Honourable ITAT has relied on the ITAT Surat Bench Order passed in the case of Pankaj K. Choudhary [ ITA No. 1379/Ahd/2017] claiming that the issue in the case of assessee is squarely covered by the decision of Pankaj K. Choudhary and there is no change in facts and law. 2. In this regard, it is submitted that the facts of assessee's case and Pankaj K. Choudhary are totally different as there is a huge difference between the GP and NP ratio & also the amount of income offered for taxation by assessee and Pankaj K. Choudhary. It is relevant to mention here that during the course of hearing we have filed a chart for various assessment years showing amount of purchases, addition made, % of total purchases & G.P%. The same is reproduced hereunder:- Assessment Years 2007-08 2008-09 2013-14 Total purchases 951460460 1069681387 2749551856 Addition 84762961 179986565 78047828 Page | 3 MA.36 to 38/SRT/2022 Ravjibhai B. Dhameliya % of total purchases 8.91% 16.83% 2.84% G.P% 8.13% 5.509 6.06% 3. Further the N.P ratio in assessee's case for above years is as under:- AY 2007-08 2008-09 2013-14 N.P Ratio 4.89% 2.75% 2.67% 4. Now if comparison of gross profit and net profit ratio of assessee's case is made with the case of Pankaj Choudhary then it will be apparent that income offered by assessee & his G.P & N.P ratio is mucn better. This is evident on perusal of following table:- A.Y. 2007-08 2007-08 Amrut Export (Assessee) Pankaj K. Choudhary GP Ratio 8.13% 0.78% Net Profit 3,64,48,227 Not available NP Ratio 4.89% 0.02% 5. From the above comparison it is apparent that G.P ratio of Pankaj K. Choudhary is 10 times lower and N.P Ratio is 244.5 times lower than what is declared by assessee for the year under consideration. Therefore, facts of assessee's case are much better as he has already offered much higher income compared to Pankaj K. Choudhary and thus, quantum of disallowance of purchases should be either Nil or at a rate much lower than the rate of 6% adopted in case of Pankaj Choudhary. 6. It is not clear from the order of Honourable IT AT in assessee's case the specific rate at which disallowance of purchases has been upheld as in para no. 20 specific percentage at which disallowance is to be made in assessee's case is not stated. Further in para 21 of the said order it is written that appeals of the assessee are dismissed and appeals of revenue are allowed to the extent indicated above. If disallowance is to be made as per the order passed in case of Pankaj Choudhary in that case the appeal of revenue will stand partly allowed. 7. It is therefore, prayed that suitable modification may kindly be made to the order of Hon'ble ITAT in assessee’s case in the interest of justice and the assessee shall always remain grateful for the act of kindness.” 4. Therefore, Ld. Counsel contended that Gross Profit Ratio and Net Profit Ratio is higher side in case of these three assessees`, hence the Page | 4 MA.36 to 38/SRT/2022 Ravjibhai B. Dhameliya Tribunal should not have made addition at the rate of 6% rather it should be at the rate of 5%, that is, addition sustained by the Ld. CIT(A). 5. On the other hand, Learned Departmental Representative (Ld. DR) for the Revenue submitted that Tribunal has passed the speaking order on merit and therefore there is no apparent mistake on record, hence the Miscellaneous Application filed by the assessee should be dismissed. 6. We have heard both the parties and perused the material available on record. We note that Tribunal has concluded the issue on merit, observing as follows: “19. We note that so far merit is concerned, the issue is squarely covered by the judgment of the Coordinate Bench in the case of Pankaj K. Choudhary, in ITA No.1152/AHD/2017 (AY 2007-08), order dated 27.09.2021, wherein the Coordinate Bench held as follows: “12. We have heard the submission of ld.CIT-DR for the Revenue and the ld. Authorised Representative (AR) of the assessee. We have also gone through the various documentary evidences furnished by assessee. The ld. CIT-DR for the Revenue supported the order of AO. The ld. CIT-DR submits that Investigation Wing, Mumbai made a search on Bhanwarlal Jain Group. During the search and after search, the Investigation Wing made a thorough investigation and concluded that Bhanwarlal Jain Group and his associates including his sons were indulging in managing about 70 benami concerns. The benami concerns were engaged in providing accommodation entries. The assessee is one of the beneficiaries of such accommodation entries. In the transaction of accommodation entries, the documentary evidences are created in such a way, so that the bogus transaction is looks like genuine transaction. In bogus transaction, the fabricated evidences are always maintained perfectly. The assessee has obtained accommodation entry only to inflate the expenses and to reduce the ultimate profit. No stocks of diamonds were found at the time of search on Bhanwarlal Jain Group. The assessee has shown a very meagre gross profit (GP) @ 0.78% and not net profit (NP) at 0.02%. The ld. CIT(A) restricted the addition to the extent of 12.5% which is on the lower side. The ld. CIT-DR for the revenue prayed that disallowance made by the AO may be upheld or in alternative submitted that it may restricted at least @ 25%, keeping in view that the NP declared by the assessee is extremely on lower side. 13.On the validity of reopening, the ld.CIT-DR for the revenue submits that the AO received credible information about the accommodation Page | 5 MA.36 to 38/SRT/2022 Ravjibhai B. Dhameliya entry provided by Bhanwarlal Jain Group. The assessee is one of the beneficiaries, who had availed accommodation entries from such hawala trader. At the time of recording reasons, the mere suspicious about the accommodation entry is sufficient as held by Hon'ble jurisdictional High Court in various cases. To support his submissions, the ld.CIT-DR relied upon the decision; Pushpak Bullion (P) Ltd Vs DCIT [2017] 85 taxmann.com 84 (Gujarat High Court), Peass Industrial Engineers (P) Ltd Vs DCIT [2016] 73 taxmann.com 185 (Gujarat High Court), ITO Vs Purushttom Dass Bangur [1997} 90 Taxman 541 (SC) and Mayank Diamond Private Limited (2014) (11) TMI 812 (Gujarat High Court). AGR Investment Vs Additional Commissioner 197 Taxman 177 (Delhi) and Chuharmal Vs CIT [1998] 38 Taxman 190 (SC). 14. On the other hand, the ld.AR of the assessee submits that he has challenged the validity of reopening as well as restricting the addition to the extent of 12.50% of the alleged bogus purchases. The ld.AR of the assessee submits during the assessment, the AO has not made any independent investigation. The AO reopened the case of the assessee on the basis of third party information without making any preliminary investigation. The AO received vague information about providing accommodation entry by Bhanwarlal Jain Group. No specific information about the accommodation entry obtained by assessee was received by AO. There is no live link between the reasons recorded qua the assessee. Therefore, the re-opening is invalid and all subsequent action is liable to be set aside. 15. On account of additions of bogus purchases, the ld.AR submits that in the original assessment, the assessee filed its complete details of purchases to prove the genuineness of expenses. The AO accepted the same in the assessment order passed under section 143(3) on 10.03.2009. During re-assessment, the assessee again furnished complete details about the genuineness of purchases. The assessee filed confirmation purchases invoices, accounts of the parties, bank statement of assessee showing transaction to the banking channel. The AO has not made any comment on the documentary evidence furnished by assessee. The AO solely relied upon the statement of third party and the report of Investigation Wing. The report of wing and the statement of Bhanwarlal Jain were not provided to the assessee. The AO has not disputed the sales of assessee. No sale is possible in absence of purchase. The books of accounts were not rejected. The AO made the disallowance of entire purchases. The assessing officer not provided cross examination of the alleged hawala dealers. The disallowances sustained by the Ld. CIT(A) @ 12.5% of the impugned purchases, is on higher side and deserve to be deleted in Page | 6 MA.36 to 38/SRT/2022 Ravjibhai B. Dhameliya total. The ld.AR of the assessee submits that entire purchases shown by assessee are genuine. In without prejudice and alternative submissions, the Ld. AR for the assessee submits that in alternative submission, the disallowance may be sustained on reasonable basis. To support his various submission, the ld.AR for the assessee is relied upon case laws: 1 M/s Andaman Timber industries VsCommissioner of Central Excise, CIVIL APPEAL NO. 4228 OF 2006 (Supreme Court) 2 CIT vs. Indrajit Singh Suri [2013] 33 taxmann.com 281 (Gujarat) 3 Albers Diamonds Pvt. Ltd. Vs ITO 1(1)(1), Surat I.T.A. No.776 &1180/AHD/2017 4 The PCIT-5 vs. M/s. Shodiman Investments Pvt. Ltd. TTANO. 1297 OF 2015 (Bombay High Court) 5 ShilpiJewellers Pvt. Ltd. vs. Union of India &Ors. WRIT PETITION NO. 3540 OF 2018 (Bombay High Court) 6 CIT in Vs. Mohmed Juned Dadani 355 ITR 172 (Gujarat) 7 Micro Inks Pvt. Ltd. Vs. ACIT [2017] 79 taxmann.com 153 (Gujarat) 8 Shakti Karnawat Vs. ITO - 2(3)(8), Surat ITA 1504/Ahd/2017 and 1381 /Ahd/2017 9 Asian Paints Ltd. Vs. DCIT, [2008] 296 ITR 90 (Bombay) 10 PCIT, Surat 1 Vs. Tejua Rohit kumar Kapadia [2018] 94 taxmann.com 325 (SC) 11 The PCIT-17 vs. M/s Mohommad Haji Adam & Co. ITA NO. 1004 OF 2016(Bombay High Court) 12 Pankaj Kanwarlal Jain HUF Vs. ITO 2(3)(8) Surat ITA.No.269/SRT/2017 16. In the rejoinder submissions the ld. CIT-DR for the revenue submits that that rigour of the rules of evidence contained in the Evidence Act is not applicable before the tax authorities. It was submitted that the ratio of various case laws relied by the ld. AR for the assessee is not applicable on the facts of the present cases. The ratio of decision of Hon’ble Gujarat High Court in Mayank Diamond Private Limited (supra) is directly applicable on the facts of the present case. 17. We have considered the submissions of the parties and have gone through the order of the lower authorities. We have also deliberated on each and every case laws relied by both the parties. We have also examined the financial statement of all the assessee(s) consisting of computation of income and audit report. We have also gone through the documentary evidences furnished in all cases. Ground No.1 in assessee’s appeal relates to the validity of reopening. The ld AR for the assessee vehemently argued that the AO reopened the case of the assessee on the basis of third party information, and without making any preliminary investigation, which was vague about the alleged accommodation entry by Bhanwarlal Jain Group. And that there was no specific information about the accommodation entry availed by the Page | 7 MA.36 to 38/SRT/2022 Ravjibhai B. Dhameliya assessee. There is no live link between the reasons recorded qua the assessee. We find that the assessee has raised objection against the validity of the reopening before the AO. The objections of the assessee was duly disposed by AO in his order dated 09.02.2015. The assessee raised ground of appeal before ld CIT(A) while assailing the order of AO on reopening. The ld CIT(A) while considering the ground of appeal against the reopening held that the AO has received report from investigation wing Mumbai, which indicate that the assessee is beneficiary of the accommodation entry operators. The accommodation entry provider admitted before investigation wing that he has given such entry to various persons; based on such report the AO has reason to believe that the income of the assessee has escaped assessment and thus the action of AO in reopening is justified. 18. We find that the Hon’ble Jurisdictional High Court in Peass Industrial Engineers (P) Ltd Vs DCIT (supra) while considering the validity of similar notice of reopening, which was also issued on the basis of information of investigation wing that they have searched a person who is engaged in providing accommodation entries, held that where after scrutiny assessment the assessing officer received information from the investigation wing that well known entry operators of the country provided bogus entries to various beneficiaries, and assessee was one of such beneficiary, assessing officer was justified in re-opening assessment. Further similar view was taken by Hon’ble Jurisdictional High Court in Pushpak Bullion (P) Ltd Vs DCIT (supra). Therefore, respectfully following the order of Hon’ble High Court, we find that the assessing officer validly assumed the jurisdiction for making re-opening under section 147 on the basis of information of investigation wing Mumbai. So far as other submissions of the ld AR for the assessee that there is no live link of the reasons recorded, we find that the Hon’ble Jurisdictional High Court in Peass Industrial Engineers (P) Ltd clearly held that when assessing officer received information from the investigation wing that two well known entry operators of the country provided bogus entries to various beneficiaries, and assessee was one of such beneficiary, assessing officer was justified. Hence, the ground No. 1 in assessee’s appeal is dismissed. 19. Ground No. 2 in assessee’s appeal and the grounds of appeal raised by the revenue are interconnected, which relates to restricting the disallowance of bogus purchases to the extent of 12.5%. The AO made of 100% of purchases shown from the hawala dealers/ entry provider namely Bhanwarlal Jain. We find that the AO while making additions of 100%, of disputed purchases solely relied on the report of the investigation wing Mumbai. No independent investigation was carried by the AO. The AO has not disputed the sale of the assessee. The AO made no comment on the evidences furnished by the assessee. We further find that ld CIT(A), while considering the submissions of the assessee accepted the lapses on the part of the AO and noted that no sale is possible in absence of purchases. The Books of the assessee Page | 8 MA.36 to 38/SRT/2022 Ravjibhai B. Dhameliya was not rejected by the AO. The ld CIT(A) on further examination of the facts and various legal submissions find that Ahmedabad Tribunal in Bholanath Poly Fab Private Limited (supra) held that in the such cases the addition of bogus purchases was sustained to the extent of 12%, on the observation that the assessee may have made purchases from elsewhere and obtained the bills from impugned supplier to inflate Gross Profit Rate. The ld CIT(A) by considering the overall facts, concluded that the 100% disallowance of purchase is not justified. We also find that the ld.CIT(A) also considered the decision of jurisdictional High Court in Mayank Diamonds Pvt. Ltd. (supra) and compared the fact of the present case with the facts in Mayank Diamonds Pvt Ltd (supra) and noted that assessee in that case was also engaged in the trading of polished diamonds. The ld CIT(A) noted that in that case the AO made disallowance of entire bogus purchase and on first appeal before CIT(A) the disallowances were maintained. However, the Tribunal gave partial relief to the assessee directing to sustain the addition @12% of such bogus purchases. And on further appeal, the Hon'ble High Court sustained Gross Profit Rate @ 5% being average rate of profit in industry. 20. Now adverting to the facts of the present case, the ld.CIT(A) held that in some other similar cases; though he had sustain 5% of Gross Profit Rate, considering the fact that where Gross Profit shown by those assessee’s are more than 5%. However, in the present case, the assessee has merely shown Gross Profit Rate only at 0.78% of turnover, accordingly, the ld. CIT(A) was of the view that disallowance of 12.5% of impugned purchases/bogus purchases would be reasonable to meet the end of justice. 21. We have seen that during the financial year under consideration the assessee has shown total turnover of Rs. 66,09,62,458/-. The assessee has shown Gross Profit @ .78% and net Profit @ .02% (page 11 of paper Book). The assessee while filing the return of income has declared taxable income of Rs. 1,81,840/- only. We are conscious of the facts that dispute before us is only with regard of the disputed purchases of Rs, 4.34 Crore, which was shown to have purchased from the entity managed by Bhanwarlal Jain Group. During the search action on Bhanwarlal Jain no stock of goods/ material was found to the investigation party. Bhanwarlal Jain while filing return of income has offered commission income (entry provider). Before us, the ld CIT- DR for the revenue vehemently submitted that the ratio of decision of Hon’ble Gujarat High Court in Mayank Diamond Private Limited (supra) is directly applicable on the facts of the present case. We find that in Mayank Diamonds the Hon’ble High Court restricted the additions to 5% of GP. We have seen that in Mayank Diamonds P Ltd (supra), the assessee had declared GP @ 1.03% on turnover of Rs. 1.86 Crore. The disputed transaction in the said case was Rs. 1.68 Crore. However, in the present case the assessee has declared the GP @ 0.78%. It is settled law that under Income-tax, the tax authorities are not entitled to tax the entire transaction, but only the income Page | 9 MA.36 to 38/SRT/2022 Ravjibhai B. Dhameliya component of the disputed transaction, to prevent the possibility of revenue leakage. Therefore, considering overall facts and circumstances of the present case, we are of the view that disallowances @ 6% of impugned purchases / disputed purchases would be sufficient to meet the possibility of revenue leakage. In the result the ground No. 2 of appeal raised by the assessee is partly allowed and the grounds of appeal raised by revenue are dismissed. 22. In the result the appeal of revenue is dismissed and the appeal of the assessee is partly allowed.” 20. We see no reasons to take any other view of the matter than the view so taken by the Coordinate Bench of this Tribunal in the case Pankaj K. Choudhary (supra), vide order dated 27.09.2021. As the issue is squarely covered by the decision of the coordinate bench, and there is no change in facts and law and the Ld. Counsel is unable to produce any material to controvert the aforesaid findings of the Coordinate Bench (supra). We find no reason to interfere in the said order of the Coordinate Bench, therefore, respectfully following the judgment of the Coordinate Bench, we dismiss all appeals of the assessee and we allow the appeal of the Revenue to the extent indicated above. 21. In the result, appeals of the Assessee are dismissed and appeals of Revenue are allowed to the extent indicated above. 7. Before we proceed to adjudicate this issue, let us first consult the provisions of section 254(2) of the Act, which reads as follows: “Orders of Appellate Tribunal “254. (2) The Appellate Tribunal may, at any time within [six months from the end of the month in which the order was passed], with a view to rectifying any mistake apparent from the record, amend any order passed by it under sub-section (1), and shall make such amendment if the mistake is brought to its notice by the assessee or the [Assessing] Officer. Provided that an amendment which has the effect of enhancing an assessment or reducing a refund or otherwise increasing the liability of the assessee, shall not be made under this sub-section unless the Appellate Tribunal has given notice to the assessee of its intention to do so and has allowed the assessee a reasonable opportunity of being heard : [Provided further that any application filed by the assessee in this sub- section on or after the 1st day of October, 1998, shall be accompanied by a fee of fifty rupees.]” 8. Having gone through sub-section 2 of section 254 of the Act, as noted above, we observed that “any mistake apparent from the record” can be rectified.The plain meaning of the word 'apparent' is that it must be something which appears to be ex-facie and incapable of argument Page | 10 MA.36 to 38/SRT/2022 Ravjibhai B. Dhameliya and debate. Thus, section 254(2) of the Act does not cover any mistake which may be discovered by a complicated process of investigation, argument or proof. Therefore, amendment of an order under section 254(2) of the Act, does not mean entire obliteration of order originally passed by the Tribunal and its substitution by a new order of Tribunal, this is not permissible under section 254(2) of the Act. Power to rectify an order, under section 254(2) of the Act is extremely limited and it does not extend to correcting errors of law, or re-appreciating factual findings. Therefore, considering these facts and circumstances, we are of the view that there is no mistake apparent from record in the order of Tribunal, hence we dismiss these three Miscellaneous Applications. 9. In the result, these three Miscellaneous Applications (36, 37, and 38/SRT/2017) filed by the assessee are dismissed. Registry is directed to place one copy of this order in all appeals folder / case files. Order is pronounced on 17/07/2023 in the open court. Sd/- Sd/- (PAWAN SINGH) (Dr. A.L. SAINI) JUDICIAL MEMBER ACCOUNTANT MEMBER lwjr /Surat Ǒदनांक/ Date: 17/07/2023 SAMANTA Copy of the Order forwarded to 1. The Assessee 2. The Respondent 3. The CIT(A) 4. CIT 5. DR/AR, ITAT, Surat 6. Guard File By Order // TRUE COPY // Assistant Registrar/Sr. PS/PS ITAT, Surat
Other Referred Cases
Pankaj K. Choudhary [ ITA No. 1379/Ahd/2017], Mayank Diamond Private Limited (2014) (11) TMI 812 (Gujarat High Court), Pushpak Bullion (P) Ltd Vs DCIT [2017] 85 taxmann.com 84 (Gujarat High Court), Peass Industrial Engineers (P) Ltd Vs DCIT [2016] 73 taxmann.com 185 (Gujarat High Court), ITO Vs Purushttom Dass Bangur [1997} 90 Taxman 541 (SC), AGR Investment Vs Additional Commissioner 197 Taxman 177 (Delhi), Chuharmal Vs CIT [1998] 38 Taxman 190 (SC), Andaman Timber industries Vs Commissioner of Central Excise, CIVIL APPEAL NO. 4228 OF 2006 (Supreme Court), CIT vs. Indrajit Singh Suri [2013] 33 taxmann.com 281 (Gujarat), Albers Diamonds Pvt. Ltd. Vs ITO 1(1)(1), Surat I.T.A. No.776 &1180/AHD/2017, The PCIT-5 vs. M/s. Shodiman Investments Pvt. Ltd. TTANO. 1297 OF 2015 (Bombay High Court), Shilpi Jewellers Pvt. Ltd. vs. Union of India & Ors. WRIT PETITION NO. 3540 OF 2018 (Bombay High Court), CIT in Vs. Mohmed Juned Dadani 355 ITR 172 (Gujarat), Micro Inks Pvt. Ltd. Vs. ACIT [2017] 79 taxmann.com 153 (Gujarat), Shakti Karnawat Vs. ITO - 2(3)(8), Surat ITA 1504/Ahd/2017 and 1381 /Ahd/2017, Asian Paints Ltd. Vs. DCIT, [2008] 296 ITR 90 (Bombay), PCIT, Surat 1 Vs. Tejua Rohit kumar Kapadia [2018] 94 taxmann.com 325 (SC), The PCIT-17 vs. M/s Mohommad Haji Adam & Co. ITA NO. 1004 OF 2016(Bombay High Court), Pankaj Kanwarlal Jain HUF Vs. ITO 2(3)(8) Surat ITA.No.269/SRT/2017
Laws Referred To
Income Tax Act, 1961
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