Andaman Timber Industries v. CCE

281 CTR 241Supreme Court of India2015#32 most cited

What is Andaman Timber Industries v. CCE authority for?

An assessee must be given an opportunity to cross-examine third parties whose statements are relied upon for adverse findings. Failure to provide this opportunity is a serious flaw rendering the order a nullity.

1,335

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2016 to 2026.

Also referred to as

Andaman Timber Industries · cross-examination · third party information · principles of natural justice · adverse inference · retraction of statement · section 132(4) · section 143(3) · nullity of order · denial of cross-examination

Also reported as

62 Taxmann.com 3127 DTR 241324 ELT 6412015 SCC OnLine SC 1051

Sections most often in play

Section 143(3)Section 153CSection 132Section 132(4)Section 69Section 147Section 153ASection 148

Issues it is cited on

third party informationsection 65section 65bpreponderance of probabilitysection 131(1a)retracted statementsection 132(4a)on-moneysection 69bdumb documentsbogus ltcgstatement under section 132(4)

Judgments citing Andaman Timber Industries v. CCE

ACIT CC-7(1), Mumbai vs. Shri Shreyas Vasant Parikh, Mumbai

In the result, the appeal of the revenue as well as cross-objection of the assessee are dismissed

ITA 1580/MUM/2021[2017-18]Status: DisposedITAT Mumbai10 Oct 2022AY 2017-18

Bench: Shri Aby T. Varkey, Jm & Shri Amarjit Singh, Am आयकर अपील सं/ I.T.A. No.1580/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2017-18) Acit, Cc-7(1) बिधम/ Shreyas Vasant Parikh R. No.676B, 6Th Floor, 5 Raj Mayur, 19Th Road, Vs. Aayakar Bhavan, M. K. Khar (W), Mumbai- Road, Road, Mumbai- 400052. 400020. Cross Objection No. 30/Mum/2022 Arising Out Of I.T.A. No.1580/Mum/2021 (निर्धारण वर्ा / Assessment Years: 2017-18) Shreyas Vasant Parikh Acit, Cc-7(1) बिधम/ 5 Raj Mayur, 19Th Road, R. No.676B, 6Th Floor, Vs. Khar (W), Mumbai-400052. Aayakar Bhavan, M. K. Road, Road, Mumbai- 400020. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaepp1118J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri V. R. Choksi Revenue By: Shri Amit Kumar Soni सुनवाई की तारीख / Date Of Hearing: 13/07/2022 घोषणा की तारीख /Date Of Pronouncement: 10/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm:

For Appellant: Shri V. R. ChoksiFor Respondent: Shri Amit Kumar Soni
Section 153CSection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI ABY T. VARKEY, JM AND SHRI AMARJIT SINGH, AM आयकर अपील सं/ I.T.A. No.1580/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2017-18) ACIT, CC-7(1) बिधम/ Shreyas Vasant Parikh R. No.676B, 6th Floor, 5 Raj Mayur, 19th Road, Vs. Aayakar Bhavan, M. K. Khar (W), Mumbai- Road, Road, Mumbai- 400052. 400020. Cross Objection No. 30/Mum/2022 Arising out of I.T.A. No.1580/Mum/2021 (निर्धारण वर्ा / Assessment Years: 2017-18) Shreyas Vasant Parikh ACIT, CC-7(1) बिधम/ 5 Raj Mayur, 19th Road, R. No.676B, 6th Floor, Vs. Khar (W), Mumbai-400052. Aayakar Bhavan, M. K. R…

Chandrakant Narshi Dedhia, Mumbai vs. CIT-(A)-28 NFAC, Mumbai

ITA 505/MUM/2022[2017-18]Status: DisposedITAT Mumbai29 Sept 2022AY 2017-18

Bench: Shri Kuldip Singh

For Appellant: NoneFor Respondent: Shri Anil Gupta, D.R
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “SMC”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER ITA Nos.504 & 505/M/2022 Assessment Years: 2016-17 & 2017-18 Shri Chandrakant N. CIT(A)-28, NFAC, Dedhia, Mumbai 501-6 New Anant Bhuvan, Vs. Narshi Natha Street Bhat Bazar, Mumbai – 400 009 PAN: AABPD2996F (Appellant) (Respondent) Present for: Assessee by : None Revenue by : Shri Anil Gupta, D.R. Date of Hearing : 27. 09 . 2022 Date of Pronouncement : 29. 09 . 2022 O R D E R Per : Kuldip Singh, Judicial Member: Since common questions of facts and law have been raised in both the inter-connected appeals, t…

Chandrakant N. Dedhia, Mumbai vs. CIT-(Appeals)-28 (NFAC), Mumbai

ITA 504/MUM/2022[2016-17]Status: DisposedITAT Mumbai29 Sept 2022AY 2016-17

Bench: Shri Kuldip Singh

For Appellant: NoneFor Respondent: Shri Anil Gupta, D.R
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “SMC”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER ITA Nos.504 & 505/M/2022 Assessment Years: 2016-17 & 2017-18 Shri Chandrakant N. CIT(A)-28, NFAC, Dedhia, Mumbai 501-6 New Anant Bhuvan, Vs. Narshi Natha Street Bhat Bazar, Mumbai – 400 009 PAN: AABPD2996F (Appellant) (Respondent) Present for: Assessee by : None Revenue by : Shri Anil Gupta, D.R. Date of Hearing : 27. 09 . 2022 Date of Pronouncement : 29. 09 . 2022 O R D E R Per : Kuldip Singh, Judicial Member: Since common questions of facts and law have been raised in both the inter-connected appeals, t…

The Income Tax Officer, Ward-2(3)(7), Surat vs. Shri Abhishek L. Jain, Surat

In the result, the grounds of appeal raised by the revenue is partly allowed

ITA 344/SRT/2019[2007-08]Status: DisposedITAT Surat26 Sept 2022AY 2007-08

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.344/Srt/2019 (Ay 2007-08) (Hearing In Virtual Court) Income Tax Officer, Ward- Shri Abhishek L.Jain 2(3)(7), Room No. 414, 4Th Prop Of Manglam Export, Vs Floor, Anavil Business Centre, 302, Pipla Sheri, Adajan-Hajira Road, Mahidharpura, Adajan, Surat-395003 Pan : Abxpj 0344 G Surat-395009 अपीलाथ"/Appellant ""यथ" /Respondent

Section 143(2)Section 143(3)Section 147Section 148Section 254(1)

…issal of the appeal filed by the Revenue. To support his various submission, the ld. AR for the assessee relied upon the following case law:  Kishanchand Chellaram vs. CIT 125 IDTR 713 (SC)  Andaman Timber Industries Vs Commissioner of Central Excise (2015) 281 CTR 241 (SC)  Mehta Parikh & Co. 30 ITR 181 (SC)  CIT vs. Odeon Builders Private Limited (Review Petition) (C) Diary No. 22394 of 2019  CIT vs. Sunita Dhadda 406 ITR 220 (Raj) 12 Sh. Abhishek L. Jain  Sunita Dhadda vs. DCIT 148 TTJ 719 (Jaipur Trib.)  PCIT Vs Tejua R Kapadia 24 taxmann.com 325 (SC)  PCIT Vs Tejua R. Kapadia [TA No.691/2017 (Guj) …

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jay Fe Cylinder Ltd

Accordingly, the same are dismissed along with pending applications

ITA/360/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…te a specific request, this Court is in agreement with the ITAT that his statement needs to be excluded and cannot be relied upon as a piece of evidence to make any addition. In fact the Supreme Court in the case of M/s Andaman Timber Industries vs. CCE (SC), 127 DTR 241 has held “...not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003918 ITA Nos.358-368/2022 Page 13 of 13 impugned order is a serious flaw which makes the order nullity inasm…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jpm Tools Ltd

Accordingly, the same are dismissed along with pending applications

ITA/362/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…te a specific request, this Court is in agreement with the ITAT that his statement needs to be excluded and cannot be relied upon as a piece of evidence to make any addition. In fact the Supreme Court in the case of M/s Andaman Timber Industries vs. CCE (SC), 127 DTR 241 has held “...not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003920 ITA Nos.358-368/2022 Page 13 of 13 impugned order is a serious flaw which makes the order nullity inasm…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jay Iron and Steel Ltd

Accordingly, the same are dismissed along with pending applications

ITA/365/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…te a specific request, this Court is in agreement with the ITAT that his statement needs to be excluded and cannot be relied upon as a piece of evidence to make any addition. In fact the Supreme Court in the case of M/s Andaman Timber Industries vs. CCE (SC), 127 DTR 241 has held “...not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003923 ITA Nos.358-368/2022 Page 13 of 13 impugned order is a serious flaw which makes the order nullity inasm…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jay Ace Technologies Ltd

Accordingly, the same are dismissed along with pending applications

ITA/367/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…te a specific request, this Court is in agreement with the ITAT that his statement needs to be excluded and cannot be relied upon as a piece of evidence to make any addition. In fact the Supreme Court in the case of M/s Andaman Timber Industries vs. CCE (SC), 127 DTR 241 has held “...not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003925 ITA Nos.358-368/2022 Page 13 of 13 impugned order is a serious flaw which makes the order nullity inasm…

ACIT, C.C. -4, Jaipur vs. Maverick Commodity Brokers Pvt. Ltd., Jaipur

In the result appeals of the revenue are dismissed

ITA 27/JPR/2020[2014-15]Status: DisposedITAT Jaipur26 Sept 2022AY 2014-15
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…gs. However, the ld. AO did not offer the opportunity of cross examination even though the assessee has sought specifically. Thus, as observed in various judgment specifically the famous decision of apex court in the case of CCE vs. Andaman Timber Industries 127 DTR 241 the assessment based on statement without giving an opportunity is not sustainable in law. We further note that the assessee M/S Maverick Commodity Brokers Pvt. Ltd.& others produced copy of affidavit of Shri Anil Agarwal who has retracted his statement, however without going into controversy of the retraction of the statement, the fact remains…

ACIT, CC-4, Jaipur vs. Shri Anshul Jain, Jaipur

In the result appeals of the revenue are dismissed

ITA 163/JPR/2020[2014-15]Status: DisposedITAT Jaipur26 Sept 2022AY 2014-15
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…gs. However, the ld. AO did not offer the opportunity of cross examination even though the assessee has sought specifically. Thus, as observed in various judgment specifically the famous decision of apex court in the case of CCE vs. Andaman Timber Industries 127 DTR 241 the assessment based on statement without giving an opportunity is not sustainable in law. We further note that the assessee M/S Maverick Commodity Brokers Pvt. Ltd.& others produced copy of affidavit of Shri Anil Agarwal who has retracted his statement, however without going into controversy of the retraction of the statement, the fact remains…

ACIT, CC-4, Jaipur vs. Smt. Sunita Agarwal, Jaipur

In the result appeals of the revenue are dismissed

ITA 158/JPR/2020[2015-16]Status: DisposedITAT Jaipur26 Sept 2022AY 2015-16
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…gs. However, the ld. AO did not offer the opportunity of cross examination even though the assessee has sought specifically. Thus, as observed in various judgment specifically the famous decision of apex court in the case of CCE vs. Andaman Timber Industries 127 DTR 241 the assessment based on statement without giving an opportunity is not sustainable in law. We further note that the assessee M/S Maverick Commodity Brokers Pvt. Ltd.& others produced copy of affidavit of Shri Anil Agarwal who has retracted his statement, however without going into controversy of the retraction of the statement, the fact remains…

ACIT, CC-4, Jaipur vs. Smt. Sunita Agarwal, Jaipur

In the result appeals of the revenue are dismissed

ITA 157/JPR/2020[2014-15]Status: DisposedITAT Jaipur26 Sept 2022AY 2014-15
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…gs. However, the ld. AO did not offer the opportunity of cross examination even though the assessee has sought specifically. Thus, as observed in various judgment specifically the famous decision of apex court in the case of CCE vs. Andaman Timber Industries 127 DTR 241 the assessment based on statement without giving an opportunity is not sustainable in law. We further note that the assessee M/S Maverick Commodity Brokers Pvt. Ltd.& others produced copy of affidavit of Shri Anil Agarwal who has retracted his statement, however without going into controversy of the retraction of the statement, the fact remains…

ACIT, CC-4, Jaipur vs. Shri Mukut Behari Agarwal, Jaipur

In the result appeals of the revenue are dismissed

ITA 155/JPR/2020[2015-16]Status: DisposedITAT Jaipur26 Sept 2022AY 2015-16
For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.R. Meena (Pr.CIT)
Section 115BSection 127Section 132Section 133ASection 143(2)Section 153ASection 68Section 69C

…gs. However, the ld. AO did not offer the opportunity of cross examination even though the assessee has sought specifically. Thus, as observed in various judgment specifically the famous decision of apex court in the case of CCE vs. Andaman Timber Industries 127 DTR 241 the assessment based on statement without giving an opportunity is not sustainable in law. We further note that the assessee M/S Maverick Commodity Brokers Pvt. Ltd.& others produced copy of affidavit of Shri Anil Agarwal who has retracted his statement, however without going into controversy of the retraction of the statement, the fact remains…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jay Auto Components Ltd

Accordingly, the same are dismissed along with pending applications

ITA/363/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…te a specific request, this Court is in agreement with the ITAT that his statement needs to be excluded and cannot be relied upon as a piece of evidence to make any addition. In fact the Supreme Court in the case of M/s Andaman Timber Industries vs. CCE (SC), 127 DTR 241 has held “...not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003921 ITA Nos.358-368/2022 Page 13 of 13 impugned order is a serious flaw which makes the order nullity inasm…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jay Iron and Steel Ltd

Accordingly, the same are dismissed along with pending applications

ITA/361/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…te a specific request, this Court is in agreement with the ITAT that his statement needs to be excluded and cannot be relied upon as a piece of evidence to make any addition. In fact the Supreme Court in the case of M/s Andaman Timber Industries vs. CCE (SC), 127 DTR 241 has held “...not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003919 ITA Nos.358-368/2022 Page 13 of 13 impugned order is a serious flaw which makes the order nullity inasm…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jay Iron and Steel Ltd

Accordingly, the same are dismissed along with pending applications

ITA/364/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…te a specific request, this Court is in agreement with the ITAT that his statement needs to be excluded and cannot be relied upon as a piece of evidence to make any addition. In fact the Supreme Court in the case of M/s Andaman Timber Industries vs. CCE (SC), 127 DTR 241 has held “...not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003922 ITA Nos.358-368/2022 Page 13 of 13 impugned order is a serious flaw which makes the order nullity inasm…

Pr. Commissioner of Income Tax (Central)-2 vs. M/S Jpm Tools Ltd

Accordingly, the same are dismissed along with pending applications

ITA/358/2022HC Delhi26 Sept 2022

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

…te a specific request, this Court is in agreement with the ITAT that his statement needs to be excluded and cannot be relied upon as a piece of evidence to make any addition. In fact the Supreme Court in the case of M/s Andaman Timber Industries vs. CCE (SC), 127 DTR 241 has held “...not allowing the assessee to cross-examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the This is a digitally signed Judgement. NEUTRAL CITATION NO: 2022/DHC/003917 ITA Nos.358-368/2022 Page 13 of 13 impugned order is a serious flaw which makes the order nullity inasm…

Assistant Commissioner of Income Tax, Circle -1(1), Raipur vs. M/S R.N. Navnirman Private Limited, Raipur

ITA 143/RPR/2018[2014-15]Status: DisposedITAT Raipur23 Sept 2022AY 2014-15

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.143/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. R.N. Navnirman Pvt. Ltd. Vandana Building, Raipur (C.G.) Pan : Aadcr0896D ……""यथ" / Respondent Assessee By :Shri R.B Doshi, Ca Revenue By :Shri Sanjay Kumar, Sr. Dr

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 14ASection 14A(2)Section 14A(3)Section 250(4)Section 68

…bserved by the CIT(Appeals) that as the A.O had by relying on certain documents at the back of the assessee drawn adverse inferences in the latter’s hand, therefore, the same pursuant to the judgment of the Hon’ble Supreme Court in the case of Andaman Timber, 281 CTR 241 (SC) in the light of the basic tenements of the principles of natural justice could not be sustained. It was observed by the CIT(Appeals) that now when the assessee had discharged the primary onus that was cast upon it by placing on record supporting documentary evidence to substantiate the genuineness and veracity of the transaction of having re…

Shri Mukeshkumar Vrajlal Akbari, Jamnagar vs. The ITO, Ward-3(1), Jamngar, Jamnagar

In the result, the appeal of the assessee is allowed

ITA 55/RJT/2021[2011-12]Status: DisposedITAT Rajkot21 Sept 2022AY 2011-12
For Appellant: Shri Chetan Agarwal, A.RFor Respondent: Shri B.D. Gupta, Sr. D.R
Section 143(3)Section 147Section 148

…ents:- I.T.A Nos. 54 & 55/Rjt/2021 A.Y. 2010-11 & 2011-12 Page No 4 Shri Mukeshkumar Vrajlal Akbari (a) Dhakeswari Cotton Mills Ltd. Vs. CIT 26 ITR 775 (SC) (b) Krishna Chand Chela Ram Vs. CIT 125 ITR 713 (SC) (c) Andaman Timber Industries Vs. CIT (2015) 62 Taxmann.com 3 (SC) (d) Ayubkhan Noorkhan Pathan Vs. State of Mharashtra & Ors. (Civil Appeal No. 7728 of 2012 dated 08/11/2012) (e) Khem Chand Vs. Union of India (AIR 1958 SC 300) (f) Amitabh Bansal Vs. ITO Ward-46(4), [2019] 102 taxmann.com 229 (g) CIT Vs. Indrajit Singh Suri [2013] 33 taxmann.com 281 (Guj) (h) PCIT Vs. Kanubhai Maganlal Patel [2017…

Shri Mukeshkumar Vrajlal Akbari, Jamnagar vs. The ITO, Ward-3(1), Jamngar, Jamnagar

In the result, the appeal of the assessee is allowed

ITA 54/RJT/2021[2010-11]Status: DisposedITAT Rajkot21 Sept 2022AY 2010-11
For Appellant: Shri Chetan Agarwal, A.RFor Respondent: Shri B.D. Gupta, Sr. D.R
Section 143(3)Section 147Section 148

…ents:- I.T.A Nos. 54 & 55/Rjt/2021 A.Y. 2010-11 & 2011-12 Page No 4 Shri Mukeshkumar Vrajlal Akbari (a) Dhakeswari Cotton Mills Ltd. Vs. CIT 26 ITR 775 (SC) (b) Krishna Chand Chela Ram Vs. CIT 125 ITR 713 (SC) (c) Andaman Timber Industries Vs. CIT (2015) 62 Taxmann.com 3 (SC) (d) Ayubkhan Noorkhan Pathan Vs. State of Mharashtra & Ors. (Civil Appeal No. 7728 of 2012 dated 08/11/2012) (e) Khem Chand Vs. Union of India (AIR 1958 SC 300) (f) Amitabh Bansal Vs. ITO Ward-46(4), [2019] 102 taxmann.com 229 (g) CIT Vs. Indrajit Singh Suri [2013] 33 taxmann.com 281 (Guj) (h) PCIT Vs. Kanubhai Maganlal Patel [2017…