Cambay Electric Supply Industrial Co. Ltd. v. CIT

113 ITR 84Supreme Court of India1978#355 most cited

What is Cambay Electric Supply Industrial Co. Ltd. v. CIT authority for?

The expression "attributable to" is wider in scope and import than the expression "derived from" when interpreting provisions related to profits and gains from a business or industrial undertaking. The legislature's deliberate use of these distinct phrases indicates a nuanced intent regarding the directness of the nexus between income and the source.

245

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 1999 to 2026.

Also referred to as

Cambay Electric Supply Industrial Co. Ltd. v. CIT · 113 ITR 84 · Section 80P · derived from · attributable to · scope of expressions · profits and gains · business income attribution · industrial undertaking income · income interpretation · direct nexus

Sections most often in play

Section 80P(2)(a)(i)Section 143(3)Section 80P(2)(d)Section 80PSection 250Section 263Section 56Section 2(19)
Read the full judgment

Issues it is cited on

section 57(i)section 80(2)(d)section 80(p)(2)(a)section 286section 161section 80p(2)(a)(iii)section 80p(2)(c)section 60section 80jinterest on securitiessection 80p(1)section 2(19)

Judgments citing Cambay Electric Supply Industrial Co. Ltd. v. CIT

Alpa India Private Limited, Hyderabad vs. DCIT Circle -1(1), Hyderabad

In the result, the appeal of the assessee company is partly allowed for statistical purposes in terms of our aforesaid observations

ITA 457/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 May 2025AY 2018-19

Bench: Us:

For Appellant: Sri PVSS Prasad, CAFor Respondent: Sri B. Bala Krishna, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 3Section 80Section 80I

…view that there has to be a direct nexus between the income derived and the business of the industrial undertaking can safely be gathered from the judgment of the Hon'ble Supreme Court in the case of Cambay Electrical Supply Industrial Co. Ltd. Vs. CIT (1978) 113 ITR 84 (SC). The Hon'ble Apex Court deliberating upon the pari materia provisions of section 80IA of the Act, had observed, that though the expression “attributable to”, has a much wider import and takes within its meaning receipts which are incidental to the 19 Alpla India Private Limited vs. DCIT ITA 457/Hyd/2022 actual conduct of the business of the i…

Assistant Commissioner of Income Tax, C-1(1)(1), Bangalore vs. Bangalore International Airport Limited, Bangalore

In the result, the cross objection of the assessee is hereby partly allowed

ITA 1109/BANG/2024[2020-21]Status: DisposedITAT Bangalore16 Apr 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Smt. Nandini Das, CIT-DR
Section 80I

…ble industrial undertaking and not income attributable to the eligible industrial undertaking. The phrase “derived from” has narrow meaning as defined by the Hon’ble Supreme Court in the case of Cambay Electrical Supply Industrial Co. Ltd. vs. CIT reported in 113 ITR 84. Therefore, only the income receipt from actual conduct of business will be covered under the income derived from and not the income incidental to the actual conducts of business. The AO further referred to the decision of Hon’ble Supreme in the case of Sterling Foods reported in 237 ITR 53 and Pandian Chemical reported in 262 ITR 278 to buttress…

Assistant Commissioner of Income Tax, C-1(1)(1), Bangalore vs. Bangalore International Airport Limited, Bangalore

ITA 1108/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Smt. Nandini Das, CIT-DR
Section 143(4)Section 80I

…ble industrial undertaking and not income attributable to the eligible industrial undertaking. The phrase “derived from” has narrow meaning as defined by the Hon'ble Supreme Court in the case of Cambay Electrical Supply Industrial Co. Ltd. vs. CIT reported in 113 ITR 84. Therefore, only the income receipt from actual conduct of business will be covered under the income derived from and not the income incidental to the actual conducts of business. The AO further referred to the decision of Hon'ble Supreme in the case of Sterling Foods reported in 237 ITR 53 and Pandian Chemical reported in 262 ITR 278 to buttress…

Asstt. Commissioner of Income Tax, CC-1, Lucknow, Aayakar Bhawan, Ashok Marg vs. Apco Infratech Pvt. Ltd., Vibhuti Khand Gomti Nagar Lko

In the result, appeals vide

ITA 623/LKW/2024[2018-19]Status: DisposedITAT Lucknow02 Apr 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…restricted to ‘business income’ only. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restrict…

M/S Apco Infratech Pvt. Ltd., Lucknow vs. D/ACIT-1, Central-1, Lucknow

In the result, appeals vide

ITA 17/LKW/2024[2018-19]Status: DisposedITAT Lucknow02 Apr 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…restricted to ‘business income’ only. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restrict…

ACIT, Range-I, Lucknow vs. M/S Apco Infratech Pvt. Ltd., Lucknow

ITA 454/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…ns are clearly applicable in the case of the appellant. Further, it is humbly submitted that the findings of the A.O. are reiterated and reliance is placed on the judicial Precedents are as under: (SC): Cambay Electric Supply Industrial Co. Ltd. v. CIT (1978) 113 ITR 84 The Supreme Court held that the expression "derived from" is narrower in scope than "attributable to." It implies a direct nexus between the income and the business activity. Interest earned on surplus funds does not have a direct nexus with the core business activity of infrastructure development or power generation. Sterling Foods v. CIT (1999)…

ACIT, Range-I, Lucknow vs. M/S Apco Infratech Pvt. Ltd., Lucknow

ITA 453/LKW/2020[2016-17]Status: DisposedITAT Lucknow02 Apr 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…ns are clearly applicable in the case of the appellant. Further, it is humbly submitted that the findings of the A.O. are reiterated and reliance is placed on the judicial Precedents are as under: (SC): Cambay Electric Supply Industrial Co. Ltd. v. CIT (1978) 113 ITR 84 The Supreme Court held that the expression "derived from" is narrower in scope than "attributable to." It implies a direct nexus between the income and the business activity. Interest earned on surplus funds does not have a direct nexus with the core business activity of infrastructure development or power generation. Sterling Foods v. CIT (1999)…

M/S. Apco Infratech Pvt. Ltd., Lucknow vs. ACIT-I, Lucknow

In the result, appeals vide I

ITA 357/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…are clearly applicable in the case of the appellant. Further, it is humbly submitted that the findings of the A.O. are reiterated and reliance is placed on the judicial Precedents are as under: (SC): Cambay Electric Supply Industrial Co. Ltd. v. CIT (1978) 113 ITR 84 The Supreme Court held that the expression "derived from" is narrower in scope than "attributable to." It implies a direct nexus between the income and the business activity. Interest earned on surplus funds does not have a direct nexus with the core business activity of infrastructure development or power generation. Sterling Foods v. CIT (1999)…

M/S. Apco Infratech Pvt. Ltd., Lucknow vs. ACIT-1, Lucknow

In the result, appeals vide

ITA 356/LKW/2020[2016-17]Status: DisposedITAT Lucknow02 Apr 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…restricted to ‘business income’ only. On the other hand, according to him, subsection (5) deals with determination of the quantum of deduction by treating eligible business as the only source of income of the Assessee. Sub-section (5), therefore, is 2 (1978) 2 SCC 644 3 (2008) 4 SCC 22 4 (2003) 5 SCC 590 concerned with computation of the deduction, which is at a stage prior to allowing the deduction so computed. He submitted that there is no dispute that the computation of deduction is only from the eligible business. The claim of the Assessee, as accepted by the Appellate Authority, is that there is no restrict…

M. P Police Sakh Sahkari Sanstha Maryadit Ujjain, Ujjain vs. Income Tax Officer -2(1), Ujjain

In the result appeal of the assessee is dismissed

ITA 192/IND/2024[2020-21]Status: DisposedITAT Indore28 Feb 2025AY 2020-21

Bench: Shri Manish Boradm.P. Police Sakh Sahakari Ito 2(1), Sanstha Maryadit, Ujjain 32Nd Battalion, Vs. Dewas Road Nagari, Ujjain (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabam5551C Assessee By Shri Milind Wadhwani, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 27.02.2025 Date Of Pronouncement 28.02.2025 O R D E R

Section 143(3)Section 80P

…ion is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions of the statute in the case of Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 (at page 93) as under:- 'As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attributable to the business of the specified industry (here generation and distribution of electricity) on which the learned Solicitor-General relied, it will be pertinent to observe that the legislature has de…

Southern Railway Employees Cooperative Credit Society Ltd., Tiruchirappalli vs. DCIT, Cricle-1(1), Trichy

In the result, appeal filed by the assessee is allowed

ITA 2426/CHNY/2024[2017-18]Status: DisposedITAT Chennai05 Feb 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.G. Baskar, AdvocateFor Respondent: Ms.Sheila Parthasarthy
Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

…ion is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions of the statute in the case of Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 (at page 93) as under:— “As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attributable to the business of" the specified industry (here generation and distribution of electricity) on which the learned Solicitor-General relied, it will be pertinent to observe that the legislature has d…

Primary Agricultural Credit Co-Operative Society Limited, Tumkur vs. Income Ta Officer, Ward-2, Tumkur

In the result, the appeal filed by the assessee is partly allowed

ITA 2260/BANG/2024[2017-18]Status: DisposedITAT Bangalore28 Jan 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Prakash S Hegde, CA
Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 8o

…ee that the interest income is attributable to the profits and gains of the business and therefore the interest income derived from the deposits made with the banks are entitled for deduction. The Hon’ble Page 5 of 7 Supreme Court in its judgment reported in 113 ITR 84 in the case of Cambay Electrical Supply Industrial Co. Ltd. vs. CIT had considered the term ‘attributable’ and held as follows: “As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attributable to the business" of the specific industry (here generation and distribution of society) on whi…

ACIT Circle 8(3)(1), Mumbai vs. Thirumalai Chemicals Limited, Mumbai

Appeal of the revenue is dismissed

ITA 3358/MUM/2024[2018-19]Status: DisposedITAT Mumbai07 Jan 2025AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Deepak Shah, CAFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 143(1)Section 32Section 801ASection 80I

…icals Ltd. 2. Whether on the facts and in the circumstances of the case and in law, the LD.CIT(A) erred in ignoring the ratio of Supreme Court judgements in in the case of Sterling Foods 237 ITR 53(SC) and in the case of Cambay Electrical Supply Company Ltd. 113 ITR 84 wherein it is held that the income incidental to the main business of the assessee and there is no direct nexus between the income and the industrial undertaking is not direct but incidental only ? 3. Whether on the facts and in the circumstances of the case and in law, the Ld.CIT(A) erred in holding that catalyst expenditure as revenue expenditur…

Asstt.Commissioner of Income Tax Circle-5, Nagpur vs. The Nirmal Ujwal Credit Co-Op Society Ltd, Nagpur

In the result, appeal filed by the Revenue for the assessment year

ITA 390/NAG/2019[2012-13]Status: HeardITAT Nagpur27 Nov 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Vikash Agrawal
Section 139(1)Section 143(1)Section 143(2)Section 80PSection 80P(2)

…2)(a)(i) is of great importance. The Apex Court had an occasion to het: the meaning of the word ‗attributable‘ as supposed to derive from its use in various other provisions of the statute in the case of Cambay Electric Supply Industrial Co. Ltd V- CIT [1978] 113 ITR 84 (at page 93) as under :- ‗As regards the aspect emerging from the expression ―attributable to‖ occurring in the phrase ―profits and gains attributable to the business of the specified industry (here generation and distribution of electricity) on which the learned Solicitor-General relied, it will be pertinent to observe that the legislature has de…

Muktadevi Gramin Bigarsheti Sahakari Patsanstha Maryadit Gunjalwadi, Pune vs. ITO Ward 10(1), Pune

ITA 1840/PUN/2024[2017-18]Status: DisposedITAT Pune22 Nov 2024AY 2017-18

Bench: Ms.Ashta Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1840/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Muktadevi Gramin Bigarsheti V The Income Tax Officer, Sahakari Patanstha Maryadit S Ward-10(1), Pune. Gunjalwadi, At Post – Gunjalwadi,Taluke – Junnar, District – Pune, Pune – 412401. Pan: Aaaam6151H Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri A.D.Kulkarni – Addl.Cit(Dr) Date Of Hearing 19/11/2024 Date Of Pronouncement 22/11/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act, 1961 Dated 09.07.2024 For A.Y.2017-18. The Assessee Has Raised The Following Grounds Of Appeal : “Being Aggrieved By The Order Dated 09/07/2024 Passed By The Learned Commissioner Of Income Tax (Appeals), Nfac, Delhi U/S 250 Of The Income-Tax Act, 1961 (“Act”), Your Appellant Prefers This Appeal, Among Others, On The Following Grounds Of Appeal, Each Of Which Is Without Prejudice To & Independent Of, The Other: 1. On The Facts & In The Circumstances Of The Case & In Law, The Appellant Submits That Ld. Cit(A) Erred By Making Disallowance Of Our Claim For Deduction U/S. 80P(2) Of The Act. The Appellant, Therefore, Prays That Deduction U/S. 80P (2) (A) (I) & 80P (2) (C) (Ii) Be Allowed To Us As Claimed In Itr. 2. Your Appellant Craves Leave To Alter, Modify, Amend Or Delete Any Of The Above Grounds Of Appeal, Or To Add One Or More New Ground(S), As May Be Necessary.” Submission Of Ld.Ar : 2. None Appeared On Behalf Of The Assessee, However, Assessee Has Filed A Paper Book & Written Submission. We Have Considered The Written Submission & Paper Book.

Section 250Section 70Section 80Section 80PSection 80P(2)

…।आयकर अपीलीय अिधकरण ”एस एम सी” "ायपीठ पुणेम"। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “SMC” :: PUNE BEFORE MS.ASHTA CHANDRA, JUDICIAL MEMBER AND DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No.1840/PUN/2024 िनधा"रण वष" / Assessment Year: 2017-18 Muktadevi Gramin Bigarsheti V The Income Tax Officer, Sahakari Patanstha Maryadit s Ward-10(1), Pune. Gunjalwadi, At Post – Gunjalwadi,Taluke – Junnar, District – Pune, Pune – 412401. PAN: AAAAM6151H Appellant/ Assessee Respondent / Revenue Assessee by None Revenue by Shri A.D.Kulkarni – Addl.CIT(DR) Date of hearing 19/11/2024 Date of pronouncement…

Shri Shivaji Maharaj Credit Co-Op Society Ltd, Bijapur vs. Income Tax Officer, Ward-1 and Tps, Vijaypur

ITA 976/BANG/2024[2015-16]Status: DisposedITAT Bangalore22 Aug 2024AY 2015-16
Section 80P(2)(a)Section 80P(2)(d)

…Page 2 of 17 ITA Nos. 939, 940 & 976/Bang/2024 PER BEENA PILLAI, JUDICIAL MEMBER Present appeals arises out of independent orders passed by the Ld.CIT(A)/NFAC for A.Ys. 2015-16 & 2017-18 vide order dated 29.04.2024 and for A.Y. 2018-19 vide order dated 20.04.2024. 2. The Ld.AR at the outset submitted that, all the three appeals are on common issue relating to denial of deduction u/s. 80P(2)(a)(i) of the act. He submitted that, the assessee filed application for admission of additional ground on 03.07.2024 for Α.Υ. 2015-16, wherein additional ground nos. 3 & 4 are raised on jurisdiction of the CIT(A)/NFAC to consi…

Shri Shivaji Maharaj Credit Co-Op Society, Bijapur vs. Income Tax Officer Ward-1 and Tps, Vijapur

ITA 939/BANG/2024[2017-18]Status: DisposedITAT Bangalore22 Aug 2024AY 2017-18
Section 80P(2)(a)Section 80P(2)(d)

…Page 2 of 17 ITA Nos. 939, 940 & 976/Bang/2024 PER BEENA PILLAI, JUDICIAL MEMBER Present appeals arises out of independent orders passed by the Ld.CIT(A)/NFAC for A.Ys. 2015-16 & 2017-18 vide order dated 29.04.2024 and for A.Y. 2018-19 vide order dated 20.04.2024. 2. The Ld.AR at the outset submitted that, all the three appeals are on common issue relating to denial of deduction u/s. 80P(2)(a)(i) of the act. He submitted that, the assessee filed application for admission of additional ground on 03.07.2024 for Α.Υ. 2015-16, wherein additional ground nos. 3 & 4 are raised on jurisdiction of the CIT(A)/NFAC to consi…

Om Infra Limited, Jaipur Rajasthan vs. DCIT, Central Circle-1, Jaipur, Rajasthan

In the result, we find no substantial question of law being involved in this appeal

ITA 811/JPR/2023[2015-16]Status: DisposedITAT Jaipur31 Jul 2024AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. A. S. Nehra (Addl. CIT)
Section 115JSection 143(3)Section 154Section 80Section 801C(2)(b)Section 80I

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA No. 811/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2015-16 cuke Om Infra Limited, DCIT, Vs. Om Tower, M. I. Road Church Central Circle-01, Jaipur Road, LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAACO 8245 J vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. P. C. Parwal (CA) jktLo dh vksj ls@ Revenue by : Sh. A.…

Adarsh Seva Sahakari Patpedhi Limited, Mumbai vs. Income-Tax Officer, National Faceless Assessment Centre, New Delhi

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 636/MUM/2024[2018-19]Status: DisposedITAT Mumbai25 Jul 2024AY 2018-19

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri Ramesh IyerFor Respondent: Shri Sunny Kachhwaha
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 56Section 66Section 68Section 80P(2)(a)Section 80P(2)(d)

…ion is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions of the statute in the case of Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 (SC) as under: 'As regards the aspect emerging from the expression "attributable to" occurring in the phrase "profits and gains attributable to the business of the specified industry (here generation and distribution of electricity) on which the learned Solicitor- General relied, it will be pertinent to observe that the legislature, has deliberate…

P vs. Multiplex (India) Ltd., Meerutvs.ACIT, Circle- 2, Meerut

The appeal of the assessee stands dismissed

ITA 7697/DEL/2018[2008-09]Status: DisposedITAT Delhi22 Jul 2024AY 2008-09

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(3)Section 154Section 263Section 36(1)(vi)Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER ITA No.7697/Del/2018, A.Y. 2008-09 PVS Multiplex (India) Ltd. ACIT, I BLOCK, Circle-2, Shastri Nagar, Meerut Vs. Meerut Uttar Pradesh PAN : AACCP8168R (Appellant) (Respondent) Appellant by Shri Rohit Agarwal, CA Respondent by Sh. Vivek Vardhan, Sr. DR Date of Hearing 27/06/2024 Date of Pronouncement 22/07/2024 ORDER PER AVDHESH KUMAR MISHRA, AM The appeal for the Assessment Year (In Short, the ‘AY’) 2008-09 filed by the assessee is directed against the ord…