CIT v. Hotel Meriya

332 ITR 537High Court2011#731 most cited

What is CIT v. Hotel Meriya authority for?

A statement recorded under Section 132(4) during a search, along with seized documents, constitutes evidence under the Income-tax Act read with the Indian Evidence Act, making such evidence admissible for search assessments.

139

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2026.

Also referred to as

CIT v. Hotel Meriya · Section 132(4) · statement during search · admissibility of evidence · search assessment · seized documents · Income-tax Act evidence · scope of statement under 132(4) · 332 ITR 537 · Evidence Act Section 3

Also reported as

195 Taxmann 459

Sections most often in play

Section 143(3)Section 153ASection 132Section 132(4)Section 147Section 142(1)Section 69CSection 68
Read the full judgment

Issues it is cited on

section 181section 24asection 56(2)(vii)(c)section 153a(b)section 245c(1)section 245d(1)section 114(e)section 79section 193section 65b(4)section 17(2)section 158bb

Judgments citing CIT v. Hotel Meriya

Reena Engineers and Contractors Private Ltd, Panaji vs. ACIT, Central Circle-1, Calicut

In the result, the appeals filed by the assessee stand partly allowed statistical purposes

ITA 268/COCH/2021[2013-2014]Status: DisposedITAT Cochin31 Jul 2025AY 2013-2014

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

…le Rajasthan High Court in the case of CIT v. Pink City Developers [2017] 398 ITR 153. There is no embargo even to reject the books of account in the assessment made u/s. 153A of the Act. The Hon'ble Kerala High Court in the case of CIT v. Hotel Meriya [2011] 332 ITR 537 held Reena Engineers and Contractors Pvt. Ltd. that estimation of income even in the search assessment had upheld. This reasoning was upheld in the recent judgement of the Hon'ble Kerala High Court in the case of Sunny Jacob Jewellers v. CIT [2024] 473 ITR 159 wherein it was held as under: - “10. In the case of Hotel Meriya (supra) the Assessin…

Reena Engineers and Contractors Private Ltd, Panaji vs. ACIT, Central Circle-1, Calicut

In the result, the appeals filed by the assessee stand partly

ITA 267/COCH/2021[2012-2013]Status: DisposedITAT Cochin31 Jul 2025AY 2012-2013

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri G. Surendranath Rao, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 132Section 139(1)Section 143Section 143(3)Section 153Section 153ASection 80

…le Rajasthan High Court in the case of CIT v. Pink City Developers [2017] 398 ITR 153. There is no embargo even to reject the books of account in the assessment made u/s. 153A of the Act. The Hon'ble Kerala High Court in the case of CIT v. Hotel Meriya [2011] 332 ITR 537 held that estimation of income even in the search assessment had upheld. This reasoning was upheld in the recent judgement of the Hon'ble Kerala High Court in the case of Sunny Jacob Jewellers v. CIT [2024] 473 ITR 159 wherein it was held as under: - “10. In the case of Hotel Meriya (supra) the Assessing Officer, during the search operations unde…

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Central Circle-1, Jaipur

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

…ious High Courts in Lekh Raj Dhunna (supra), Bachittar Singh (supra). Professional Automotives Private Limited vs. ACIT Rameshchandra& Co. v. CIT[1987] 35 Taxman 153/168 ITR 375 (Bom.), Dr. S.C. Gupta (supra), CIT v. Hotel Meriya [2010] 195 Taxman 459/[2011] 332 ITR 537 (Ker.) O. Abdul Razak (supra)." (Emphasis Supplied) Commissioner of Income-tax v. Lekh Raj Dhunna [2012] 20 taxmann.com 554 (Punjab & Haryana)/[2012] 344 ITR 352 (Punjab & Haryana)/[2010] 236 CTR 414 (Punjab & Haryana) [29-09-2010] "15. Having crystalized legal position, it is now apt to delve on the factual situation of the present case. It is…

Kailash Chand Maheshwari, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

ITA 1465/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 May 2025AY 2017-18
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

…sed in detail in the earlier ground of appeal where this contention of the appellant has been rejected and the same is referred to and not repeated here for the sake of brevity. Commissioner of Income-tax v. Hotel Meriya [2010] 195 Taxman 459. (Kerala)/[2011] 332 ITR 537 (Kerala) [26-05-2010] "What is evidence? We shall examine it first. Evidence is defined in section 3 of the Evidence Act as follows: "Evidence":- "Evidence" means and includes (1) all statements which the Court permits or requires to be made before it by witnesses, in relation to matters of fact under inquiry, such statements are called oral evid…

Kailash Chand Maheshwari, Jaipur vs. Deputy Commissioner of Income Tax, Centralcircle-2, Jaipur

ITA 1464/JPR/2024[2016-17]Status: DisposedITAT Jaipur20 May 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

…sed in detail in the earlier ground of appeal where this contention of the appellant has been rejected and the same is referred to and not repeated here for the sake of brevity. Commissioner of Income-tax v. Hotel Meriya [2010] 195 Taxman 459. (Kerala)/[2011] 332 ITR 537 (Kerala) [26-05-2010] "What is evidence? We shall examine it first. Evidence is defined in section 3 of the Evidence Act as follows: "Evidence":- "Evidence" means and includes (1) all statements which the Court permits or requires to be made before it by witnesses, in relation to matters of fact under inquiry, such statements are called oral evid…

Kailash Chand Maheshwari, Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

ITA 1463/JPR/2024[2015-16]Status: DisposedITAT Jaipur20 May 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

…ed in detail in the earlier ground of appeal where this contention of the appellant has been rejected and the same is referred to and not repeated here for the sake of brevity. Commissioner of Income-tax v. Hotel Meriya [2010] 195 Taxman 459. (Kerala)/[2011] 332 ITR 537 (Kerala) [26-05-2010] "What is evidence? We shall examine it first. Evidence is defined in section 3 of the Evidence Act as follows: "Evidence":- "Evidence" means and includes (1) all statements which the Court permits or requires to be made before it by witnesses, in relation to matters of fact under inquiry, such statements are called oral evi…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3005/DEL/2024[2017-18]Status: DisposedITAT Delhi20 May 2025AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Date of Hearing
Section 132(4)Section 153ASection 50Section 68

…Supreme Court in the case of Dayawanti v. CIT, 2016 SCC Online Del 5772, decision of Hon'ble Delhi High Court in the case of Anil kumar Bhatia [2013] 352 ITR 493 (Del), PCIT v. Nau Nidh Overseas Pvt. Ltd. [2017] 394 ITR 753 (Del), CIT v. Hotel Meriya, (2011) 332 ITR 537, B. Kishore Kumar v. DCIT, Central Circle IV(1), Chennai, [2014] 52 taxmann.com 449, B. Kishore Kumar was upheld in (2015) 62 taxmann.com 215 to support that statement also constitutes as material because it is made in the course of the search. 27. As far as the statement u/s 132(4) of the Act by the assessee and three other persons, Mr. M.N. Kha…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3004/DEL/2024[2016-17]Status: DisposedITAT Delhi20 May 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special counsel for the Department
Section 132(4)Section 153ASection 50Section 68

…SCC Online Del 5772 , decision of ITA Nos. 2999 to 3005/Del/2024 Sushen Mohan Gupta Hon‘ble Delhi High Court in the case of Anil kumar Bhatia [2013] 352 ITR 493 (Del), PCIT v. Nau Nidh Overseas Pvt. Ltd. [2017] 394 ITR 753 (Del), CIT v. Hotel Meriya, (2011) 332 ITR 537, B. Kishore Kumar v. DCIT, Central Circle IV(1), Chennai, [2014] 52 taxmann.com 449, B. Kishore Kumar was upheld in (2015) 62 taxmann.com 215 to support that statement also constitutes as material because it is made in the course of the search . 27. As far as the statement u/s 132(4) of the Act by the assessee and three other persons, Mr. M.N. K…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3003/DEL/2024[2015-16]Status: DisposedITAT Delhi20 May 2025AY 2015-16

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Ms. Ragini Handa, Adv
Section 132(4)Section 153ASection 50Section 68

…Supreme Court in the case of Dayawanti v. CIT, 2016 SCC Online Del 5772, decision of Hon'ble Delhi High Court in the case of Anil kumar Bhatia [2013] 352 ITR 493 (Del), PCIT v. Nau Nidh Overseas Pvt. Ltd. [2017] 394 ITR 753 (Del), CIT v. Hotel Meriya, (2011) 332 ITR 537, B. Kishore Kumar v. DCIT, Central Circle IV(1), Chennai, [2014] 52 taxmann.com 449, B. Kishore Kumar was upheld in (2015) 62 taxmann.com 215 to support that statement also constitutes as material because it is made in the course of the search. 27. As far as the statement u/s 132(4) of the Act by the assessee and three other persons, Mr. M.N. Kha…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3002/DEL/2024[2014-15]Status: DisposedITAT Delhi20 May 2025AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Ms. Ragini Handa, Adv
Section 132(4)Section 153ASection 50Section 68

…Supreme Court in the case of Dayawanti v. CIT, 2016 SCC Online Del 5772, decision of Hon'ble Delhi High Court in the case of Anil kumar Bhatia [2013] 352 ITR 493 (Del), PCIT v. Nau Nidh Overseas Pvt. Ltd. [2017] 394 ITR 753 (Del), CIT v. Hotel Meriya, (2011) 332 ITR 537, B. Kishore Kumar v. DCIT, Central Circle IV(1), Chennai, [2014] 52 taxmann.com 449, B. Kishore Kumar was upheld in (2015) 62 taxmann.com 215 to support that statement also constitutes as material because it is made in the course of the search. 27. As far as the statement u/s 132(4) of the Act by the assessee and three other persons, Mr. M.N. Kha…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3001/DEL/2024[2013-14]Status: DisposedITAT Delhi20 May 2025AY 2013-14

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special
Section 132(4)Section 153ASection 50Section 68

…Supreme Court in the case of Dayawanti v. CIT, 2016 SCC Online Del 5772, decision of Hon'ble Delhi High Court in the case of Anil kumar Bhatia [2013] 352 ITR 493 (Del), PCIT v. Nau Nidh Overseas Pvt. Ltd. [2017] 394 ITR 753 (Del), CIT v. Hotel Meriya, (2011) 332 ITR 537, B. Kishore Kumar v. DCIT, Central Circle IV(1), Chennai, [2014] 52 taxmann.com 449, B. Kishore Kumar was upheld in (2015) 62 taxmann.com 215 to support that statement also constitutes as material because it is made in the course of the search. 27. As far as the statement u/s 132(4) of the Act by the assessee and three other persons, Mr. M.N. Kha…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3000/DEL/2024[2012-13]Status: DisposedITAT Delhi20 May 2025AY 2012-13

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special
Section 132(4)Section 153ASection 50Section 68

…Supreme Court in the case of Dayawanti v. CIT, 2016 SCC Online Del 5772, decision of Hon'ble Delhi High Court in the case of Anil kumar Bhatia [2013] 352 ITR 493 (Del), PCIT v. Nau Nidh Overseas Pvt. Ltd. [2017] 394 ITR 753 (Del), CIT v. Hotel Meriya, (2011) 332 ITR 537, B. Kishore Kumar v. DCIT, Central Circle IV(1), Chennai, [2014] 52 taxmann.com 449, B. Kishore Kumar was upheld in (2015) 62 taxmann.com 215 to support that statement also constitutes as material because it is made in the course of the search. 27. As far as the statement u/s 132(4) of the Act by the assessee and three other persons, Mr. M.N. Kha…

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle -15, Delhi

ITA 2999/DEL/2024[2011-12]Status: DisposedITAT Delhi20 May 2025AY 2011-12

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special counsel for the Department
Section 132(4)Section 153ASection 50Section 68

…SCC Online Del 5772 , decision of ITA Nos. 2999 to 3005/Del/2024 Sushen Mohan Gupta Hon‘ble Delhi High Court in the case of Anil kumar Bhatia [2013] 352 ITR 493 (Del), PCIT v. Nau Nidh Overseas Pvt. Ltd. [2017] 394 ITR 753 (Del), CIT v. Hotel Meriya, (2011) 332 ITR 537, B. Kishore Kumar v. DCIT, Central Circle IV(1), Chennai, [2014] 52 taxmann.com 449, B. Kishore Kumar was upheld in (2015) 62 taxmann.com 215 to support that statement also constitutes as material because it is made in the course of the search . 27. As far as the statement u/s 132(4) of the Act by the assessee and three other persons, Mr. M.N. K…

Adhyatm Jain Prop. M/S Jambu Kumar Adhyatam Jain Saraf, Lucknow vs. Dy. Commissioner of Income Tax, Central Circle-2, Lucknow

In the result, all the appeal of the assessee is allowed

ITA 787/LKW/2024[2015-16]Status: HeardITAT Lucknow06 May 2025AY 2015-16

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 132Section 153ASection 153DSection 250Section 68

…(8) TMI 474 (Rajasthan), etc.; courts took a view in favour of Revenue in cases reported as CIT vs. Rajkumar Arora (supra), CIT vs. Mahndipur Balaji 447 ITR 517 (All.), CIT vs. K. P. Ummer 413 ITR 251 (Ker.), Sunny Jacob Jewellers and Wedding Centre vs. DCIT 362 ITR 664 (Ker.), E. N. Gopakumar 75 taxmann.com 215 (Kerala), etc. The issue has now been finally settled by decisions of Hon'ble Supreme Court in the aforesaid cases of Principal Commissioner of Income-tax vs. Abhisar Buildwell (supra) and Dy. CIT vs. U. K. Paints (Overseas) Ltd. (supra) wherein view in favour of assessee has been taken. (C.2.1) In the…

Shri. Rajnish Gopinath, Bangalore vs. The Addl. Commissioner of Income Tax, Central Range-1, Bengaluru

In the result, appeal filed by the assessee is dismissed

ITA 1918/BANG/2024[2018-19]Status: DisposedITAT Bangalore25 Apr 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year :2018-19

For Appellant: Shri. R. S. V. S. Pavan Kumar, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 153Section 269SSection 271DSection 296S

…ble improvement of statements recorded under section 132(4) of the Act during search and seizure operations. During the appellate proceedings, the AO has relied on the judgment of Hon’ble Kerala High Court in the case of CIT v. Hotel Meriya reported in [2011] 332 ITR 537 / [2010] 195 Taxman 459 (Ker.) and held that there is strong evidentiary value of statements which were recorded under section 132(4) of the Act and there is other judgment of the Hon’ble Kerala High Court in the case of Abdul Razak ([2012] 20 taxman.com48[kerla]) which are very much applicable to the present facts of the case of the assessee whi…

Sudhir Singh Yadav, Gurgaon vs. DCIT, Circle 3(1), Gurgaon

ITA 3001/DEL/2023[2013-14]Status: DisposedITAT Delhi07 Apr 2025AY 2013-14

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special counsel for the Department
Section 132(4)Section 153ASection 50Section 68

…SCC Online Del 5772 , decision of ITA Nos. 2999 to 3005/Del/2024 Sushen Mohan Gupta Hon‘ble Delhi High Court in the case of Anil kumar Bhatia [2013] 352 ITR 493 (Del), PCIT v. Nau Nidh Overseas Pvt. Ltd. [2017] 394 ITR 753 (Del), CIT v. Hotel Meriya, (2011) 332 ITR 537, B. Kishore Kumar v. DCIT, Central Circle IV(1), Chennai, [2014] 52 taxmann.com 449, B. Kishore Kumar was upheld in (2015) 62 taxmann.com 215 to support that statement also constitutes as material because it is made in the course of the search . 27. As far as the statement u/s 132(4) of the Act by the assessee and three other persons, Mr. M.N. K…

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

ITA 120/JPR/2024[2018-19]Status: DisposedITAT Jaipur11 Mar 2025AY 2018-19
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

…y two parties and thus this claim cannot be accepted. 5.6 Further, regarding the legal principles to examine the validity of the retraction of statement, guidance is taken from the following judgments: CIT v. Hotel Meriya [2010] 195 Taxman 459 (Kerala)/[2011] 332 ITR 537 (Kerala) [26.05.2010] X X X X Pr. CIT vs. Shri Roshan Lal Sancheti [IT Appeal No. 47 of 2018, dated 30.10.2018], Hon'ble Rajasthan High Court. X X X X In the above judgment, inter-alia, the following arguments were taken on behalf of the assessee which stand rejected:- “Per contra, Mr. Prakul Khurana, learned counsel for the respondent-assessee s…

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

ITA 119/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Mar 2025AY 2017-18
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

…y two parties and thus this claim cannot be accepted. 5.6 Further, regarding the legal principles to examine the validity of the retraction of statement, guidance is taken from the following judgments: CIT v. Hotel Meriya [2010] 195 Taxman 459 (Kerala)/[2011] 332 ITR 537 (Kerala) [26.05.2010] X X X X Pr. CIT vs. Shri Roshan Lal Sancheti [IT Appeal No. 47 of 2018, dated 30.10.2018], Hon'ble Rajasthan High Court. X X X X In the above judgment, inter-alia, the following arguments were taken on behalf of the assessee which stand rejected:- “Per contra, Mr. Prakul Khurana, learned counsel for the respondent-assessee s…

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

ITA 118/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Mar 2025AY 2016-17
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

…y two parties and thus this claim cannot be accepted. 5.6 Further, regarding the legal principles to examine the validity of the retraction of statement, guidance is taken from the following judgments: CIT v. Hotel Meriya [2010] 195 Taxman 459 (Kerala)/[2011] 332 ITR 537 (Kerala) [26.05.2010] x x x X Pr. CIT vs. Shri Roshan Lal Sancheti [IT Appeal No. 47 of 2018, dated 30.10.2018], Hon'ble Rajasthan High Court. x x X X In the above judgment, inter-alia, the following arguments were taken on behalf of the assessee which stand rejected:- “Per contra, Mr. Prakul Khurana, learned counsel for the respondent-assessee s…

Jaipal Singh, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-2, Jaipur

Appeal of the assessee are disposed off

ITA 116/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

…y two parties and thus this claim cannot be accepted. 5.6 Further, regarding the legal principles to examine the validity of the retraction of statement, guidance is taken from the following judgments: CIT v. Hotel Meriya [2010] 195 Taxman 459 (Kerala)/[2011] 332 ITR 537 (Kerala) [26.05.2010] X X X X Pr. CIT vs. Shri Roshan Lal Sancheti [IT Appeal No. 47 of 2018, dated 30.10.2018], Hon'ble Rajasthan High Court. X X X X In the above judgment, inter-alia, the following arguments were taken on behalf of the assessee which stand rejected:- “Per contra, Mr. Prakul Khurana, learned counsel for the respondent-assessee s…