CIT v. Sree Meenakshi Mills Rs. 73.5

63 ITR 609Supreme Court of India1967#1938 most cited

What is CIT v. Sree Meenakshi Mills Rs. 73.5 authority for?

The Commissioner (Appeals) has the power to enhance an assessment under section 251(2) of the Income Tax Act, 1961, provided the assessee has been given a reasonable opportunity of being heard.

59

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. Sree Meenakshi Mills · section 251(2) · Commissioner Appeals · power to enhance assessment · natural justice · opportunity of hearing

Sections most often in play

Section 142(1)Section 144BSection 147Section 148Section 151Section 246ASection 250Section 253

Issues it is cited on

section 31paper companysection 251(2)share capital and share premiumsource of sourcecreditworthiness of the creditorsection 251(1)(a)live linkadmission of additional evidenceset off of lossesretraction of statemententry operator

Judgments citing CIT v. Sree Meenakshi Mills Rs. 73.5

ACIT, New Delhi vs. M/S. Star Light Consumer Electronics Pvt. Ltd., New Delhi

ITA 6070/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ACIT, New Delhi vs. M/S. Superstar Agency Pvt. Ltd., New Delhi

ITA 5832/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ACIT, New Delhi vs. M/S. Sur Buildcon Pvt. Ltd., New Delhi

ITA 5831/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ITO, New Delhi vs. M/S Stylish Construction Pvt. Ltd., New Delhi

ITA 5744/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ITO, New Delhi vs. M/S. Sukhna Real Estate Pvt. Ltd., Ghaziabad

ITA 5742/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ITO, New Delhi vs. M/S. Sukhna Steel Pvt. Ltd., New Delhi

ITA 5741/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ITO, New Delhi vs. M/S. Sunlight Tour and Travels Pvt. Ltd., Sahibabad

ITA 5740/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ITO, New Delhi vs. M/S. Sintex Consumers Electronics Pvt. Ltd., Delhi

ITA 5736/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ITO, New Delhi vs. M/S. Supreme Placement Services Pvt. Ltd., New Delhi

ITA 5650/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ITO, New Delhi vs. M/S Angel Cement Pvt. Ltd., Ghaziabad

ITA 4691/DEL/2016[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…• soon as they are CIT V Durga Prasad More 82 received(Page – 36, Para ITR 540 (SC) • 7.9 – CIT(A)’s order) Bombay Oil Industries Ltd V  Therefore, the CIT(A) DCIT [2000] 82 ITD 626 has deleted addition of • CIT V Sree Meenakshi Mills Rs. 73.5 crores and Ltd 63 ITR 609 made addition of Rs. • CIT V Precision Finance Ltd 1.74 crores @ 2 percent (1994) 208 ITR 405 for routing these • Bharati Pvt Ltd V CIT W.B. transactions of having (1978) 111 ITR 991 been providing a fluid • CIT V Frostair (P) Ltd ITA No. mechanism from one 183 0f 2002 and 1638 of company to another. 2006 (Page – 37, Para 7.10 – • CIT V Youth Cons…

ITO 8 (2)(1), Mumbai vs. Bhairav Steel Enterprises Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue is hereby dismissed

ITA 4126/MUM/2019[2009-10]Status: DisposedITAT Mumbai01 Mar 2021AY 2009-10

Bench: Shri M. Balaganesh, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.4126/Mum/2019 (निर्धारण वर्ा / Assessment Year: 2009-10) Ito 8(2)(1) बिधम/ Bhairav Steel Enterprises Room No.259/A,2Nd Floor, Pvt. Ltd. Vs. Aayakar Bhavan, M. K. 10, Kanti Nagar, A/30, Road, Mumbai-400020. Rajgruhi, Behind J. B. Nagar, Andheri Kurla Road, Andheri (E), Mumbai- 400059. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacb9118K (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. Revenue By: Shri Rajendra Joshi (Dr) Assessee By: Shri Rajiv Khandelwal सुनवाई की तारीख / Date Of Hearing: 03/12/2020 घोषणा की तारीख /Date Of Pronouncement: 01/03/2021 आदेश / O R D E R Per Amarjit Singh, Jm: The Revenue Has Filed The Present Appeal Against The Order Dated 25.03.2019 Passed By The Commissioner Of Income Tax (Appeals) -16, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2009- 10. 2. The Revenue Has Raised The Following Grounds: -

For Appellant: Shri Rajiv KhandelwalFor Respondent: Shri Rajendra Joshi (DR)
Section 143(2)Section 148

…ection of explanation 6 A.Y.2009-10 of cash credit, in the instant case the appellant has failed to even corroborate the claim before the Ld. AO. 6.2.5. Reliance is also placed on the judgement of Hon’ble Supreme Court in the case of Sri Meenakshi Mills Ltd 63 ITR 609 where it was held that the I.T. Authorities are entitled to pierce the veil of Corporate Entity and to look into reality of transaction. In the case of McDowell & Co. 154 ITR 148(SC) it was stated that implications of tax avoidance are manifold. First, there is substantial loss of much needed public revenue; Next, there is serious disturbance caus…

Essar Capital Ltd, Mumbai vs. Pr CIT 6, Mumbai

In the result the appeal of the assessee is allowed

ITA 3759/MUM/2017[2012-13]Status: DisposedITAT Mumbai08 Jan 2021AY 2012-13

Bench: Shri Rajesh Kumar & Shri Ram Lal Negiassessment Year: 2012-13 M/S. Vajresh Consultants Prcit 6, Ltd. (Earlier Known As Aayakar Bhavan, Essar Capital Ltd.), Mumbai - 400020 Vs. 40-B, Ridge Road, Malabar Hill, Mumbai – 400 006 Pan: Aabce 7257R (Appellant) (Respondent) Present For: Assessee By : Shri Nishant Thakkar, A.R. & Shri Hiten Chande, A.R. Revenue By : Shri R. Manjunatha Swamy, D.R. Date Of Hearing : 23.10.2020 Date Of Pronouncement : 08.01.2021 O R D E R

For Appellant: Shri Nishant Thakkar, A.R. &For Respondent: Shri R. Manjunatha Swamy, D.R
Section 143(3)Section 263

…y represented the facts" to the AO. "Having wrongly represented to the AO, it is not open to Indian Rayon to contend that the AO is precluded from taking corrective steps as is permissible in law" the Court added. 4.5 In CIT v. Sri Meenakshi Mills Ltd. [1967] 63 ITR 609 (SC), the judicial approach to such problems was stated as follows (p. 616): "It is true that from the juristic point of view, the company is a legal personality entirely distinct from its members and the company is capable of enjoying rights and being subjected to duties which are not the same as 63 M/s. Vajresh Consultants Ltd. (Earlier known as…

ITO, New Delhi vs. M/S Apple Green Power Ltd., New Delhi

In the result, the Appeal of the Revenue is dismissed

ITA 4354/DEL/2015[2012-13]Status: DisposedITAT Delhi18 Sept 2019AY 2012-13

Bench: Sh. H.S. Sidhu & Shri O.P. Kantassessment Year: 2012-13

Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 68

…vs. NR Portfolio Pvt. Ltd. 2013-TIOL- 3 955-HC-DEL-IT dated 22.11.2013 and Hon’ble Apex Court decisions in the case of CIT vs. Durga Prasad More (1971) 82 ITR 540 and Sumati Dayal vs. CIT (1995) 80 Taxman 89/214 ITR 801(SC) & CIT vs. Sri Meenakshi Mills Ltd. 63 ITR 609, has observed that assessee company received accommodation entries Rs. 18,48,00,000/- i.e. from M/s Shirin Exports Pvt. Ltd. amounting to Rs. 8,78,00,000/- and M/s Vigorous Trade Link Pvt. Ltd. amounting to Rs. 9,70,00,000/- and further observed that the accommodation entry givers usually charge 0.75% of the cheque amount as commission for providi…

DCIT, New Delhi vs. Sh. Anil Aggarwal, New Delhi

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4668/DEL/2015[2012-13]Status: DisposedITAT Delhi30 Aug 2019AY 2012-13

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

…a colourable device and most importantly no case of any tax evasion was established by the Assessing Officer in case of the appellant or overseas companies. 9.1.0 The Assessing Officer’s reliance on the judgment in the case of CIT Vs. Sri Meenakshi Mills Ltd. 63 ITR 609 (SC) is not applicable to the facts of the appellant’s case. In aforesaid case which was relied by the Assessing Officer upon by Assessing Officer , the company borrowed an exorbitant amount of money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the dire…

DCIT, New Delhi vs. Sh. Anil Aggarwal, New Delhi

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4665/DEL/2015[2009-10]Status: DisposedITAT Delhi30 Aug 2019AY 2009-10

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

…a colourable device and most importantly no case of any tax evasion was established by the Assessing Officer in case of the appellant or overseas companies. 9.1.0 The Assessing Officer’s reliance on the judgment in the case of CIT Vs. Sri Meenakshi Mills Ltd. 63 ITR 609 (SC) is not applicable to the facts of the appellant’s case. In aforesaid case which was relied by the Assessing Officer upon by Assessing Officer , the company borrowed an exorbitant amount of money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the dire…

DCIT, New Delhi vs. Sh. Anil Aggarwal, New Delhi

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4664/DEL/2015[2008-09]Status: DisposedITAT Delhi30 Aug 2019AY 2008-09

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

…a colourable device and most importantly no case of any tax evasion was established by the Assessing Officer in case of the appellant or overseas companies. 9.1.0 The Assessing Officer’s reliance on the judgment in the case of CIT Vs. Sri Meenakshi Mills Ltd. 63 ITR 609 (SC) is not applicable to the facts of the appellant’s case. In aforesaid case which was relied by the Assessing Officer upon by Assessing Officer , the company borrowed an exorbitant amount of money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the dire…

DCIT, New Delhi vs. Sh. Anil Aggarwal, New Delhi

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4663/DEL/2015[2007-08]Status: DisposedITAT Delhi30 Aug 2019AY 2007-08

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

…a colourable device and most importantly no case of any tax evasion was established by the Assessing Officer in case of the appellant or overseas companies. 9.1.0 The Assessing Officer’s reliance on the judgment in the case of CIT Vs. Sri Meenakshi Mills Ltd. 63 ITR 609 (SC) is not applicable to the facts of the appellant’s case. In aforesaid case which was relied by the Assessing Officer upon by Assessing Officer , the company borrowed an exorbitant amount of money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the dire…

DCIT, New Delhi vs. Sh. Anil Aggarwal, New Delhi

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4662/DEL/2015[2006-07]Status: DisposedITAT Delhi30 Aug 2019AY 2006-07

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

…a colourable device and most importantly no case of any tax evasion was established by the Assessing Officer in case of the appellant or overseas companies. 9.1.0 The Assessing Officer’s reliance on the judgment in the case of CIT Vs. Sri Meenakshi Mills Ltd. 63 ITR 609 (SC) is not applicable to the facts of the appellant’s case. In aforesaid case which was relied by the Assessing Officer upon by Assessing Officer , the company borrowed an exorbitant amount of money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the dire…

DCIT, New Delhi vs. Sh. Anil Aggarwal, New Delhi

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4667/DEL/2015[2011-12]Status: DisposedITAT Delhi30 Aug 2019AY 2011-12

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

…a colourable device and most importantly no case of any tax evasion was established by the Assessing Officer in case of the appellant or overseas companies. 9.1.0 The Assessing Officer’s reliance on the judgment in the case of CIT Vs. Sri Meenakshi Mills Ltd. 63 ITR 609 (SC) is not applicable to the facts of the appellant’s case. In aforesaid case which was relied by the Assessing Officer upon by Assessing Officer , the company borrowed an exorbitant amount of money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the dire…

DCIT, New Delhi vs. Sh. Anil Aggarwal, New Delhi

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4666/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2019AY 2010-11

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

…a colourable device and most importantly no case of any tax evasion was established by the Assessing Officer in case of the appellant or overseas companies. 9.1.0 The Assessing Officer’s reliance on the judgment in the case of CIT Vs. Sri Meenakshi Mills Ltd. 63 ITR 609 (SC) is not applicable to the facts of the appellant’s case. In aforesaid case which was relied by the Assessing Officer upon by Assessing Officer , the company borrowed an exorbitant amount of money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the dire…