How many judgments cite Coimbatore Spinning & Weaving Co. Ltd. v. CIT?

21 judgments on BharatTax cite Coimbatore Spinning & Weaving Co. Ltd. v. CIT (95 ITR 375), spanning 2015 to 2026.

Coimbatore Spinning & Weaving Co. Ltd. v. CIT

95 ITR 375High Court1974#5579 most cited

What is Coimbatore Spinning & Weaving Co. Ltd. v. CIT authority for?

Excess stock found after rejecting an assessee's explanation is an inescapable conclusion that it originated from undisclosed sources.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

Coimbatore Spinning & Weaving Co. Ltd. v. CIT · 95 ITR 375 · excess stock · undisclosed sources · unexplained cash deposits · concealed income · business income

Judgments citing Coimbatore Spinning & Weaving Co. Ltd. v. CIT

AJAY FOOD PRODUCTS vs. INCOME TAX OFFICER AND ORS.

ITA/16/2007HC J&K11 Mar 2026

Bench: HON'BLE THE CHIEF JUSTICE,HON'BLE MR. JUSTICE RAJNESH OSWAL

…has consistently been disapproved by the Courts. In support of his submissions, reliance has been placed upon the judgments of the High Court of Madras in case titled Coimbatore Spinning & Weaving Co. Ltd. Vs. Commissioner of Income Tax, passed in (1974) 95 ITR 375, High Court of Punjab and Haryana in case titled Shakuntla Thukral Vs. Commissioner of Income Tax, passed in ITA No. 302 of 2013 dated 06.02.2014 and High Court of Madhya Pradesh, Gwalior Bench in case titled Suraj Bhan Oil (P) Ltd. Vs. Deputy Commissioner of Income Tax, passed in IT Appeal No. 121 of 2021 dated 18.02.2022. 10. Heard learne…

ARJUNSINH HARISINH THAKOR,SURAT vs. INCOME TAX OFFICER, BARDOLI

In the result, grounds No

ITA 245/SRT/2021[2017-18]Status: DisposedITAT Surat15 Jun 2023AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Arjunsinh Harisinh Thakor, I.T.O., 1 Thakor Niwas, Zanda Chowk, Ward-1, Vs. Tarasadi Road, Kosamba, Bardoli. Surat-394120. Pan No. Aabpt 1270 G Appellant/ Assessee Respondent/ Revenue

Section 115BSection 254(1)Section 68

…h deposits (assets) and cash credits could be reasonably attributed to the pre-existing fund of concealed income or they were reasonably explained by reference to the concealed income earned in the relevant year. In Coimbatore Spg & Wvg Co. Ltd. v. CIT [1974] 95 ITR 375 (Mad), the Hon'ble Court held that once the Tribunal finds „excess‟ stock after rejecting the explanation furnished by the assessee, the inescapable conclusion is that the same would have come from undisclosed sources. No material/evidence of the same as representing suppressed profit, in whole or in part, has been, as aforenoted, led by the asses…

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1), JABALPUR vs. SHRI SANDESH KUMAR JAIN, JABALPUR

In the result, the Revenue‟s appeal is partly allowed

ITA 41/JAB/2020[2017-18]Status: DisposedITAT Jabalpur27 Jul 2022AY 2017-18

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

For Respondent: Shri Rahul Bardia, FCA

Section 115BSection 133ASection 143(3)Section 28Section 68Section 69Section 69B

…h deposits (assets) and cash credits could be reasonably attributed to the pre-existing fund of concealed income or they were reasonably explained by reference to the concealed income earned in the relevant year. In Coimbatore Spg & Wvg Co. Ltd. v. CIT [1974] 95 ITR 375 (Mad), the Hon‟ble Court held that once the Tribunal finds „excess‟ stock after rejecting the explanation furnished by the assessee, the inescapable conclusion is that the same would have come from undisclosed sources. No material/evidence of the same as representing suppressed profit, in whole or in part, has been, as aforenoted, led by the asses…

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 3,, AURANGABAD vs. M/S. SHYAM TRADING COMPANY,, BEED

In the result, the appeal filed the assessee stands allowed

ITA 2529/PUN/2017[2014-15]Status: DisposedITAT Pune16 Mar 2022AY 2014-15

For Appellant: Shri Chetan KariaFor Respondent: Shri Piyushkumar Singh Yadav

Section 131Section 143(3)Section 145(3)Section 36(1)(iii)Section 69

…ments furnished to the bank cannot be overlooked placing reliance on the following decisions :- (i) Estee Exports (P.) Ltd. vs. ITO, 31 taxmann.com 70. (ii) Ramanlal Kacharulal Tejmal vs. CIT, 146 ITR 368. (iii) Coimbatore Spinning & Weaving Co. Ltd. vs. CIT, 95 ITR 375. (iv) Dhansiram Agarwalla vs. CIT, 201 ITR 192. 4. However, the ld. CIT(A) had granted relief to the assessee by directing the Assessing Officer to adopt the value shown in the stock statements furnished to the bank in its entirety and not to ignore the negative stock of the cotton lint by holding that the assessee would have made undisclosed sale…

M/S. SHYAM TRADING COMPANY,BEED vs. INCOME-TAX OFFICER, WARD – 2, BEED

In the result, the appeal filed the assessee stands allowed

ITA 2706/PUN/2017[2014-15]Status: DisposedITAT Pune16 Mar 2022AY 2014-15

For Appellant: Shri Chetan KariaFor Respondent: Shri Piyushkumar Singh Yadav

Section 131Section 143(3)Section 145(3)Section 36(1)(iii)Section 69

ARCEE ISPAT UDYOG LTD.,HARYANA vs. ACIT, HISAR

In the result, the appeal of the assessee in ITA No

ITA 4653/DEL/2016[2011-12]Status: DisposedITAT Delhi19 Aug 2020AY 2011-12

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[Assessment Year: 2011-12]

For Appellant: Shri S. Krishnan AdvFor Respondent: Ms. Rakhi Vimal, Sr DR

Section 69A

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘A’ BENCH, NEW DELHI [THROUGH VIDEO CONFERENCE] BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER, AND MS. SUCHITRA KAMBLE, JUDICIAL MEMBER [Assessment Year: 2011-12] Arcee Ispat Udyog Ltd Vs. The A.C.I.T 7, K.M. Stone Talwandi Rana Hisar Circle Distt Hisar, Haryana Hisar PAN: AABCA3462 C [Appellant] [Respondent] Date of Hearing : 18.08.2020 Date of Pronouncement : 19.08.2020 Assessee by : Shri S. Krishnan Adv Revenue by : Ms. Rakhi Vimal, Sr DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER:- This appeal by the assessee is preferred against the order of the…

ACIT CORPORATE CIRCLE 2, COIMBATORE vs. ELGI ELECTRIC & INDUSTRIES LTD., COIMBATORE

In the result, the appeal filed by the Revenue is dismissed

ITA 2116/CHNY/2018[2008-09]Status: DisposedITAT Chennai02 Jan 2020AY 2008-09

Bench: Shri Inturi Rama Rao & Shri Duvvuru R.L. Reddyआयकर अपील सं./I.T.A.No.2116/Chny/2018 िनधा"रण वष"/Assessment Year: 2008-09 The Assistant Commissioner Of M/S. Elgi Electric & Industries Ltd., Income Tax, Corporate Circle, Vs. 737-D, Elgi Towers, Puliakulam, 63-A, Race Course Road, Coimbatore. Green Fields, Coimbatore 641 045. [Pan:Aabhs0590L] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri A. Sundararajan, Addl. Jcit ""थ" की ओर से/Respondent By : Ms. T. Sandhyaarti, Ca सुनवाई की तारीख/ Date Of Hearing : 06.11.2019 घोषणा की तारीख /Date Of Pronouncement : 02.01.2020 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Coimbatore, Dated 04.04.2018 For The Assessment Year 2008-09. The Revenue Has Challenged The Order Of Deleting The Addition Made On Account Of Variation In The Value Of Closing Stock Declared In The Balance Sheet Vis-À-Vis That Declared Before The Bankers, Without Appreciating The Fact That Both The Figures Are Certified By The Assessee Itself.

For Appellant: Shri A. Sundararajan, Addl. JCITFor Respondent: Ms. T. Sandhyaarti, CA

Section 143(3)Section 69

…आयकर अपीलीय अिधकरण, ‘‘बी’ "ायपीठ, चे"ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी इंटूरी रामा राव, लेखा सद" एवं "ी धु"ु" आर.एल रे"ी, "ाियक सद" के सम" Before Shri Inturi Rama Rao, Accountant Member & Shri Duvvuru R.L. Reddy, Judicial Member आयकर अपील सं./I.T.A.No.2116/Chny/2018 िनधा"रण वष"/Assessment Year: 2008-09 The Assistant Commissioner of M/s. Elgi Electric & Industries Ltd., Income Tax, Corporate Circle, Vs. 737-D, Elgi Towers, Puliakulam, 63-A, Race Course Road, Coimbatore. Green Fields, Coimbatore 641 045. [PAN:AABHS0590L] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant…

SRI.C.SHAJI,TRIVANDRUM vs. THE ITO, WARD-2(1), TRIVNDRUM

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

ITA 505/COCH/2017[2013-14]Status: DisposedITAT Cochin20 Sept 2019AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Dr.Pradeep K.P., AdvocateFor Respondent: Smt.A.S.Bindhu, Sr.DR

…n the absence of any explanation furnished by the assessee, the CIT(A) is justified in confirming the addition made by the Assessing Officer. We rely on the judgment of the Hon’ble Madras High Court in the case of Coimbatore Spinning & Weaving Co. Ltd. v. CIT 95 ITR 375 (Mad.)], wherein the Hon’ble Court held as under:- “The practice of exagerating inflation of stocks in statements given to banks to get loan is not shown to exist or that it has been recognised in the commercial circles or by Courts. Even assuming that such a practice exists the Tribunal is not expected to take judicial notice of such sub-standar…

SMT. NEETA SHARMA,AGRA vs. A.C.I.T., CIRCLE-2, AGRA

In the result, appeal of the Revenue is dismissed and the appeal of the assessee is partly allowed

ITA 299/AGR/2013[2007-08]Status: DisposedITAT Agra19 Aug 2019AY 2007-08

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaassessment Year: 2007-08

Section 234ASection 40A(2)(b)Section 40A(3)Section 46A

…sbelieved. The Tribunal has placed reliance on the following cases : 1.India Motor Parts & Accessories (P.) Ltd. v. CIT [1966] 60 ITR 531 (Mad.) 2.CIT v. Ramkrishna Mills (Coimbatore) Ltd. [1974] 93 ITR 49 (Mad.) 3.Coimbatore Spg. &Wvg. Co. Ltd. v. CIT [1974] 95 ITR 375 (Mad.) 4.Gaindamal Handa& Sons v. CIT [1980] 4 Taxman 210 (Punj. & Har.) 5. Swadeshi Cotton Mills Co. Ltd. v. CIT [1980] 125 ITR 33 1 (All.). The above cases lay down that it is a practice to inflate stocks with a view to obtain higher overdraft facilities from the banks. In the case of Swadeshi Cotton Mills Co. Ltd. ( supra), the goods pledged wi…

A.C.I.T.-2, AGRA vs. SMT. NEETA SHARMA PROP., AGRA

In the result, appeal of the Revenue is dismissed and the appeal of the assessee is partly allowed

ITA 286/AGR/2013[2007-08]Status: DisposedITAT Agra19 Aug 2019AY 2007-08

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenaassessment Year: 2007-08

Section 234ASection 40A(2)(b)Section 40A(3)Section 46A

M/S OM RUDRA PRIYA HOLIDAY RESORT PVT. LTD.,SAWAI MADHOPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, KOTA

In the result, appeal of the assessee is allowed

ITA 416/JPR/2018[2013-14]Status: DisposedITAT Jaipur20 Dec 2018AY 2013-14

For Appellant: Shri P.C. Parwal (CA)For Respondent: Shri B.K. Gupta (CIT)

Section 143(3)Section 263

…elied upon the decision of Hon’ble Calcutta High Court in the case of Binod Kumar Agarwala vs. CIT, 257 Taxman 58 (Cal.). He has also relied upon the decisions of Hon’ble Madras High Court in the case of M/s. Coimbatore Spinning & Weaving Co. Ltd. vs. CIT, 95 ITR 375 (Mad.) and Hon’ble Gauhati High Court in the case of 6 M/s. Om Rudra Priya Holiday Resort Pvt. Ltd., Sawai Madhopur. Dhansiram Agarwalla vs. CIT, 201 ITR 192 (Gau.). Thus the ld. D/R has submitted that once the AO has failed to conduct a proper enquiry on the issue, then it renders the order passed by the AO erroneous in so far as it is prejudi…

THE DCIT(OSD), CIRCLE-8,, AHMEDABAD vs. M/S. TORRENT CABLES LTD.,, AHMEDABAD

In the result, appeal filed by the Department is dismissed

ITA 1293/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad26 Oct 2018AY 2010-11

Bench: Shri Pramod Kumar & Shri Mahavir Prasad)

For Appellant: Shri Lalit P. Shah, Sr. D.RFor Respondent: Shri P. M. Mehta, A.R

Section 145Section 145ASection 14SSection 43B

…ference is only of inflated price of the stock which was given to the bank. We find that the As Officer in support of his finding has relied on the decision of the hon'ble Madras High Court in the case of Coimbatore Spinning and Weaving Co. Ltd. v. CIT [1974] 95 ITR 375. the decision of the hon'ble Supreme Court in the case of Dhansiram Aganvalla v. CIT [1993] 201 ITR 192 (Gauhati) and concluded that the assessee was unable to discharge the onus to prove that books of account alone give the correct picture and the statement given to the bank was motivated. In the present case at hand, it is not disputed by the Re…

MADAN MOHAN ENGINEERING & HARDWARE,HOOGHLY vs. ITO, WARD - 24(2), HOOGHLY , HOOGHLY

In the result, the appeal of the assessee is allowed

ITA 181/KOL/2018[2010-11]Status: DisposedITAT Kolkata20 Jun 2018AY 2010-11

Bench: Shri P.M. Jagtap, Am] I.T.A. No. 181/Kol/2018 Assessment Year: 2010-11 M/S. Madan Mohan Engineering & Hardware.................................…………………...Appellant Bhanderhati, Dhaniakhali, Hooghly – 712 301. [Pan: Aajfm 9702 A] Ito, Ward 24(2) Hooghly...................……………………………………………..................Respondent Aayakar Bhawan, G.T. Road, Khadina More, Chinsurah, Hooghly – 712 101. Appearances By: Shri Sanjoy Chatterjee, Fca Appearing On Behalf Of The Assessee. Shri D.C. Mondal, Addl. Cit Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : May 29, 2018 Date Of Pronouncing The Order : June 20, 2018 Order This Appeal Filed By The Assessee Is Directed Against The Order Of Ld. Cit (Appeals) – 6, Kolkata Dated 28.07.2017 & The Solitary Issue Involved Therein Relates To The Addition Of Rs. 10,00,890/- Made By The Ao & Confirmed By The Ld. Cit(A) On Account Of Difference In Valuation Of Stock As Reflected In The Accounts Of The Assessee & As Shown In The Stock Statement Submitted To The Bank.

Section 143(3)Section 263

…w how the document has been wrongly considered. As such neither on facts nor on law the assessee’s explanation is acceptable, as the alleged practice cannot be given judicial notice. Reliance is placed upon Coimbatore Spinning & Weaving Co. Ltd. V. CIT (1974) 95 ITR 375 (Mad), Ramanlal Kacharulal Tejmal V. CIT (1984) 146 ITR 368 and Dhansiram Agarwala V. CIT (1993) 201 ITR 192 (Gau). 5.2. In this context the ratio laid down by the Hon’ble Madras High Court in the case of “Coimbatore Spinning & Weaving Co. Ltd. V. CIT (1974) 95 ITR 375 (Mad) is mentioned. The Hon’ble High Court observed that the alleged practice…

ANIL D AGRAWAL,MUMBAI vs. ITO CIR 17(1)(1), MUMBAI

In the result, the appeal filed by the assessee is dismissed

ITA 1809/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Feb 2018AY 2010-11

Bench: Shri Joginder Singh & Shri G. Manjunathashri Anil D. Agrawal Income Tax Officer-17(1)(1) A-13, Omnitech House Room No. 115, 1St Floor Vs. Kondivita, Marol Midc Aayakar Bhavan, M.K. Road Andheri (E), Mumbai 400059 Mumbai 400020 Pan – Aerpa1868D Appellant Respondent

For Appellant: Shri Jayant R. BhattFor Respondent: Shri V. Vidhyadhar

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

…e the gross profit by 1% of the total accommodation entries. The CIT(A), after considering the submissions of the assessee and also relying upon the decision of the Hon'ble Madras High Court in the case of Coimbatore Spinning & Weaving Co. Ltd. vs. CIT (1974) 95 ITR 375, observed that the aspect of substandard morality so openly professes and admitted is astonishing and shocking to say the least. Thereafter to plead that the profit rate on the alleged practice which is unethical and illegal should be reduced to a particular percentage is taking things a bit too far. The CIT(A) further observed that already reason…

M/S AMARESH RICE MILL,BURDWAN vs. ITO, WARD 1, BURDWAN, BURDWAN

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

ITA 985/KOL/2017[2009-10]Status: DisposedITAT Kolkata05 Jan 2018AY 2009-10

Bench: Hon’Ble Shri J.Sudhakar Reddy, Am] I.T.A No. 985/Kol/2017 Assessment Year : 2009-10 M/S Amaresh Rice Mill -Vs- I.T.O., Ward-1, Burdwan [Pan: Aamfa 3953 G] (Appellant) (Respondent)

For Appellant: Shri A.N.Chatterjee, FCAFor Respondent: Shri Sanjay Mukherjee, Addl. CIT

Section 133(6)Section 143(3)Section 44A

…details of transaction of the assessee. It was contended that the word ‘provisional’ was by mistake omitted in the statement submitted to the bank. The AO relied on the decision in the case of Coimbatore Spinning & Waiving Co. Ltd. vs. CIT(Madras) reported in 95 ITR 375 and took the turn over declared by the bank as turnover of the assessee and estimated the gross profit 1.8% of the turn over as income of the assessee. Aggrieved, the assessee carried the matter in appeal without success. Further aggrieved the assessee is in appeal before us. 3. The Ld. Counsel for the assessee submitted that, the word ‘provision…

ACIT, COIMBATORE vs. M/S. ELGI ELECTRIC & INDUSTRIES LTD., COIMBATORE

In the result, the appeal filed by the revenue is allowed for statistical purposes

ITA 2362/CHNY/2016[2011-12]Status: DisposedITAT Chennai26 Jul 2017AY 2011-12

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Shri Pavuna Sundari, JCITFor Respondent: Shri Jagadisan, CA

Section 69

…5/-. After giving the assessee an opportunity of being heard etc., taking cognizance of Punjab & Haryana High Court decision in B.T. Steels Limited Vs CIT 328 ITR 471 and the Jurisdictional High Court decision in Coimbatore Spinning & Weaving Limited Vs CIT 95 ITR 375, the Assessing Officer added the above difference of Rs. 76,28,385/- u/s. 69. Aggrieved against that order, the assessee filed an appeal before the CIT(A). The CIT(A) relying on this ITAT order in ITA No. 303/Mds/2014 dated 30.04.2014 for assessment year 2009-10 allowed the appeal holding that the closing stock of this year would be treated as…

DCIT CIR 29(3), MUMBAI vs. RAJ GIRISH KARIA, MUMBAI

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

ITA 1279/MUM/2015[2010-11]Status: DisposedITAT Mumbai28 Apr 2017AY 2010-11

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2010-11

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Arun Shenoy, DR

Section 36(1)(iii)Section 68

…ck statement made for the bank should be ignored because of the practice to inflate stock so as to get larger credit from the bank cannot be lightly accepted as was decided by the Hon'ble Madras High Court in Coimbatore Spinning and Weaving Co. vs. CIT (1974) 95 ITR 375 (Mad). Following the said decision, it was held that in similar circumstances, the addition was justified. We may refer to the decision in the case of Dhansiram Agarwalla vs. CIT (1993) 201 ITR 192 (Gau) assessee’s SLP dismissed in (1993) 204 ITA No. 1279 & 1037/MUM/2015 17 ITR St. 45 (SC). In Ramanlal Kacharulal Tejmal vs. CIT(1983) 12 Taxman 1…

RAJ GIRISH KARIA,MUMBAI vs. JCIT 23(3), MUMBAI

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

ITA 1037/MUM/2015[2010-11]Status: DisposedITAT Mumbai28 Apr 2017AY 2010-11

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2010-11

For Appellant: Shri Dharmesh Shah, ARFor Respondent: Shri Arun Shenoy, DR

Section 36(1)(iii)Section 68

DCIT, NEW DELHI vs. M/S. THE BASTI SUGAR MILLS CO. LTD., DELHI

In the result ground No. 1 of the appeal of the revenue is dismissed

ITA 1032/DEL/2014[1999-2000]Status: DisposedITAT Delhi06 Feb 2017AY 1999-2000

Bench: Shri H.S.Sidhu & Shri Prashant Maharishidcit, The Basti Sugar Mills Co. Ltd, Circle-14(1), 207, Essel House, Vs. New Delhi 10 Asaf Ali Road, Delhi Pan: Aaact0490Q (Appellant) (Respondent)

For Appellant: Ms. Rachna Singh, CIT DRFor Respondent: Sh. KVSR Krishna, CA

…quantity which can be obtained by the assessee. He further relied upon the decision of the Hon’ble Gauhati High Court in case of Dhansiram Agarwalla V CIT 201 ITR 192, Hon’ble Madras High Court in case of Coimbatore spinning and weaving company Ltd versus CIT 95 ITR 375, Hon’ble Karnataka High Court in case of Recon machine tools private Ltd versus CIT 286 ITR 637, Hon’ble Andhra Pradesh High Court in case of CIT versus mopeds India 173 ITR 347 and Hon’ble Bombay High Court in case of Molmould Corporation versus CIT 202 ITR 789. 5. The Ld. authorized representative first referred to the para No. 11 of the order o…

ITO, WD-41(2), KOLKATA, KOLKATA vs. M/S IMAGE SIGN, KOLKATA

In the result, appeal of revenue is dismissed

ITA 650/KOL/2014[2006-2007]Status: DisposedITAT Kolkata03 Feb 2017AY 2006-2007

Bench: Shri N. V. Vasudevan, Jm & Shri M. Balaganesh, Am]

For Appellant: Md. Ghayas Uddin, JCITFor Respondent: Shri D. K. Bandyopadhyay, FCA

Section 143(3)Section 154Section 194CSection 40

…ng High Courts in the following cases and hence, the same would make the issue debatable: i) CIT Vs. Pioneer Breeding Farms 295 ITR 78 (Mad), ii) CIT Vs. Udaipur Chemicals & Fertilizers (P) Ltd. 211 CTR 191, iii) Coimbatore Spinning & Weaving Co. Ltd. Vs. CIT 95 ITR 375 (Mad), iv) Dhansiram Agarwalla Vs. CIT 111 CTR 39 (Gau), v) Century Foams (P) Ltd. Vs. CIT 123 CTR 342 (All) and vi) V. Rajan Vs. CIT 96 ITR 64 (Mad). Since the subject mentioned issue also is debatable the same cannot be adjudicated in section 154 proceedings. Hence, the grounds raised by the revenue are dismissed and 6 M/s. Image Sign, AY 2006-0…

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