Indian Hotels Co. Ltd. v. ITO

245 ITR 538Supreme Court of India2000#4416 most cited

What is Indian Hotels Co. Ltd. v. ITO authority for?

A tribunal's decision against an assessee is upheld when following the Supreme Court's decision in Indian Hotels Co. Ltd. v. ITO, which dealt with the issue of 'manufacture or production' in relation to excise duty payment.

27

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2015 to 2025.

Also referred to as

Indian Hotels Co. Ltd. v. ITO · 245 ITR 538 · 112 Taxman 46 · manufacture or production · excise duty · assessment

Also reported as

112 Taxmann 46

Sections most often in play

Section 10BSection 144Section 145Section 147Section 80HHCSection 148Section 2(29BA)Section 10B(9A)
Read the full judgment

Issues it is cited on

section 2(29ba)export oriented unitconvertible foreign exchangespeculation losssection 80jsection 10brejection of books of accountsection 145section 56first appealspeaking ordersection 10

Judgments citing Indian Hotels Co. Ltd. v. ITO

Srimanthi Kanthimathi Kumaraswami Mudaliar Kalyanamandapam Trust, Chittoor vs. CIT (Exemption), Hyderabad

ITA 690/HYD/2025[2025-26]Status: HeardITAT Hyderabad16 Jul 2025AY 2025-26

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

Section 12A

…uction' as repeatedly decided by the Apex Court in: Tanna & modi vs CIT 292 ITR 209 (SC) K.P.Mohammed Salim vs CIT 300 ITR 302 (SC) New India assurance co ltd vs Nusli Neville Wadia 13 SCR 598 K.P.Varghese vs ITO 131 ITR 597 (SC); Indian Hotels co ltd. vs ITO 245 ITR 538 (SC) R & B Falcon (A) pty ltd. vs CIT 301 ITR 309 (SC) LIC vs Retires LIC officers association AIR 2008 SC 1485 8. The CIT(E) failed to follow the principle that…

ACIT Cir 4(2), Mumbai vs. M .M. Poonjiaji Spices Ltd, Mumbai

ITA 755/MUM/2012[B]Status: DisposedITAT Mumbai15 Apr 2024

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…to 2003-04 in ITA Nos. 2416 to 2418/Mds/2007 vide order dated 06-02-2009 the co-ordinate Bench of this Tribunal has held the issue against the assessee by following the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538/ 112 Taxman 46. It was the submission that after the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. (supra) referred to supra, the issue of 'manufacture or production' has undergone substantial debate. It was the submission that the Hon'ble Supreme Court in the case of ITO v. Arihant Tiles & Marbles (P) Ltd. [2010] 32…

DCIT., Cir.-4(2), Mumbai vs. M.M. Poonjiaji Spices Ltd, Mumbai

ITA 3409/MUM/2011[2007-08]Status: DisposedITAT Mumbai15 Apr 2024AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…to 2003-04 in ITA Nos. 2416 to 2418/Mds/2007 vide order dated 06-02-2009 the co-ordinate Bench of this Tribunal has held the issue against the assessee by following the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538/ 112 Taxman 46. It was the submission that after the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. (supra) referred to supra, the issue of 'manufacture or production' has undergone substantial debate. It was the submission that the Hon'ble Supreme Court in the case of ITO v. Arihant Tiles & Marbles (P) Ltd. [2010] 32…

DCIT Cir 4(2), Mumbai vs. M.M. Poonjilaji Spices Ltd, Mumbai

ITA 5539/MUM/2009[2006-07]Status: DisposedITAT Mumbai15 Apr 2024AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Dr. K. Shivaram, Sr. AdvFor Respondent: Shri Chetan M. Kacha, Sr. AR
Section 10BSection 143Section 144Section 145Section 147Section 148Section 9

…to 2003-04 in ITA Nos. 2416 to 2418/Mds/2007 vide order dated 06-02-2009 the co-ordinate Bench of this Tribunal has held the issue against the assessee by following the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538/ 112 Taxman 46. It was the submission that after the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. (supra) referred to supra, the issue of 'manufacture or production' has undergone substantial debate. It was the submission that the Hon'ble Supreme Court in the case of ITO v. Arihant Tiles & Marbles (P) Ltd. [2010] 32…

Income Tax Officer 4(2)(4), Mumbai vs. M/S. M.M. Poonjiaji Spices Ltd., Mumbai

ITA 6523/MUM/2008[2005-2006]Status: DisposedITAT Mumbai15 Apr 2024AY 2005-2006

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…to 2003-04 in ITA Nos. 2416 to 2418/Mds/2007 vide order dated 06-02-2009 the co-ordinate Bench of this Tribunal has held the issue against the assessee by following the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538/ 112 Taxman 46. It was the submission that after the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. (supra) referred to supra, the issue of 'manufacture or production' has undergone substantial debate. It was the submission that the Hon'ble Supreme Court in the case of ITO v. Arihant Tiles & Marbles (P) Ltd. [2010] 32…

ITO - 4(2)(4), Mumbai vs. M/S. M.M. Poonjiaji Spices Ltd., Mumbai

ITA 4988/MUM/2008[2004-2005]Status: DisposedITAT Mumbai15 Apr 2024AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…to 2003-04 in ITA Nos. 2416 to 2418/Mds/2007 vide order dated 06-02-2009 the co-ordinate Bench of this Tribunal has held the issue against the assessee by following the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538/ 112 Taxman 46. It was the submission that after the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. (supra) referred to supra, the issue of 'manufacture or production' has undergone substantial debate. It was the submission that the Hon'ble Supreme Court in the case of ITO v. Arihant Tiles & Marbles (P) Ltd. [2010] 32…

ITO - 4(2)(4), Mumbai vs. M/S. M.M. Poonjiaji Spices Ltd., Mumbai

ITA 4987/MUM/2008[2002-2003]Status: DisposedITAT Mumbai15 Apr 2024AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…to 2003-04 in ITA Nos. 2416 to 2418/Mds/2007 vide order dated 06-02-2009 the co-ordinate Bench of this Tribunal has held the issue against the assessee by following the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538/ 112 Taxman 46. It was the submission that after the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. (supra) referred to supra, the issue of 'manufacture or production' has undergone substantial debate. It was the submission that the Hon'ble Supreme Court in the case of ITO v. Arihant Tiles & Marbles (P) Ltd. [2010] 32…

I.T.O-4(2)(4), Mumbai vs. M/S M.M.Poonjiaji Spices Ltd, Mumbai

ITA 2943/MUM/2008[2001-2002]Status: DisposedITAT Mumbai15 Apr 2024AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…to 2003-04 in ITA Nos. 2416 to 2418/Mds/2007 vide order dated 06-02-2009 the co-ordinate Bench of this Tribunal has held the issue against the assessee by following the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538/ 112 Taxman 46. It was the submission that after the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. (supra) referred to supra, the issue of 'manufacture or production' has undergone substantial debate. It was the submission that the Hon'ble Supreme Court in the case of ITO v. Arihant Tiles & Marbles (P) Ltd. [2010] 32…

ITO - 4(2)(2), Mumbai vs. M/S. M.M. Poonjiaji Spices Ltd., Mumbai

ITA 6537/MUM/2006[2003-2004]Status: DisposedITAT Mumbai15 Apr 2024AY 2003-2004

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 10BSection 143Section 144Section 145Section 147Section 9

…to 2003-04 in ITA Nos. 2416 to 2418/Mds/2007 vide order dated 06-02-2009 the co-ordinate Bench of this Tribunal has held the issue against the assessee by following the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538/ 112 Taxman 46. It was the submission that after the decision of the Hon'ble Supreme Court in the case of Indian Hotels Co. Ltd. (supra) referred to supra, the issue of 'manufacture or production' has undergone substantial debate. It was the submission that the Hon'ble Supreme Court in the case of ITO v. Arihant Tiles & Marbles (P) Ltd. [2010] 32…

Commissioner of Income Tax vs. M/S Primal Projects (P) Ltd

In the result, the appeal fails and is hereby

ITA/196/2011HC Karnataka10 Nov 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 260Section 260ASection 80I

…eat. In support of aforesaid submissions, reliance has been placed on decisions of the Supreme Court in 'GOPAL REDDY VS. STATE OF ANDHRA PRADESH JT,', 1996 (6) SC 268, 'P.VARGHESE VS. ITO', (1981) 131 ITR 597 (SC), INDIAN HOTEL CO. LTD. VS. ITO', (2000) 245 ITR 538 (SC). 6. On the other hand, learned counsel for the assessee submitted that the finding of the tribunal that the respondent constructed required number of units is a question of fact and by no stretch of imagination can be said to be perverse. It is also submitted that the finding that the respondent has fulfilled the requirements as…

DCIT (Ltu), New Delhi vs. M/S. Gail (India) Ltd., New Delhi

Appeal is dismissed

ITA 4642/DEL/2013[1996-97]Status: DisposedITAT Delhi26 Oct 2020AY 1996-97

Bench: Sh. R. K. Panda & Ms Suchitra Kamble

Section 80HSection 80I

…1 ITA Nos. 4454 & 4642/Del/2013 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘C’ NEW DELHI BEFORE SH. R. K. PANDA, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A. No. 4454/Del/2013 (A.Y 1996-97) Gail (India) Ltd., Vs DCIT-LTU Delhi 16, Bhikaji Cama Place, Large Tax Payer Unit, New Delhi – 110 066 NBCC Plaza Pushp Vihar, (PAN : AAACG 1209 J) Sector – 3, New Delhi – 110 017 (APPELLANT) (RESPONDENT) And I.T.A. No. 4642/Del/2013 (A.Y 1996-97) DCIT-LTU Delhi Vs Gail (India) Ltd., Large Tax Payer Unit, 16, Bhikaji Cama Place, NBCC Plaza Pushp Vihar, New Delhi – 110 066 Sector – 3, (PAN : A…

Gail (India) Ltd., New Delhi vs. DCIT-Ltu Delhi, New Delhi

Appeal is dismissed

ITA 4454/DEL/2013[1996-97]Status: DisposedITAT Delhi26 Oct 2020AY 1996-97

Bench: Sh. R. K. Panda & Ms Suchitra Kamble

Section 80HSection 80I

…1 ITA Nos. 4454 & 4642/Del/2013 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘C’ NEW DELHI BEFORE SH. R. K. PANDA, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A. No. 4454/Del/2013 (A.Y 1996-97) Gail (India) Ltd., Vs DCIT-LTU Delhi 16, Bhikaji Cama Place, Large Tax Payer Unit, New Delhi – 110 066 NBCC Plaza Pushp Vihar, (PAN : AAACG 1209 J) Sector – 3, New Delhi – 110 017 (APPELLANT) (RESPONDENT) And I.T.A. No. 4642/Del/2013 (A.Y 1996-97) DCIT-LTU Delhi Vs Gail (India) Ltd., Large Tax Payer Unit, 16, Bhikaji Cama Place, NBCC Plaza Pushp Vihar, New Delhi – 110 066 Sector – 3, (PAN : A…

Deputy Commissioner of Income Tax Central Circle-1(3), Bangalore vs. M/S Coffeeday Global Limited, Bangalore

In the result, the appeals of the Revenue are partly allowed

ITA 3041/BANG/2018[2014-15]Status: DisposedITAT Bangalore24 Feb 2020AY 2014-15

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

Section 14ASection 32(1)(iia)Section 43A

…ore us. The Ld. DR relied on the order of the Assessing Officer. 6.2 The Ld. AR submitted that the Assessing Officer had disallowed additional depreciation solely relying on the decision of Supreme Court in the case of M/s.Indian Hotels Co., Ltd V. ITO (2000) 112 Taxmann 46 (SC). The Ld. AR submitted that the decision of Supreme Court was in the context of deductions under the provisions of section 80J/32A of the Act and has no relevance to the provisions of section 32(1)(iia) of the Act. It was also the claim of the Ld. AR that I.T.A. Nos.3040 & 3041/Bang/2018 the time of the decision of the Supreme Court in the…

Deputy Commissioner of Income Tax Central Circle-1(3), Bangalore vs. M/S Coffeeday Global Limited, Bangalore

In the result, the appeals of the Revenue are partly allowed

ITA 3040/BANG/2018[2013-14]Status: DisposedITAT Bangalore24 Feb 2020AY 2013-14

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

Section 14ASection 32(1)(iia)Section 43A

…ore us. The Ld. DR relied on the order of the Assessing Officer. 6.2 The Ld. AR submitted that the Assessing Officer had disallowed additional depreciation solely relying on the decision of Supreme Court in the case of M/s.Indian Hotels Co., Ltd V. ITO (2000) 112 Taxmann 46 (SC). The Ld. AR submitted that the decision of Supreme Court was in the context of deductions under the provisions of section 80J/32A of the Act and has no relevance to the provisions of section 32(1)(iia) of the Act. It was also the claim of the Ld. AR that I.T.A. Nos.3040 & 3041/Bang/2018 the time of the decision of the Supreme Court in the…

ITO 33 (3) (4), Mumbai vs. Sudarshan R. Kharbanda, Mumbai

The appeal of the Revenue is dismissed

ITA 2160/MUM/2016[2011-12]Status: DisposedITAT Mumbai19 Sept 2018AY 2011-12

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Year: 2011-12 Income Tax Officer-33(3)(4), Shri Sudarshan R. C-12, R. No.604, बनाम/ Kharbanda, Prop. Time Link, Pratyakshakar Bhavan, 17/301, Evershine Vs. Bandra Kurla Complex, Millennium Paradise, Thakur Bandra (East), Village, Kandivali (Eat), Mumbai-400051 Mumbai-400101 (याजस्व /Revenue) (यनधाारयती /Assessee) P.A. No.Ahdpk9148D

Section 80I

…Pharma (I.)(P) Ltd. (2011) 10 taxman.com 261 (Del.) held that converting raw fish into tinned fish does not amount to manufacturing. j) Likewise preparation of food stuffs/food packet by hotel does not amount to manufacture in India Hotels Company Ltd. vs ITO 245 ITR 538 (SC). k) Likewise conversion of Chicory Roots into Chicory powder was held to be not manufacturing in Sacs Eagles Chicory vs CIT 255 ITR 178 (SC). If the aforementioned judicial pronouncements and the facts available on record are kept in juxtaposition and analyzed with the assembling of parts done by the 40 Sudarshan R. Kharbanda assessee, we f…

The J.K. Trust Bombay, Mumbai vs. CIT (E), Mumbai

The appeal of the assessee is allowed

ITA 3769/MUM/2017[2012-13]Status: DisposedITAT Mumbai25 Jul 2018AY 2012-13

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2012-13 M/S The J. K. Trust Cit (Exemption) Bombay, R. No.617, 6Th Floor, बनाम/ New Hind House, Piramal Chambers, Vs. Narottam Morrjee Marg, Lalbaug, Ballard Estate, Mumbai-400012 Mumbai-400001

Section 11Section 263

…ely not different from the retreading of an old tyre and that the law laid down in that case would apply to the facts of this case as well. 5. Attention was also invited to the observations of the Apex Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538 wherein the Court observed, inter alia, thus : "...The word 'manufacture' has various shades of meaning but unless defined under the Act it is to be interpreted in the context of the object and the language used in the sections. In the context of the provisions which deal with grant of investment allowance or deduction under section 80J it is app…

Maharashtra Airport Development, Mumbai vs. Pr CIT 3, Mumbai

The appeal of the assessee is allowed

ITA 3741/MUM/2016[2011-12]Status: DisposedITAT Mumbai18 Jul 2018AY 2011-12

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2011-12 M/S Maharashtra Airport Pr. Cit-3, Development Company 612, 6Th Floor, बनाम/ Ltd. Aayakar Bhavan, Vs. 8Th Floor, World Trade M. K. Road, Centre, Tower No.1, Mumbai-400020 Cuffe Parade, Mumbai-400005 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No. Aadcm9623M

Section 148Section 154Section 263Section 80I

…ely not different from the retreading of an old tyre and that the law laid down in that case would apply to the facts of this case as well. 5. Attention was also invited to the observations of the Apex Court in the case of Indian Hotels Co. Ltd. v. ITO [2000] 245 ITR 538 wherein the Court observed, inter alia, thus : "...The word 'manufacture' has various shades of meaning but unless defined under the Act it is to be interpreted in the context of the object and the language used in the sections. In the context of the provisions which deal with grant of investment allowance or deduction under section 80J it is app…

ITO WD 3(4), Thane vs. Ulhas Gopal Karle, Thane

In the result, the Revenue’s appeal for A

ITA 2033/MUM/2015[2011-12]Status: DisposedITAT Mumbai01 Dec 2016AY 2011-12

Bench: Shri Jason P. Boaz & Shri Sandeep Gosain Income Tax Officer-3(4) Shri Ulhas Gopal Karle 6Th Floor, Ashar It Park 204, Kalika Tower Road No. 16Z, Wagle Vs. Opp. Pratap Cinema Industrial Estate Kolbad Road Thane (W) 400604 Thane (W) 400601 Pan – Afypk0221L Appellant Respondent

For Appellant: Shri Saurabh DeshpandeFor Respondent: Shri Deepak Tikekar
Section 143(1)Section 143(3)Section 80Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL "F" Bench, Mumbai Before Shri Jason P. Boaz, Accountant Member and Shri Sandeep Gosain , Judicial Member Income Tax Officer-3(4) Shri Ulhas Gopal Karle 6th Floor, Ashar IT Park 204, Kalika Tower Road No. 16Z, Wagle Vs. Opp. Pratap Cinema Industrial Estate Kolbad Road Thane (W) 400604 Thane (W) 400601 PAN – AFYPK0221L Appellant Respondent Appellant by: Shri Saurabh Deshpande Respondent by: Shri Deepak Tikekar Date of Hearing: 29.11.2016 Date of Pronouncement: 01.12.2016 O R D E R Per Jason P. Boaz, A.M. This appeal by the Revenue is directed against the order of the CIT(…

Star India Pvt.Ltd., Mumbai vs. Addl.C.I.T.-Range311(1), Mumbai

The appeal of the AO is dismissed

ITA 6332/MUM/2008[2003-2004]Status: DisposedITAT Mumbai20 May 2016AY 2003-2004
For Appellant: S/Shri Porus Kaka & Divesh ChawlaFor Respondent: Shri N.K. Chand-CIT
Section 143(3)Section 254(1)Section 92

…the intendment of providing for higher rate of depreciation. We may refer to several case law to analyse as to which formula would aptly suit the situation in the given case. 20. In Indian Hotels Co. Ltd. & Ors. vs. ITO & Ors. (2000) 162 CTR (SC) 31 : (2000) 245 ITR 538 (SC), the issue was about the granting of deduction under s. 80J to an 19 6385&6332/09-Star India industrial undertaking. It was noticed that s. 80J provides for grant of deduction to an assessee who derives income from an industrial undertaking or a ship or the business of a hotel to which the section applies and the section applies to any ind…

M/S J.D .Marketing Pvt Ltd, Kolkata vs. D.C.I.T Cir - 1, Kolkata.

In the result, all the appeals of revenue as well as assessee are dismissed

ITA 812/KOL/2013[2006-07]Status: DisposedITAT Kolkata10 Feb 2016AY 2006-07

Bench: Shri Mahavir Singh, Jm & Shri Waseem Ahmed, Am]

For Appellant: Shri Barun Kumar Ghosh, FCAFor Respondent: Shri Satyendra Mohan Das, JCIT
Section 143(3)Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH: KOLKATA [Before Shri Mahavir Singh, JM & Shri Waseem Ahmed, AM] I.T.A Nos.700 & 701/Kol/2013 Assessment Years: 2005-06 & 2006-07 Deputy Commissioner of Income-tax, Vs. M/s. J. D. Marketing Pvt. Ltd. Circle-1, Kolkata. (PAN: AABCJ2681E) (Appellant) (Respondent) & I.T.A Nos.811 & 812/Kol/2013 Assessment Year: 2005-06 & 2006-07 M/s. J. D. Marketing Pvt. Ltd. Vs. Deputy Commissioner of Income-tax, Circle-1, Kolkata. (Appellant) (Respondent) Date of hearing: 21.01.2016 Date of pronouncement: 10.02.2016 For the Revenue: Shri Satyendra Mohan Das, JCIT For the Assesse…