ITO v. M. Pirai Choodi

334 ITR 262Supreme Court of India2011#427 most cited

What is ITO v. M. Pirai Choodi authority for?

If an assessee was denied an adequate opportunity of being heard, including the right to cross-examine a witness, the assessment should be set aside and restored for fresh adjudication after affording due opportunity, even if the assessee failed to appear at an appellate stage. The Tribunal, in the interest of justice, should ensure such matters are re-adjudicated.

211

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also referred to as

ITO v. M. Pirai Choodi · natural justice · opportunity of being heard · right to cross-examine witness · assessment restoration · fresh adjudication · Tribunal powers · Section 143(3) · Section 147 · Section 133(6) · Supreme Court

Also reported as

20 Taxmann.com 733

Sections most often in play

Section 147Section 143(3)Section 133(6)Section 37(1)Section 132(4)Section 69ASection 153ASection 68

Issues it is cited on

survey under section 133astatement under section 132(4)violation of natural justicesection 158share application moneysearch assessmentservice of noticeaccommodation entrysection 133section 133aincome-tax officersection 133(6)

Judgments citing ITO v. M. Pirai Choodi

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…lakhs to the income of the Assessee was not justified. Question (B) is answered in the affirmative, i.e., in favour of the Assessee and against the Revenue. 18. Mr. Singh has placed reliance on the decision of the Supreme Court in ITO v. M Pirai Choodi (2011) 334 ITR 262(SC) to urge that denial of an opportunity to cross-examine by itself could not vitiate the assessment proceedings particularly when the Assessee had not raised a demand to that effect before the AO. He submitted that in the present case, it was recorded by the AO himself that despite sufficient opportunities, the Assessee did not cooperate. It wa…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7841/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…lakhs to the income of the Assessee was not justified. Question (B) is answered in the affirmative, i.e., in favour of the Assessee and against the Revenue. 18. Mr. Singh has placed reliance on the decision of the Supreme Court in ITO v. M Pirai Choodi (2011) 334 ITR 262(SC) to urge that denial of an opportunity to cross-examine by itself could not vitiate the assessment proceedings particularly when the Assessee had not raised a demand to that effect before the AO. He submitted that in the present case, it was recorded by the AO himself that despite sufficient opportunities, the Assessee did not cooperate. It wa…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…lakhs to the income of the Assessee was not justified. Question (B) is answered in the affirmative, i.e., in favour of the Assessee and against the Revenue. 18. Mr. Singh has placed reliance on the decision of the Supreme Court in ITO v. M Pirai Choodi (2011) 334 ITR 262(SC) to urge that denial of an opportunity to cross-examine by itself could not vitiate the assessment proceedings particularly when the Assessee had not raised a demand to that effect before the AO. He submitted that in the present case, it was recorded by the AO himself that despite sufficient opportunities, the Assessee did not cooperate. It wa…

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7838/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…lakhs to the income of the Assessee was not justified. Question (B) is answered in the affirmative, i.e., in favour of the Assessee and against the Revenue. 18. Mr. Singh has placed reliance on the decision of the Supreme Court in ITO v. M Pirai Choodi (2011) 334 ITR 262(SC) to urge that denial of an opportunity to cross-examine by itself could not vitiate the assessment proceedings particularly when the Assessee had not raised a demand to that effect before the AO. He submitted that in the present case, it was recorded by the AO himself that despite sufficient opportunities, the Assessee did not cooperate. It wa…

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE -05 , DELHI

ITA 5521/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

…lakhs to the income of the Assessee was not justified. Question (B) is answered in the affirmative, i.e., in favour of the Assessee and against the Revenue. 18. Mr. Singh has placed reliance on the decision of the Supreme Court in ITO v. M Pirai Choodi (2011) 334 ITR 262(SC) to urge that denial of an opportunity to cross-examine by itself could not vitiate the assessment proceedings particularly when the Assessee had not raised a demand to that effect before the AO. He submitted that in the present case, it was recorded by the AO himself that despite sufficient opportunities, the Assessee did not cooperate. It wa…

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5520/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…lakhs to the income of the Assessee was not justified. Question (B) is answered in the affirmative, i.e., in favour of the Assessee and against the Revenue. 18. Mr. Singh has placed reliance on the decision of the Supreme Court in ITO v. M Pirai Choodi (2011) 334 ITR 262(SC) to urge that denial of an opportunity to cross-examine by itself could not vitiate the assessment proceedings particularly when the Assessee had not raised a demand to that effect before the AO. He submitted that in the present case, it was recorded by the AO himself that despite sufficient opportunities, the Assessee did not cooperate. It wa…

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5517/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…lakhs to the income of the Assessee was not justified. Question (B) is answered in the affirmative, i.e., in favour of the Assessee and against the Revenue. 18. Mr. Singh has placed reliance on the decision of the Supreme Court in ITO v. M Pirai Choodi (2011) 334 ITR 262(SC) to urge that denial of an opportunity to cross-examine by itself could not vitiate the assessment proceedings particularly when the Assessee had not raised a demand to that effect before the AO. He submitted that in the present case, it was recorded by the AO himself that despite sufficient opportunities, the Assessee did not cooperate. It wa…

VESTIGE MARKETING PVT LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

ITA 5516/DEL/2025[2019-20]Status: DisposedITAT Delhi20 Mar 2026AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…lakhs to the income of the Assessee was not justified. Question (B) is answered in the affirmative, i.e., in favour of the Assessee and against the Revenue. 18. Mr. Singh has placed reliance on the decision of the Supreme Court in ITO v. M Pirai Choodi (2011) 334 ITR 262(SC) to urge that denial of an opportunity to cross-examine by itself could not vitiate the assessment proceedings particularly when the Assessee had not raised a demand to that effect before the AO. He submitted that in the present case, it was recorded by the AO himself that despite sufficient opportunities, the Assessee did not cooperate. It wa…

VESTIGE MARKETING PVT. LTD.,DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

ITA 5515/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

…lakhs to the income of the Assessee was not justified. Question (B) is answered in the affirmative, i.e., in favour of the Assessee and against the Revenue. 18. Mr. Singh has placed reliance on the decision of the Supreme Court in ITO v. M Pirai Choodi (2011) 334 ITR 262(SC) to urge that denial of an opportunity to cross-examine by itself could not vitiate the assessment proceedings particularly when the Assessee had not raised a demand to that effect before the AO. He submitted that in the present case, it was recorded by the AO himself that despite sufficient opportunities, the Assessee did not cooperate. It wa…

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

ITA 902/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh15 Dec 2025AY 2020-21
Section 10(3)Section 153ASection 245D(4)

…n 292B of the\nIncome-tax Act would not protect such an order as Section 292B of the Income-\ntax Act cannot be read to confer jurisdiction on the Assessing Officer, where\nnone exists. The Supreme Court decision in the case of ITO v. M. Pirai\nChoodi; [2011] 334 ITR 262 (SC) referred to in the Revenue's reply is also not\napplicable to the issue at hand as that was a case where the assessee was not\ngiven an opportunity to cross-examine the concerned witness and which\nassessee also had a statutory appellate remedy which the assessee had failed to\navail of, whereas there is no such right available to the Petiti…

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

ITA 901/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh15 Dec 2025AY 2019-20
Section 10(3)Section 153ASection 245D(4)

…n 292B of the\nIncome-tax Act would not protect such an order as Section 292B of the Income-\ntax Act cannot be read to confer jurisdiction on the Assessing Officer, where\nnone exists. The Supreme Court decision in the case of ITO v. M. Pirai\nChoodi; [2011] 334 ITR 262 (SC) referred to in the Revenue's reply is also not\napplicable to the issue at hand as that was a case where the assessee was not\ngiven an opportunity to cross-examine the concerned witness and which\nassessee also had a statutory appellate remedy which the assessee had failed to\navail of, whereas there is no such right available to the Petiti…

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

ITA 900/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh15 Dec 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

…ction 292B of the Income-tax Act would not protect such an order as Section 292B of the Income- tax Act cannot be read to confer jurisdiction on the Assessing Officer, where none exists. The Supreme Court decision in the case of ITO v. M. Pirai Choodi; [2011] 334 ITR 262 (SC) referred to in the Revenue's reply is also not applicable to the issue at hand as that was a case where the assessee was not given an opportunity to cross-examine the concerned witness and which assessee also had a statutory appellate remedy which the assessee had failed to avail of, whereas there is no such right available to the Petitioner…

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

ITA 899/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh15 Dec 2025AY 2016-17
For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

…n 292B of the\nIncome-tax Act would not protect such an order as Section 292B of the Income-\ntax Act cannot be read to confer jurisdiction on the Assessing Officer, where\nnone exists. The Supreme Court decision in the case of ITO v. M. Pirai\nChoodi; [2011] 334 ITR 262 (SC) referred to in the Revenue's reply is also not\napplicable to the issue at hand as that was a case where the assessee was not\ngiven an opportunity to cross-examine the concerned witness and which\nassessee also had a statutory appellate remedy which the assessee had failed to\navail of, whereas there is no such right available to the Petiti…

SAVLI TALUKA SECONDARY AND HIGHER SECONDARY EMPLOYEES CO OP. CREDIT SOCIETY LIMITED,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(2), VADODARA

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

ITA 1772/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2019-20

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1772/Ahd/2024 िनधा"रण वष" /Assessment Year : 2019-20 Savli Taluka Secondary & The Income Tax Officer बनाम/ Higher Secondary Employees Ward-1(2)(2) V/S. Co-Op. Credit Society Ltd. Vadodara – 390 007 18, Rayakaka Park Savli Desar Road Vadodara – 391 770. "थायी लेखा सं./Pan: Aafas 6647 D (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Sanket Bakshi, Ar Revenue By : Shri Abhijit Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/08/2025 घोषणा की तारीख /Date Of Pronouncement: 04/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm:

For Appellant: Shri Sanket Bakshi, ARFor Respondent: Shri Abhijit Sr.DR
Section 144BSection 147Section 148Section 148ASection 234ASection 234BSection 234CSection 250Section 272(1)(d)Section 68

…providing the assessee an adequate opportunity of being heard, the proper course would be to set aside the assessment and direct the Assessing Officer to pass a fresh order after affording a reasonable opportunity. Similarly, in ITO v. M. Pirai Choodi [(2011) 334 ITR 262 (SC)], it was held that even if the assessee fails to appear before the CIT(A), the Tribunal should, in the interest of justice, restore the matter to the CIT(A) or the AO for fresh adjudication after due opportunity. Respectfully following the ratio laid down in the above judicial precedents and considering the totality of the facts, we are of t…

DCIT,CC-2(2), KOLKATA, KOLKATA vs. SPML INFRA LTD, NEW DELHI

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

ITA 440/KOL/2025[2016-17]Status: DisposedITAT Kolkata11 Sept 2025AY 2016-17

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 13Section 143(2)Section 143(3)Section 2(24)(x)Section 250Section 36(1)(iv)Section 36(1)(va)Section 43Section 80Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘D’ BENCH, KOLKATA Before SHRI GEORGE MATHAN, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER I.T.A. No.: 440/KOL/2025 Assessment Year: 2016-17 DCIT, CC-2(2), Kolkata SPML Infra Ltd. Vs. (Appellant) (Respondent) PAN: AADCS2469K Appearances: Department represented by : Sanjay Mukherjee, CIT-DR. Assessee represented by : Debarghya Banerjee. AR. Date of concluding the hearing : 10-July-2025 Date of pronouncing the order : 11-September-2025 ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: This appeal filed by the Revenue is against the order of the Commissioner of Incom…

COMPAREX INDIA P.LTD,NEW DELHI vs. ITO, CIRCLE-4(2), NEW DELHI

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

ITA 2151/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Ajit Jain, ARFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(2)Section 143(3)Section 144C(10)Section 144C(13)Section 144C(8)Section 92CSection 92C(3)

…upreme Court in the case of Sugandhi vs. P. Rajkumar in Civil Appeal No.3427 of 2020 dated October 13, 2020. Further, he submitted that with regard to failure on granting cross-examination, Hon’ble Supreme Court in 9 the case of ITO vs. M. Pirai Choodi (2011) 334 ITR 262 (SC) rejected the view of Hon’ble High Court for quashing of assessment proceedings and they observed that the High Court should not have quashed the assessment proceedings. Further, he submitted that on the issue of the Assessing Officer failed to refer the case of international transaction to TPO. Hon’ble Supreme Court has remitted the issue ba…

LATE SHARMISHTA MAFATLAL MEHTA,MUMBAI vs. COMMISSIONR OF INCOME TAX (A), NFAC , DELHI, MUMBAI

ITA 4219/MUM/2023[2010-11]Status: DisposedITAT Mumbai27 Aug 2024AY 2010-11

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Hemant MehtaFor Respondent: Shri Avinash Baburao Karpe
Section 133(6)Section 142(1)Section 143(3)Section 254Section 27(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL "G" BENCH, MUMBAI SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER Hemant Maftlal Mehta (Legal Heir of Late Sharmista Maftlal Mehta) A-13, Yashwant Building, 90 Feet Road, Ghatkopar East, Mumbai - 400077 [PAN: AFAPM1923P] …………. Appellant Income Tax Officer, Vs Ward 27(3)(1), Mumbai Aaykar Bhavan, Vashi Railway Station, Navi Mumbai – 400 073 …………. Respondent Appearance For the Appellant/Assessee : Shri Hemant Mehta For the Respondent/Department : Shri Avinash Baburao Karpe Date Conclusion of hearing : 19.06.2024 Pronouncement of order : 27.08.…

PR. COMMISSIONER OF INCOME TAX vs. ARUN MALHOTRA

ITA/118/2020HC Delhi03 Jul 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

Section 158Section 158BSection 40A(3)

…igned By:KAMLESH KUMAR Signing Date:10.07.2024 16:34:10 Signature Not Verified ITA 118/2020 Page 5 of 12 Court with an order of remand in the decision reported as Income Tax Officer vs. M. Pirari Chrodi (2011) 334 ITR 262 (SC) with a direction that the High court was not correct in taking the view and an order of remand was passed for cross examination. Even if we ignore the statement of Chander Prakash Sachdeva, the appellant's contention is that there was sufficient evidence or material to show that transactions were not genuine. Further in case statements…

NEENA KAILAS JADHAV,THANE vs. ACIT CIRCLE 1, AURANGABAD

In the result, the appeal filed by the assessee stands

ITA 901/PUN/2023[2012-13]Status: DisposedITAT Pune19 Apr 2024AY 2012-13

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.901/Pun/2023 "नधा"रण वष" / Assessment Year : 2012-13

For Appellant: NoneFor Respondent: Shri Arvind Desai
Section 10(3)Section 10(38)Section 143(3)Section 68

…holding so, he relied on the following judgments : 1. Arun Kumar J, Muchhala (2017) 85 taxmann.com 306 (Bom) – Ho’ble Bombay High Court 2. Marg Projects and Infrastructure Ltd. (2023) 147 taxmann.com 130 (Madras)/448 ITR 649 3. ITO Vs. M/s. Pirai Choodi (SC) 334 ITR 262 9. In a case involving identical facts of the case, the Hon’ble Calcutta High Court after making reference to the decisions of Hon’ble Madras High Court in the case of CIT vs. Manish D. Jain, 5 120 taxmann.com 180 (Mad.) and PCIT vs. Prabha Jain, 439 ITR 304 (Mad.) had confirmed the action of the Assessing Officer by holding that the Assessin…

MRS. HEMA RAMNATH,KOCHI vs. DCIT, ERNAKULAM

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 118/COCH/2021[2010-11]Status: DisposedITAT Cochin15 Mar 2024AY 2010-11

Bench: Shri Sanjay Arora & Dr. Seethalakshmihema Ramnath Dy. Cit, Corporate Circle 1(1) 35/2968, Laxmi Villa Ernakulam 682018 Church Road, Palarivattom Vs. Kochi - 682025 [Pan:Aavpr8682G] (Appellant) (Respondent)

For Appellant: Shri R. Krishnan, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 139Section 143(3)Section 45Section 54FSection 54F(1)

…portunity toward this being allowed by the ld. CIT(A). This is clearly an irregularity, and the matter shall necessarily have to travel to the stage where the 3 | P a g e Hema Ramnath v. Dy. CIT irregularity had intervened (viz. ITO v. M. Pirai Choodi [2011] 334 ITR 262 (SC); Guduthur Bros. v. ITO [1960] 40 ITR 298 (SC)). The matter, accordingly, goes back to the file of the ld. CIT(A) for the purpose. In fact, we also observe that both, i.e., the finding by the AO and that by the ld. CIT(A), modifying the former, are without statement of any reason/s informing the same and, thus, not sustainable on that ground…

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ITO v. M. Pirai Choodi (334 ITR 262) — Cited in 211 Judgments | BharatTax