Jagdamba Trading Co. v. ITO

16 SOT 66Income Tax Appellate Tribunal2007#7601 most cited
15

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2023.

Also reported as

107 TTJ 398

Issues it is cited on

section 147(1)section 147(b)section 147(a)third party informationsection 43canon application of mindsection 40a(2)live linkrejection of books of accountborrowed satisfactionsection 50section 145

Judgments citing Jagdamba Trading Co. v. ITO

DINESH KUMAR JAIN ,MUMBAI vs. ITO, BALOTRA

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

ITA 374/JODH/2019[2011-12]Status: DisposedITAT Jodhpur16 Oct 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.374/Jodh/2019 Assessment Year: 2011-12

Section 143(3)Section 148Section 250

…rties before the AO. It was upon the AO to prove that the documents are not genuine. AO never stated that the documents were bogus. Addition confirmed by the CIT (A) was also deleted and the appeal of assessee was allowed." b) Jagdamba Trading Company vs ITO, 107 TTJ 398, ITAT (Jodhpur) Certain purchases made by the assessee could not be considered as bogus merely on the basis of seller's deposition before the Sales Tax Department that no sales were made during the relevant year, as it was not proved that the amount paid by the assessee through cheque for purchases was returned and deposited in its account and no…

DEPUTY COMMISSIONER OF INCOME TAX 3(2)(2), MUMBAI vs. PHULCHAND EXPORTS PRIVATE LIMITED, MUMBAI

In the result, appeal filed by the revenue and cross objection filed by the assessee are dismissed

ITA 7214/MUM/2017[2008-09]Status: DisposedITAT Mumbai12 May 2022AY 2008-09

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Shankarlal JainFor Respondent: Shri Sandeep Raj
Section 147

…man.com 413 Guj. a statement was recorded during IT search and based on that statement additional tax was Imposed under GST without any independent verification. The High Court of Guj. deleted the addition. The decision in case of Jagdamba Trading Co. vs. ITO 16 SOT 66 (Jodh.)(URO)and in case of Premchand 25 SOT 11 Jodhpur (URO) may also be referred holding that based on proceeding before Sales Tax department ,an assessment of income cannot be based. 2.2 No copy of statement provided. No cross examination provided although requested. High Court of Bombay in RW Promotion Pvt. Ltd. 281 CTR 200 Bombay deleted the ad…

DEPUTY COMMISSIONER OF INCOME TAX 3(2)(2), MUMBAI vs. PHULCHAND EXPORTS PRIVATE LIMITED, MUMBAI

In the result, appeal filed by the revenue and cross objection filed by the assessee are dismissed

ITA 7213/MUM/2017[2011-12]Status: DisposedITAT Mumbai12 May 2022AY 2011-12

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Shankarlal JainFor Respondent: Shri Sandeep Raj
Section 147

…man.com 413 Guj. a statement was recorded during IT search and based on that statement additional tax was Imposed under GST without any independent verification. The High Court of Guj. deleted the addition. The decision in case of Jagdamba Trading Co. vs. ITO 16 SOT 66 (Jodh.)(URO)and in case of Premchand 25 SOT 11 Jodhpur (URO) may also be referred holding that based on proceeding before Sales Tax department ,an assessment of income cannot be based. 2.2 No copy of statement provided. No cross examination provided although requested. High Court of Bombay in RW Promotion Pvt. Ltd. 281 CTR 200 Bombay deleted the ad…

DEPUTY COMMISSIONER OF INCOME TAX 3(2)(2), MUMBAI vs. PHULCHAND EXPORTS PRIVATE LIMITED, MUMBAI

In the result, appeal filed by the revenue and cross objection filed by the assessee are dismissed

ITA 7212/MUM/2017[2010-11]Status: DisposedITAT Mumbai12 May 2022AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Shankarlal JainFor Respondent: Shri Sandeep Raj
Section 147

…man.com 413 Guj. a statement was recorded during IT search and based on that statement additional tax was Imposed under GST without any independent verification. The High Court of Guj. deleted the addition. The decision in case of Jagdamba Trading Co. vs. ITO 16 SOT 66 (Jodh.)(URO)and in case of Premchand 25 SOT 11 Jodhpur (URO) may also be referred holding that based on proceeding before Sales Tax department ,an assessment of income cannot be based. 2.2 No copy of statement provided. No cross examination provided although requested. High Court of Bombay in RW Promotion Pvt. Ltd. 281 CTR 200 Bombay deleted the ad…

M/S ANANTHA REFINERY PVT. LTD. vs. DCIT,

In the result, both the appeals of the assessee are partly allowed

ITA 1554/BANG/2013[2007-08]Status: DisposedITAT Bangalore29 Apr 2022AY 2007-08

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

For Appellant: Shri K.R.Pradeep &For Respondent: Dr.Manjunath Karkihalli, CIT-DR

…ratios] for the AYs 2006-07 & 2007-08 respectively. 6.6. We shall now proceed to analyze the judicial views on the issue, chronologically, as under: (i) Account payee cheques: The ITAT, Jodhpur Bench in the case of Jagdamba Trading Company v. ITO reported in 107 TTJ 398 (Jd) has held that 'In the absence of any proof to show that the amount paid by the assessee through cheque for purchases from a party was returned and deposited in the account of the assessee, said purchases cannot be held to be bogus. ' (ii) In the case of DCIT v. Adinath Industries reported in 252 ITR 476 (Guj), the Hon'ble Gujarat High Court…

M/S ANANTHA REFINERY PVT. LTD. vs. DCIT,

In the result, both the appeals of the assessee are partly allowed

ITA 1553/BANG/2013[2006-07]Status: DisposedITAT Bangalore29 Apr 2022AY 2006-07

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

For Appellant: Shri K.R.Pradeep &For Respondent: Dr.Manjunath Karkihalli, CIT-DR

…ratios] for the AYs 2006-07 & 2007-08 respectively. 6.6. We shall now proceed to analyze the judicial views on the issue, chronologically, as under: (i) Account payee cheques: The ITAT, Jodhpur Bench in the case of Jagdamba Trading Company v. ITO reported in 107 TTJ 398 (Jd) has held that 'In the absence of any proof to show that the amount paid by the assessee through cheque for purchases from a party was returned and deposited in the account of the assessee, said purchases cannot be held to be bogus. ' (ii) In the case of DCIT v. Adinath Industries reported in 252 ITR 476 (Guj), the Hon'ble Gujarat High Court…

ITO, WARD 2(5), KALYAN vs. M/S BHARAT FOOD PRODUCTS, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 2765/MUM/2019[2009-10]Status: DisposedITAT Mumbai13 Nov 2020AY 2009-10

Bench: Shri C.N. Prasad, Hon'Bleincome Tax Officer - 2(5) V. M/S. Bharat Food Products 2Nd Floor, Mohan Plaza Bldg., Plot No. 02, Waco Compound Wayle Nagar, Khadakpada Industrial Area Kalyan (W), Kalyan Ulhasnagar - 421004 Mumbai - 421301 Pan: Aabfb1403H (Appellant) (Respondent) None Assessee By : Department By Amrita Singh

For Appellant: Department by Amrita Singh
Section 143(1)Section 147

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “SMC”, MUMBAI BEFORE SHRI C.N. PRASAD, HON'BLE JUDICIAL MEMBER Income Tax Officer - 2(5) v. M/s. Bharat Food Products 2nd Floor, Mohan Plaza Bldg., Plot No. 02, Waco Compound Wayle Nagar, Khadakpada Industrial Area Kalyan (W), Kalyan Ulhasnagar - 421004 Mumbai - 421301 PAN: AABFB1403H (Appellant) (Respondent) None Assessee by : Department by Amrita Singh Date of Hearing : 21.10.2020 Date of Pronouncement : 13.11.2020 O R D E R PER C.N. PRASAD (JM) 1. This appeal is filed by the revenue against the order of the Learned Commissioner of Income Tax (Appeals) – 3, Mu…

SHANTILAL B. PAREKH,MUMBAI vs. INCOME TAX OFFICER-3(4), KALYAN

In the result, appeal of the assessee in ITA No

ITA 4262/MUM/2017[2010-11]Status: DisposedITAT Mumbai04 Feb 2019AY 2010-11

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.4261 & 4262/Mum/2017 (नििाारण वर्ा / Assessment Year : 2009-10 & 2010-11) बिाम/ Shri Shantilal B. Parekh Ito-3(4), Flat No. 24, 6Th Floor, 2Nd Floor, Rani Mansion, Gaurav Apt. , Murbad Road, V. Sarvoday Nagar, Kalyan(W)- 421301 Nahur Village Road, Mulund (W), Mumbai-400080 स्थायी ऱेखा सं./ Pan: Akcpp9255C Assessee By: Mr. Divendra H. Jain Revenue By : Shri. S.K Jain सुनवाई की तारीख /Date Of Hearing : 06.11.2018 घोषणा की तारीख /Date Of Pronouncement : 04.02.2019 आदेश / O R D E R Per Ramit Kochar: These Are Two Appeals, Filed By Assessee, Being Ita No. 4261 & 4262/Mum/2017 For Ay 2009-10 & 2010-11 Respectively , Are Directed Against Common Appellate Order Dated 29.03.2017 Passed By Learned Commissioner Of Income Tax (Appeals)-1, Thane (Hereinafter Called “The Cit(A)”) In Appeal No. 222 & 223/15-16, For Assessment Year’S 2009-10 & 2010-11 Respectively, The Appellate Proceedings Had Arisen Before Learned Cit(A) From Separate Assessment Order(S) Both Dated 19.01.2015 Passed By Learned Assessing Officer (Hereinafter Called “The Ao”) U/S 144 R.W.S. 147 Of The Income-Tax Act, 1961 (Hereinafter Called “The Act”) For Ay 2009-10 & 2010-11 Respectively. Since Both These Appeals Raises Similar Issues & Common Grounds

For Appellant: Mr. Divendra H. JainFor Respondent: Shri. S.K Jain
Section 144Section 148Section 44A

…is regard on the following decisions ; i) Babulal C. Borana v. Third ITO (2006) 282ITR 251 (Bom) . ii) CIT v. M.K. Brothers (1987) 163 ITR 249 (Guj) ii) HI Lux Automotive (P.) Ltd v. ITO (2007) 163 Taxman 90 (Delhi)(Mag) v) Jagdamba Trading Co. v. ITO (2007) 16 SOT 66 (Jodh) v) ITO v. Permanand (2008) 25 SOT 11 (Jodh) (URO) 1.4 Further the Assessing Officer relying upon information received from Sales-tax department and affidavit alleged to be submitted by these parties before sales tax authorities. The learned Assessing Officer has not provided us opportunity to cross examine the witnesses and documents relied…

SHANTILAL B PAREKH,MUMBAI vs. INCOME TAX OFFICER- 3(4), MUMBAI

In the result, appeal of the assessee in ITA No

ITA 4261/MUM/2017[2009-10]Status: DisposedITAT Mumbai04 Feb 2019AY 2009-10

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.4261 & 4262/Mum/2017 (नििाारण वर्ा / Assessment Year : 2009-10 & 2010-11) बिाम/ Shri Shantilal B. Parekh Ito-3(4), Flat No. 24, 6Th Floor, 2Nd Floor, Rani Mansion, Gaurav Apt. , Murbad Road, V. Sarvoday Nagar, Kalyan(W)- 421301 Nahur Village Road, Mulund (W), Mumbai-400080 स्थायी ऱेखा सं./ Pan: Akcpp9255C Assessee By: Mr. Divendra H. Jain Revenue By : Shri. S.K Jain सुनवाई की तारीख /Date Of Hearing : 06.11.2018 घोषणा की तारीख /Date Of Pronouncement : 04.02.2019 आदेश / O R D E R Per Ramit Kochar: These Are Two Appeals, Filed By Assessee, Being Ita No. 4261 & 4262/Mum/2017 For Ay 2009-10 & 2010-11 Respectively , Are Directed Against Common Appellate Order Dated 29.03.2017 Passed By Learned Commissioner Of Income Tax (Appeals)-1, Thane (Hereinafter Called “The Cit(A)”) In Appeal No. 222 & 223/15-16, For Assessment Year’S 2009-10 & 2010-11 Respectively, The Appellate Proceedings Had Arisen Before Learned Cit(A) From Separate Assessment Order(S) Both Dated 19.01.2015 Passed By Learned Assessing Officer (Hereinafter Called “The Ao”) U/S 144 R.W.S. 147 Of The Income-Tax Act, 1961 (Hereinafter Called “The Act”) For Ay 2009-10 & 2010-11 Respectively. Since Both These Appeals Raises Similar Issues & Common Grounds

For Appellant: Mr. Divendra H. JainFor Respondent: Shri. S.K Jain
Section 144Section 148Section 44A

…is regard on the following decisions ; i) Babulal C. Borana v. Third ITO (2006) 282ITR 251 (Bom) . ii) CIT v. M.K. Brothers (1987) 163 ITR 249 (Guj) ii) HI Lux Automotive (P.) Ltd v. ITO (2007) 163 Taxman 90 (Delhi)(Mag) v) Jagdamba Trading Co. v. ITO (2007) 16 SOT 66 (Jodh) v) ITO v. Permanand (2008) 25 SOT 11 (Jodh) (URO) 1.4 Further the Assessing Officer relying upon information received from Sales-tax department and affidavit alleged to be submitted by these parties before sales tax authorities. The learned Assessing Officer has not provided us opportunity to cross examine the witnesses and documents relied…

MUSADDILALS JEWELLERS (INDIA) PRIVATE LIMITED.,HYDERABAD. vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2)., HYDERABAD

In the result, appeal of the assessee is allowed

ITA 1499/HYD/2017[2012-13]Status: DisposedITAT Hyderabad11 Jul 2018AY 2012-13

Bench: Smt P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2012-13 Musaddilals Jewellers (India) Vs. Asst. Commissioner Of Pvt. Ltd., Hyderabad. Income-Tax, Circle – 16(2), Hyderabad. Pan – Aafcm 4841 H

For Appellant: Shri K.C. DevdasFor Respondent: Smt. B.K. Vishnu Priya
Section 131Section 132Section 143(1)

…er personally and the statements were recorded after two years. In this process, he relied on the following case law: 1. ACIT Vs. M/s Larsco Entertainment Pvt. Ltd., 249/Hyd/2014 2. ITO Vs. Premanand, 25 SOT 11 ( ITAT, Jodh.) 3. Jagadamba Trading Co. Vs. ITO, 16 SOT 66 (Jodh.) 4. Multitex Filtration Engineers (P) Ltd. Vs. DCIT, 13 SOT 208 (Del.) 5. CIT Vs. Nikunj Eximp Enterprises (P) Ltd., 372 ITR 619 6. Mohanlal R. Daga Vs. ITO, 147 Taxman 28 7. CIT Vs. Bholanath Poly Fab Pvt. Ltd., 355 ITR 290 (Guj) 8. Prakash Chand Natha Vs. CIT, 301 ITR 134 (MP) 9. CIT Vs. MK Brothers, 163 ITR 249 (Guj.) 10. CIT Vs. Sunrise…

DCIT 25(3), MUMBAI vs. ARIHANT ENTERPRISES, MUMBAI

Appeal stand partly allowed

ITA 5899/MUM/2013[2010-11]Status: DisposedITAT Mumbai11 Jul 2018AY 2010-11

Bench: Shri C.N. Prasad, Jm & Shri Manoj Kumar Aggarwal, Am आयकर अपील सं./I.T.A. No.5899/Mum/2013 (िनधा"रणवष" / Assessment Year: 2010-11) Assistant Commissioner Of Income Tax-25(3) Arihant Enterprises Room No. 308, C-11 C-6, Hasmukh Chs Ltd. बनाम/ Bandra Kurla Complex, Bandra(E) Near Mandapeshwar Industrial Estate Vs. Mumbai – 400 051 Mcf, Uday Marg, Borivali(W) Mumbai – 400 092 "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aahfa-0915-F (अपीलाथ"/Appellant) (""थ" / Respondent) : & Co. No.272/Mum/2014 (िनधा"रणवष" / Assessment Year: 2010-11) Arihant Enterprises Assistant Commissioner Of Income Tax-25(3) C-6, Hasmukh Chs Ltd. Room No. 308, C-11 बनाम/ Near Mandapeshwar Industrial Estate Bandra Kurla Complex, Bandra(E) Vs. Mcf, Uday Marg, Borivali(W) Mumbai – 400 051 Mumbai – 400 092 "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aahfa-0915-F (अपीलाथ"/Appellant) (""थ" / Respondent) :

For Appellant: Hitesh P.Shah, Ld. ARFor Respondent: Rajesh Kumar Yadav, Ld. DR
Section 133(6)Section 143(3)

…of raw material and job work charges incurred, manufacture could not have been possible, addition was not justified and was required to be deleted. The case of the appellant is also supported by the judgment in the case of Jagdamba Trading Co. vs. ITO (2007) 107 TTJ 398 (Jodhpur) wherein it was held that since there is no evidence of the assessee receiving any money back, the purchase in question could not be held to be bogus. In the case of ITO vs. parmanand (2008) 25 SOT 11 (Jodhpur) it has been very categorically held that where the AO has made addition merely on the basis of observations made by the Sales Ta…

DCIT - 9(1)(1), MUMBAI vs. AIRPAC FILTERS & SYSTEMS PVT. LTD., MUMBAI

In the result, cross appeals filed by the revenue and the assessee for assessment years 2009-10 and appeal filed by the assessee for the assessment year 2010-11 are dismissed

ITA 6049/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Nov 2017AY 2009-10

Bench: Shri R.C. Sharma (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2009-10 The Dcit – 9(1)(1), M/S Airpac Filters & Systems - Room No. 260A, 2Nd Floor, Pvt. Ltd., Aayakar Bhavan, M.K. Road, 21, Papa Industrial Estate, Mumbai - 400020 Vs. 40, Suren Road, Andheri (East), Mumbai - 400093

For Appellant: Shri Jitendra Singh (AR)For Respondent: Shri V. Justin (DR)
Section 143(2)Section 143(3)Section 147Section 148Section 271

…CIT Vs. Orissa Corporation Pvt. Ltd. 159 ITR 78 (SC) Hon’ble Bombai High Court in CIT Vs. Nikunj Eximp Enterprises Pvt. Ltd. 372 ITR 619 (Bom) and CIT Vs. U M Shah 90 ITR 396 (Bomb.) and Jodhpur Bench of the Tribunal in Jagdamba Trading Company Vs. ITO (2007) 16 SOT 66 Jodhpur, the assessee has contended before the authorities below that for every sale there has to be corresponding purchases. If sales bills are being accepted then the total purchases amount should be accepted. 10. The Hon’ble Bombay High Court In CIT Vs. Nikunj Eximp Enterprises Pvt. Ltd. 372 ITR 619 (Bom), while upholding the decision of Mumbai…

DCIT 13(3)(1), MUMBAI vs. RIZVI LAND DEVELOPMENTS P.LTD, MUMBAI

In the result, appeal filed by the revenue for assessment year 2009-10 is partly allowed for statistical purposes and cross objection filed by the assessee is dismissed

ITA 5840/MUM/2015[2009-10]Status: DisposedITAT Mumbai23 Oct 2017AY 2009-10

Bench: Shri P.K. Bansal (Vp) & Shri Ram Lal Negi (Jm) Assessment Year: 2009-10 The Dcit-13(3)(1), M/S Rizvi Land Developments Pvt. Room No. 229, 2Nd Floor, Ltd., Aayakar Bhavan, M.K. Road, Rizvi House, Hill Road, Mumbai - 400020 Vs. Bandra (West), Mumbai - 400050 Pan: Aaacr4166P (Appellant) (Respondent) Co No. 177/Mum/2017 Assessment Year: 2009-10 M/S Rizvi Land Developments The Dcit-13(3)(1), Pvt. Ltd., Room No. 229, 2Nd Floor, Rizvi House (1St Floor), Aayakar Bhavan, M.K. Road, Hill Road, Bandra (West), Vs. Mumbai - 400020 Mumbai - 400050 Pan: Aaacr4166P (Appellant) (Respondent) Revenue By : Shri Purushottam Kumar (Sr. Dr) Assessee By : Shri M. Subramanian (Ar) Date Of Hearing: 09/10/2017 Date Of Pronouncement: 23/10/2017

For Appellant: Shri M. Subramanian (AR)For Respondent: Shri Purushottam Kumar (Sr. DR)
Section 133Section 143Section 147

…CIT Vs. Orissa Corporation Pvt. Ltd. 159 ITR 78 (SC) Hon’ble Bombay High Court in CIT Vs. Nikunj Eximp Enterprises Pvt. Ltd. 372 ITR 619 (Bom) and CIT Vs. U M Shah 90 ITR 396 (Bomb.) and Jodhpur Bench of the Tribunal in Jagdamba Trading Company Vs. ITO (2007) 16 SOT 66 Jodhpur, the assessee submitted that as per the ratio laid down in the aforesaid cases, if sales bills are accepted then the total purchases amount should be accepted as for every sale there has to be corresponding purchases. 8. We have heard the rival submissions and perused the entire record and also gone through the cases relied upon by the par…

INNOVATORS FACADE SYSTEMS P.LTD,THANE vs. ACIT CIR 2, THANE

In the result, appeals of assessee are allowed in part

ITA 5450/MUM/2015[2009-10]Status: DisposedITAT Mumbai20 Jul 2016AY 2009-10

Bench: Shri R.C.Sharma, Am & Shri Amarjit Singh, Jm

For Appellant: Shri Naresh Jain, A.RFor Respondent: Shri Pavan Kumar Beerla, DR
Section 133ASection 139(1)Section 143(3)Section 147Section 148

…fect that after 1970 they entered only hawala transactions- Opportunity for cross examination of M not made available to assessee either by sales-tax or by Income-tax authorities-Additions under s. 69 and 69A not justified. • Jagdamba Trading Company vs. ITO 107 TTJ 398 [Jodhpur ITAT] Income from undisclosed sources-Addition-Alleged bogus purchases-There is no proof on record that the amount of Rs.2,20,000 paid by assessee by cheque was deposited in the account of the assessee-Asstt. manager of the bank has categorically confirmed that the recipient of cash was one R and not RP, proprietor of the assessee conce…

ITO, NEW DELHI vs. SH. KAUSHALENDRA AGARWAL, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 2749/DEL/2012[2007-08]Status: DisposedITAT Delhi04 Dec 2015AY 2007-08

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

For Appellant: Ms Richa Rastogi, Sr. DRFor Respondent: Shri Rajeev Saxena, Adv
Section 143(1)Section 143(2)

…ITA No.2749/Del./2012 The ld. AR further submitted that the disallowance made by the AO of outstanding credit balances in respect of purchase is wholly un-sustainable. Reliance is placed on the following judgments : (i). Jagdamba Trading Co. vs. ITO, (2007) 16 SOT 66 (Jodh) (ii). CIT vs. Nangalia Fabrics (P) Ltd., 220 Taxman 17. (iii). CIT vs. Nikunj Exim Enterprises Pvt. Ltd.(2015) 372 ITR 616. 6. We have considered the rival submissions of both the parties and the material available before us. It is not in dispute that most of the creditors are old creditors. The account books of the assessee are audited in w…

Jagdamba Trading Co. v. ITO (16 SOT 66) — Cited in 15 Judgments | BharatTax