ACIT, New Delhi vs. M/S. Hcl Comnet Systems and Services Ltd., New Delhi
In the result, the appeal of the assessee is allowed
ITA 5924/DEL/2014[2005-06]Status: DisposedITAT Delhi25 Jun 2020AY 2005-06
Bench: Ms. Sushma Chowlashri N.K. Billaiya
For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Satpal Gulati, Sr. DR
Section 10ASection 14ASection 251(1)
…oviding for such relief, then the assessee would be entitled to such relief. 53. Relying on the judgments in the case of Wallace Flour Mills Co. Ltd. v. Collector of Central Excise [1989] 4 SCC 592, and in the case of Kasinka Trading v. Union of India [1995] 1 SCC 274, it was held that merely because exemption has been granted in respect of the taxability of particular source of income, it cannot be formulated that the entity is not liable to tax as contended by the respondents. 54. In fact the Apex Court in the case of Kasinka Trading (supra), a case arising under Customs Act at para 21 has held as under: 'Th…