M/S. State Bank of Mauritius Ltd, Mumbai vs. The Dy DIT (Int Tax) 2(1), Mumbai
In the result, both appeals of the assessee are allowed
ITA 3138/MUM/2008[1996-1997]Status: DisposedITAT Mumbai16 Oct 2015AY 1996-1997
For Appellant: Shri P.J.PardiwalaFor Respondent: Shri Vivek A. Perumpurna
Section 139Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 148
…on 147, all that is required is to have prima facie material, which certainly exists in the instant case. Legal position in this regard is very clear as held in the decisions in the cases of Raymond Woolen Mills Ltd. vs. ITO 236 ITR 34 (SC); G. Suresh vs. CIT 252 ITR 230 (Ker) and Dr. Amin's Pathology Laboratory vs. P.N. Prasad & Others 202 ITR 73 (Born). In fact, as noted by the Hon'ble Delhi High Court in the case of Bawa Abhai Singh vs. DCIT 253 ITR 83 and also in Rakesh Agarwal vs. ACIT 225 ITR 496, the provisions of section 147, as amended with effect from 01.04.1989, are contextually different and & ITA No.…