S.G. Mercantile Corporation v. CIT

113 ITR 712High Court1978#4605 most cited

What is S.G. Mercantile Corporation v. CIT authority for?

Profit motive is an essential condition for an activity to be considered as business, trade, or commerce.

25

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2022.

Also referred to as

S.G. Mercantile Corporation v. CIT · business · profit motive · essential condition · trade · commerce · Narasingha Kar & CO.

Judgments citing S.G. Mercantile Corporation v. CIT

VARANASI DEVELOPMENT AUTHORITY,VARANASEE vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result appeal filed by assessee in ITA no

ITA 267/ALLD/2017[2014-15]Status: DisposedITAT Varanasi06 Jul 2022AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R
Section 11Section 12Section 12ASection 143(3)Section 2(15)

…vity; and (ii) it must be carried on with a profit motive." Similar findings have been made in the following case laws: (1) Barendra Prasad Ray v. ITO (1981) 129 ITR 295 (SC) (2) LalaIndra Sun In Re (1940) 8 ITR 187 (Alld) (3) NarasinghaKar& CO. v, CIT (1978) 113 ITR 712(Ori) 9.11 From the aforesaid, it is clear that the appellant "Authority" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as st…

VARANASI DEVELOPMENT AUTHORITY,VARANASEE vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result appeal filed by assessee in ITA no

ITA 266/ALLD/2017[2013-14]Status: DisposedITAT Varanasi06 Jul 2022AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R
Section 11Section 12Section 12ASection 143(3)Section 2(15)

…vity; and (ii) it must be carried on with a profit motive." Similar findings have been made in the following case laws: (1) Barendra Prasad Ray v. ITO (1981) 129 ITR 295 (SC) (2) LalaIndra Sun In Re (1940) 8 ITR 187 (Alld) (3) NarasinghaKar& CO. v, CIT (1978) 113 ITR 712(Ori) 9.11 From the aforesaid, it is clear that the appellant "Authority" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as st…

M/S. VARANASI DEVELOPMENT AUTHORITY,VARANASI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), VARANASI

In the result appeal filed by assessee in ITA no

ITA 265/ALLD/2017[2012-13]Status: DisposedITAT Varanasi06 Jul 2022AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R
Section 11Section 12Section 12ASection 143(3)Section 2(15)

…vity; and (ii) it must be carried on with a profit motive." Similar findings have been made in the following case laws: (1) Barendra Prasad Ray v. ITO (1981) 129 ITR 295 (SC) (2) LalaIndra Sun In Re (1940) 8 ITR 187 (Alld) (3) NarasinghaKar& CO. v, CIT (1978) 113 ITR 712(Ori) 9.11 From the aforesaid, it is clear that the appellant "Authority" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as st…

M/S. VARANASI DEVELOPMENT AUTHORITY,VARANASI vs. ASSISTANT COMMISSIONER OF INCOME TAX , VARANASI

In the result appeal filed by assessee in ITA no

ITA 264/ALLD/2017[2011-12]Status: DisposedITAT Varanasi06 Jul 2022AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R
Section 11Section 12Section 12ASection 143(3)Section 2(15)

…vity; and (ii) it must be carried on with a profit motive." Similar findings have been made in the following case laws: (1) Barendra Prasad Ray v. ITO (1981) 129 ITR 295 (SC) (2) LalaIndra Sun In Re (1940) 8 ITR 187 (Alld) (3) NarasinghaKar& CO. v, CIT (1978) 113 ITR 712(Ori) 9.11 From the aforesaid, it is clear that the appellant "Authority" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as st…

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 701/LKW/2019[2017-18]Status: DisposedITAT Lucknow10 Jun 2022AY 2017-18

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

…Page 1 of 86 (UP AWAS EVAM VIKAS PARISHAD) IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH ‘B’, LUCKNOW BEFORE SHRI A. D. JAIN, VICE PRESIDENT AND SHRI T. S. KAPOOR, ACCOUNTANT MEMBER I.T.A. No.165/Lkw/2019 Assessment Year:2015-16 I.T.A. No.166/Lkw/2019 Assessment year:2016-17 I.T.A. No.701/Lkw/2019 Assessment year:2017-18 M/s U.P. Awas Evam Vikas Vs. A.C.I.T (Exemption), Parishad Lucknow. 104, Mahatma Gandhi Marg, Lucknow. PAN:AAAJU0103A (Appellant) (Respondent) C.O.No.02/Lkw/2020 (in I.T.A. No.166/Lkw/2019 Assessment year:2016-17 C.O.No.03/Lkw/2020 (in I.T.A. No.701/Lkw/2019) Assessment year:2017-1…

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 166/LKW/2019[2016-17]Status: DisposedITAT Lucknow10 Jun 2022AY 2016-17

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

…Page 1 of 86 (UP AWAS EVAM VIKAS PARISHAD) IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH ‘B’, LUCKNOW BEFORE SHRI A. D. JAIN, VICE PRESIDENT AND SHRI T. S. KAPOOR, ACCOUNTANT MEMBER I.T.A. No.165/Lkw/2019 Assessment Year:2015-16 I.T.A. No.166/Lkw/2019 Assessment year:2016-17 I.T.A. No.701/Lkw/2019 Assessment year:2017-18 M/s U.P. Awas Evam Vikas Vs. A.C.I.T (Exemption), Parishad Lucknow. 104, Mahatma Gandhi Marg, Lucknow. PAN:AAAJU0103A (Appellant) (Respondent) C.O.No.02/Lkw/2020 (in I.T.A. No.166/Lkw/2019 Assessment year:2016-17 C.O.No.03/Lkw/2020 (in I.T.A. No.701/Lkw/2019) Assessment year:2017-1…

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 165/LKW/2019[2015-16]Status: DisposedITAT Lucknow10 Jun 2022AY 2015-16

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

…Page 1 of 86 (UP AWAS EVAM VIKAS PARISHAD) IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH ‘B’, LUCKNOW BEFORE SHRI A. D. JAIN, VICE PRESIDENT AND SHRI T. S. KAPOOR, ACCOUNTANT MEMBER I.T.A. No.165/Lkw/2019 Assessment Year:2015-16 I.T.A. No.166/Lkw/2019 Assessment year:2016-17 I.T.A. No.701/Lkw/2019 Assessment year:2017-18 M/s U.P. Awas Evam Vikas Vs. A.C.I.T (Exemption), Parishad Lucknow. 104, Mahatma Gandhi Marg, Lucknow. PAN:AAAJU0103A (Appellant) (Respondent) C.O.No.02/Lkw/2020 (in I.T.A. No.166/Lkw/2019 Assessment year:2016-17 C.O.No.03/Lkw/2020 (in I.T.A. No.701/Lkw/2019) Assessment year:2017-1…

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 24/LKW/2017[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…d as business are (i) it must be a continuous course of activity; and (ii) it must be carried on with a profit motive." Barendra Prasad Ray vs. ITO (1981) 129 ITR 295 (SC) 4) Lala Indra Sun In Re (1940) 8 ITR 187 (Alld.) 5) Narasingha Kar & CO. vs, CIT (1978) 113 ITR 712(Ori.) 6) From the aforesaid, it is clear that the Parishad "Parishad" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as stat…

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 23/LKW/2017[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…d as business are (i) it must be a continuous course of activity; and (ii) it must be carried on with a profit motive." Barendra Prasad Ray vs. ITO (1981) 129 ITR 295 (SC) 4) Lala Indra Sun In Re (1940) 8 ITR 187 (Alld.) 5) Narasingha Kar & CO. vs, CIT (1978) 113 ITR 712(Ori.) 6) From the aforesaid, it is clear that the Parishad "Parishad" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as stat…

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 211/LKW/2017[2014-15]Status: DisposedITAT Lucknow08 Jun 2022AY 2014-15

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…d as business are (i) it must be a continuous course of activity; and (ii) it must be carried on with a profit motive." Barendra Prasad Ray vs. ITO (1981) 129 ITR 295 (SC) 4) Lala Indra Sun In Re (1940) 8 ITR 187 (Alld.) 5) Narasingha Kar & CO. vs, CIT (1978) 113 ITR 712(Ori.) 6) From the aforesaid, it is clear that the Parishad "Parishad" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as stat…

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 210/LKW/2017[2013-14]Status: DisposedITAT Lucknow08 Jun 2022AY 2013-14

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…d as business are (i) it must be a continuous course of activity; and (ii) it must be carried on with a profit motive." Barendra Prasad Ray vs. ITO (1981) 129 ITR 295 (SC) 4) Lala Indra Sun In Re (1940) 8 ITR 187 (Alld.) 5) Narasingha Kar & CO. vs, CIT (1978) 113 ITR 712(Ori.) 6) From the aforesaid, it is clear that the Parishad "Parishad" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as stat…

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 165/LKW/2017[2012-13]Status: DisposedITAT Lucknow08 Jun 2022AY 2012-13

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…d as business are (i) it must be a continuous course of activity; and (ii) it must be carried on with a profit motive." Barendra Prasad Ray vs. ITO (1981) 129 ITR 295 (SC) 4) Lala Indra Sun In Re (1940) 8 ITR 187 (Alld.) 5) Narasingha Kar & CO. vs, CIT (1978) 113 ITR 712(Ori.) 6) From the aforesaid, it is clear that the Parishad "Parishad" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as stat…

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 164/LKW/2017[2011-12]Status: DisposedITAT Lucknow08 Jun 2022AY 2011-12

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…d as business are (i) it must be a continuous course of activity; and (ii) it must be carried on with a profit motive." Barendra Prasad Ray vs. ITO (1981) 129 ITR 295 (SC) 4) Lala Indra Sun In Re (1940) 8 ITR 187 (Alld.) 5) Narasingha Kar & CO. vs, CIT (1978) 113 ITR 712(Ori.) 6) From the aforesaid, it is clear that the Parishad "Parishad" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as stat…

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 631/LKW/2016[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…d as business are (i) it must be a continuous course of activity; and (ii) it must be carried on with a profit motive." Barendra Prasad Ray vs. ITO (1981) 129 ITR 295 (SC) 4) Lala Indra Sun In Re (1940) 8 ITR 187 (Alld.) 5) Narasingha Kar & CO. vs, CIT (1978) 113 ITR 712(Ori.) 6) From the aforesaid, it is clear that the Parishad "Parishad" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as stat…

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 630/LKW/2016[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…d as business are (i) it must be a continuous course of activity; and (ii) it must be carried on with a profit motive." Barendra Prasad Ray vs. ITO (1981) 129 ITR 295 (SC) 4) Lala Indra Sun In Re (1940) 8 ITR 187 (Alld.) 5) Narasingha Kar & CO. vs, CIT (1978) 113 ITR 712(Ori.) 6) From the aforesaid, it is clear that the Parishad "Parishad" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce as stat…

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. DCIT (E), LUCKNOW

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

ITA 666/LKW/2019[2012-13]Status: DisposedITAT Lucknow05 Apr 2022AY 2012-13

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 13(1)(c)Section 13(3)Section 143(3)Section 147Section 154Section 2(15)Section 40

…vity; and (ii) it must be carried on with a profit motive." Similar findings have been made in the following case laws: Barendra Prasad Ray v. ITO (1981) 129 ITR 295 (SC) (1) LalaIndra Sun In Re (1940) 8 ITR 187 (Alld) (2) NarasinghaKar& CO. v, CIT (1978) 113 ITR 712(Ori) (3) 9.11 From the aforesaid, it is clear that the appellant "Authority" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce…

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. DCIT (E), LUCKNOW

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

ITA 665/LKW/2019[2012-13]Status: DisposedITAT Lucknow05 Apr 2022AY 2012-13

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 13(1)(c)Section 13(3)Section 143(3)Section 147Section 154Section 2(15)Section 40

…vity; and (ii) it must be carried on with a profit motive." Similar findings have been made in the following case laws: Barendra Prasad Ray v. ITO (1981) 129 ITR 295 (SC) (1) LalaIndra Sun In Re (1940) 8 ITR 187 (Alld) (2) NarasinghaKar& CO. v, CIT (1978) 113 ITR 712(Ori) (3) 9.11 From the aforesaid, it is clear that the appellant "Authority" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce…

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. DCIT (E), LUCKNOW

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

ITA 656/LKW/2019[2012-13]Status: DisposedITAT Lucknow05 Apr 2022AY 2012-13

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 13(1)(c)Section 13(3)Section 143(3)Section 147Section 154Section 2(15)Section 40

…vity; and (ii) it must be carried on with a profit motive." Similar findings have been made in the following case laws: Barendra Prasad Ray v. ITO (1981) 129 ITR 295 (SC) (1) LalaIndra Sun In Re (1940) 8 ITR 187 (Alld) (2) NarasinghaKar& CO. v, CIT (1978) 113 ITR 712(Ori) (3) 9.11 From the aforesaid, it is clear that the appellant "Authority" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essential conditions of business, trade or commerce…

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. DCIT (E), LUCKNOW

In the result, all the appeals are partly allowed

ITA 439/LKW/2019[2016-17]Status: DisposedITAT Lucknow10 Mar 2022AY 2016-17

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 2(15)

…vity; and (ii) it must be carried on with a profit motive." Similar findings have been made in the following case laws: (1) Barendra Prasad Ray v. ITO (1981) 129 ITR 295 (SC) LalaIndra Sun In Re (1940) 8 ITR 187 (Alld) (2) NarasinghaKar& CO. v, CIT (1978) 113 ITR 712(Ori) (3) I.T.A. Nos.185,186,163,164,439/Lkw/2019 38 9.11 From the aforesaid, it is clear that the appellant "Authority" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essenti…

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. ACIT (E), LUCKNOW

In the result, all the appeals are partly allowed

ITA 186/LKW/2019[2013-14]Status: DisposedITAT Lucknow10 Mar 2022AY 2013-14

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 2(15)

…vity; and (ii) it must be carried on with a profit motive." Similar findings have been made in the following case laws: (1) Barendra Prasad Ray v. ITO (1981) 129 ITR 295 (SC) LalaIndra Sun In Re (1940) 8 ITR 187 (Alld) (2) NarasinghaKar& CO. v, CIT (1978) 113 ITR 712(Ori) (3) I.T.A. Nos.185,186,163,164,439/Lkw/2019 38 9.11 From the aforesaid, it is clear that the appellant "Authority" is not engaged in carrying on any activity in the nature of trade, commerce or business or any activity in rendering any service in relation to any trade, commerce or business in as much as profit motive is one of the essenti…

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S.G. Mercantile Corporation v. CIT (113 ITR 712) — Cited in 25 Judgments | BharatTax