M/S.VIRTUAL SOFT SYSTEMS LTD. vs. COMMISSIONER OF INCOME TAX, DELHI-I
C.A. No.-007115-007115 - 2005Supreme Court06 Feb 2007
For Respondent: Commissioner of Income Tax, Delhi-I
Section 260ASection 271(1)(c)Section 68
2. Whether the ITAT was justified in holding that
the judgments in Prithipal Singh’s case (183 ITR 69
and 249 ITR 670) will apply even after insertion of
Explanation 4 to Section 271(1)(c) of the Income
Tax Act, 1961 with effect from 1.4.1976?
FACTS (C.A. NO. 7115 OF 2005)
For the assessment year 1996-97, the assessee