In the result, the appeal of the revenue is dismissed
Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 103 & 104/Asr/2024 Assessment Years: 2014-15 & 2017-18 Ito, Ward-3(1), Vs. M/S Jatin Agro Fort Road, Ferozepur. 152-P, Ferozepur. [Pan:-Aarpm5393F] (Appellant) (Respondent) Sh. Ashray Sarna, Ca Appellant By Respondent By Sh. Sunil Gautam, Cit. Dr
section 194(I) of the Act. 7.2 The Ld. DR in support of his contention referred to the decision of Hon’ble Apex Court in the case of CIT vs. M/s Shambhu investment private limited 263 ITR 143 (SC) and submitted that the primary object of the assessee while explaining the property is to be seen and if the main