In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes
Bench: Shri Sanjay Arora & Shri Manomohan Das
7 minor partners to the benefits of the partnership, were ladies, who were not residing either in the proximity or vicinity of the mining site, or at a place where the assessee had business transactions. They were, in the view of the Revenue, not working partners in terms of section 40(b)(i) of the Act r/w Explanation 4 thereto