SURYA MERCHANTS LTD.,NEW DELHI vs. DCIT, GHAZIABAD

In the result, the above appeals filed by the assessee are partly allowed

Bench: Sh. R.K. Panda & Ms. Suchitra Kamble

section 40A(3). Rule 6DD is not exhaustive but illustrative. 4 6. The Ld. Counsel for the assessee referring to the decision of Hon’ble Supreme Court in the case of Jute Corporation of India Limited Vs. CIT reported in 187 ITR 688 and NTPC Vs. CIT reported in 229 ITR 383 submitted that the above additional grounds being