Bench: Hon’Ble Sri M.Balaganesh, Am & Shri Partha Sarathi Chaudhury, Jm] I.T.A No. 365/Kol/2013 Assessment Year : 2009-10 I.T.O., Ward-8(3), -Vs.- M/S. Ruia Sons Pvt. Ltd. Kolkata Kolkata [Pan : Aaccr 3949 Q] (Respondent) (Appellant) For The Appellant : Shri Arup Kumar Sinha, Cit For The Respondent : Shri Manoj Kataruka, Advocate
44D or mask the true character of the income by disguising it as a capital receipt as in a case falling within section 44E or assume diverse other forms. But there must be some artifice or device enabling the assessee to avoid payment of tax on which is really and in truth his income. If the assessee parts with