PRINCIPAL COMNR. OF INCOME TAX, SAMBALPUR RANGE vs. M/S. TATA SPONGE IRON LTD.

Bench: MR. JUSTICE ARINDAM SINHA,MR. JUSTICE SANJAY KUMAR MISHRA

1) to Rule 3 is not applicable and transaction value is determined in terms of Rules 4 to 9 of the 2007 Rules. 16.6. The proper officer can raise doubts as to the truth or accuracy Digitally Signed By:KAMLESH KUMAR Signing Date:27.11.2024 18:20:25 Signature Not Verified CUSAA 26/2022 & connected matters Page

PRINCIPAL COMMNR. OF INCOME TAX, SAMBALPUR vs. BINAY KUMAR JINDAL, HUF

Accordingly, this appeal fails and is dismissed

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE MURAHARI SRI RAMAN

12. The following words of Lord Denning in the matter of applying precedents have become locus classicus: (Abdul Kayoom v. CIT, AIR 1962 SC 680, p. 688, para 19) "19… Each case depends on its own facts and a close similarity between one case and another is not enough because even a single significant detail may alter the entire aspect