In the result, the appeal filed by the Revenue in ITA
Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)
section 41(1) of the Act. Reliance in this regard can be placed on the decision of the Hon’ble Gujarat High Court in the case of Aircel Cellular Ltd. vs. CIT, 45 taxmann.com 55 (Guj.). The ld. CIT(A) had fell in serious error in confirming the addition merely going by the fact that the assessee itself had written