In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee M/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue
B)." In view of above, it is held that the ratio and findings in the case of Manjunath Cotton (Supra) are totally inapplicable in the given facts of the case. On the contrary, the ratio laid down by the Hon'ble Court in Manjunath Cotton's case support the case of the AO as discussed in detail. The reliance