TMI Blog2011 (12) TMI 338X X X X Extracts X X X X X X X X Extracts X X X X ..... arlier years - Appeal is dismissed - IT Appeal No. 41 of 2011 - - - Dated:- 7-12-2011 - J.P. Devadhar, A.R. Joshi, JJ. D.K. Kamwal for the Appellant Deepak Tralshawala with V.S. Hadade for the Respondent JUDGEMENT By the court:- 1. Three questions of law raised by the Revenue in this appeal read thus:- "(a) Whether on the facts and in the circumstances of the case ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eality, it employed only two carpenters and other barely labours, only for the purpose of manufacture/production of crafts and artistic articles dissatisfying the condition required by the provision of s. 10BA(2)(e) of the IT Act, 1961? (c) Whether on the facts and circumstances of the case, the Tribunal erred in law in holding DEPB as a profit derived from export business for the purpose of c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... umstances, questions (a) and (b) raised by the Revenue cannot be entertained. 4. As regards question (c) is concerned, counsel for the Revenue fairly states that though the question has been raised by relying upon the decision of the apex Court in the case of Liberty India vs. CIT (2009) 225 CTR (SC) 233 : (2009) 28 DTR (SC) 73 : (2009) 317 ITR 218 (SC), the said decision has no relevance to t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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