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TMI Blog2022 (4) TMI 912X X X X Extracts X X X X X X X X Extracts X X X X ..... Respondent Through: Mr. Puneet Rai, senior standing counsel for the Revenue with Ms. Adeeba Mujahid and Mr. Karan Pandey, Advocates. J U D G M E N T MANMOHAN, J (Oral): C.M.No.18115/2022 Exemption allowed, subject to all just exceptions. Accordingly, the application stands disposed of. ITA No.85/2022 1. Present appeal has been filed challenging the Order dated 18th February, 2020 passed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (2010) taxmann.com 302 (Delhi) as well as Principal Commissioner of Income Tax-1 vs. Asian Mills Pvt. Ltd. decided by Gujarat High Court in R/Tax Appeal No.244/2021. 4. Learned counsel for the Appellant further states that the Tribunal has failed to follow the principle of consistency laid down by the Supreme Court in Radha Soami Satsang v. CIT [1992]193 ITR 321(SC). 5. Having perused the pape ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... see is not sufficient to prove that Mr. Pandey had provided any kind of service. The Profit and Loss Account of Mr. D.N. Pandey for the previous assessment year shows that out of gross receipt of Rs. 1,64,40,356/-, he had incurred expense of Rs. 1,38,05,010/- towards labour, loading & unloading charges! Last but not the least, the agreement between Mr. D.N. Pandey and the Appellant/assessee does n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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