IN THE GUJARAT HIGH COURT
J.B. PARDIWALA & ILESH J. VORA, JJ.
Pr. CIT v. Shreno Ltd.
R/Tax Appeal No. 302 of 2020 with R/Tax Appeal No. 311 of 2020
21 January, 2021
Appellant(s) by: No. 1 Varun K. Patel (3802)
Opponent(s) by :No. 1 B.S. Soparkar (6851)
J.B. Pardiwala, J.
As the proposed questions of law in both the tax appeals are by and large common and the assessee is also the same, those were taken up for hearing analogously and are being disposed of by this common order.
Tax Appeal No. 302 of 2020:
2. This tax appeal under section 260A of the Income Tax Act, 1961 (for short the Act, 1961 ) is at the instance of the revenue and is directed against the order passed by the Income Tax Appellate Tribunal dt. 18-12-2019 in the ITA No.675/Ahd/2016 for the assessment year 2012-13.
3. The revenue has proposed the following three questions of law for the consideration of this Court;
(A) Whether on the facts and in the circumstances of the case, the learned ITAT has erred in law and on facts in not upholding the entire addition of Rs. 97,57,920 made by the assessing officer under section 14A of the Income Tax Act, 1961 read with rule 8D of the Income Tax Rules, 1962?