2003 (5) TMI 47

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.... entered in reference on behalf of the assessee. We heard Sri Shambhu Chopra, learned standing counsel for the Revenue. This is a reference under section 256(1) of the Income-tax Act, 1961, referring the following two questions: Reference by the Commissioner of Income-tax R.A. No. 431 (Alld) of 1981, assessment year 1976-77: "Whether, on the facts and in the circumstances of the case, the Appe....

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....n 147(b) of the Act, 1961. A similar view has been reiterated in Tube Suppliers Ltd. v. CIT [1995] 216 ITR 596, by the Madras High Court and Smt. Indira Devi v. CIT [1994] 210 ITR 537 (Mad). In the instant case as the audit party has pointed out for the assessment year 1976-77 that the assessee was not manufacturing the goods itself rather it was getting them manufactured through some other part....