2021 (11) TMI 1190

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....Senior Advocate a/w Mr. Niraj D. Sheth i/b Mr. Nitin Dhumal P. C. :- 1. Heard. 2. Following substantial questions of law are proposed by the Appellant : (i) Whether on the facts and in the circumstances of the case, the Hon'ble ITAT was right in deleting the addition of Rs.22,45,06,500/- made on account of cash donation collected outside the books of accounts, ignoring the presumption cast a....

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....ormal rate of taxes. As such, interpretation of Mafatlal decision is in direct contravention of the earlier decisions of Bombay High Court in the case of Shardaben Bhagubai Mafatlal Public Charitable Trust (247 ITR 1) and also of the Hon'ble Apex Court in the case of Director of Income Tax Vs. Bharat Diamond Bourse, 2002 ? 3. As regards Question (ii), we are not inclined to entertain the same ina....