NAVDEEP INVESTMENT P LTD Vs. INCOME TAX OFFICER
INCOME TAX APPELLATE TRIBUNAL
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B.L. Chhibber, Accountant Member -
(1.) THESE two appeals by the assessee are directed against the orders of the learned CIT (Appeals).
(2.) First we take up the appeal (ITA No. 249/Ahd./1990) as our findings in this appeal will have great consequential effect on appeal in ITA No. 1991/Ahd./90.
The first and the main grievance of the assessee is that the learned CIT(A) has erred in holding that the learned ITO was fully justified in making addition of Rs. 15,76,019 being difference between the amount charged to 100% subsidiary company and the cost price as income from business.
(3.) THE assessee is an Investment Company. It holds large investments in shares of companies and it is held to be a dealer in shares and the profit and/or loss therefrom is treated as income from business. It is also having investment in immovable properties. THE rent income received from the immovable properties has been shown and assessed under the head "Property income" for all the years ever since the inception of the company.;
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