Supreme Court of India
Commissioner Of Income Tax vs K.T. Doctor on 18 February, 1997
Equivalent citations: AIR1999SC1546, [1998]230ITR744(SC), (1999)9SCC119, AIR 1999 SUPREME COURT 1546, 1999 (9) SCC 119, 1998 AIR SCW 3941, (1998) 230 ITR 744, (1998) 147 CURTAXREP 336
Bench: B.P. Jeevan Reddy, K.S. Paripoornan
ORDER
1. We find that there is no discussion about the plea of device in the judgment of the Tribunal, though, it is true, that the appeals before the Tribunal were by the assessee. We also find that even in the judgment of the High Court, this aspect does not seem to have been argued or dealt with. In the circumstances, it is not possible for us to examine the theory of device. These appeals are dismissed accordingly. No costs.