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6.Further, we find that against dismissal of the Miscellaneous Petition filed by the Revenue in the case of DCIT v. Paragon Steels Pvt. Ltd. in M.P. No. 214/Mds/2016 [in I.T.A. No.887/Mds/2015] dated 03.03.2017, the Revenue preferred further appeal before the Hon'ble Madras High Court in T.C.A. No. 579 of 2017. While dismissing the appeal filed by the Revenue, the Hon'ble Jurisdictional High Court has held as under: