Ifb Securities Ltd. vs Income Tax Officer on 10 February, 2006
In support of his contention, he has relied on the judgment of Tribunal, Mumbai Bench in case of Amitabh Bachchan v. Dy. CIT (2005) 97 TTJ (Mumbai) 516, wherein it was held that Revenue cannot assess more than real income in respect of transaction entered into by the parties. Relying on the para 10 of the above order, the learned Counsel has submitted that Revenue cannot blow both hot and cold while considering the assessee's agreement with M/s NGL. The learned Counsel for the assessee has, therefore, submitted that it was not justified on the part of the Revenue to take a contrary stand in relation to the assessee's agreement with M/s NGL without disputing and doubting the genuineness of such agreement.