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Commissioner Of Income-Tax vs Sakarlal Balabhai on 15 January, 1968

5. The assessee appealed to the AAC. The quantum as computed by the ITO was not disputed but the application of Section 44F was challenged. The stand of the assessee was that there was no avoidance of tax and, secondly, in any event, there was no deliberate intention to avoid tax. It was contended that the sales of the shares in dispute formed only a small part of the transactions in shares amounting to Rs. 45.64 lakhs. It was also contended that if at all there was any avoidance of tax, it was exceptional and not systematic and in any event there was no such avoidance in any of the three preceeding years. Reliance was placed by the assessee on the decision of the Gujarat High Court in the case of CIT v. Sakarlal Balabbai [1968] 69 ITR186.
Gujarat High Court Cites 14 - Cited by 13 - Full Document
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