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Addl Cit Large Tax Payer Unit, Mumbai vs Reliance Industries Ltd, Mumbai on 12 April, 2017

7.28 The ld Counsel Counsel submitted that aforesaid view has subsequently been reiterated and followed by the Hon'ble Bombay High Court in CIT v. Reliance Industries Ltd. [(2019) 102 Taxmann.com 372], wherein, in paragraph 7 of the judgment, the principle that a tariff fixed under a Court once again approved the principle regulatory framework cannot be equated with a price discovered in an open and competitive market.
Income Tax Appellate Tribunal - Mumbai Cites 91 - Cited by 73 - Full Document

M/S Godrej Investment Pvt. Ltd. (Now ... vs Dcit 14(1)(2), Mumbai on 26 November, 2021

5.23 In support of the proposition that recording of objective satisfaction is a mandatory jurisdictional requirement before invoking Rule 8D, the learned counsel placed reliance on authoritative judicial pronouncements. Reference was made to the judgment of the Hon'ble Supreme Court in Godrej & Boyce Manufacturing Ltd.(supra),, wherein it was held that Rule 8D can cturing Co. Ltd.(supra) be applied only after the Assessing Officer records satisfaction, having regard to the accounts of the assessee, that the claim made by the assessee is not correct.
Income Tax Appellate Tribunal - Mumbai Cites 22 - Cited by 276 - Full Document
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