further submitted that the principle laid down in the case of McDowell & Co. v. CTO is not applicable to the case of this company ... relying on the decision of the apex Court in the case of McDowell & Co. v. CTO (supra), made the abovementioned disallowance
branch at Faridabad was earlier handling the sale of IMFL manufactured by McDowell and Herbertsons. It was submitted that McDowell & Co. Ltd., vide their ... notice of the assessee-company regarding unsatisfactory sales of various McDowell products through the assessee's depot at Faridabad. McDowell & Co. Ltd. brought
order of the Hon'ble Supreme Court in case of McDowell and Co. Ltd V.
Commercial Tax office ... decisions of the Hon'ble
Supreme Court, in the case of McDowell and Co. Ltd. V. Commercial Tax
Off ice (supra
judgment of the Hon'ble Supreme Court in the case of Mcdowell & Co.
Ltd. Vs CTO 154 ITR 148 (SC)
3. The Appellant ... laws of JiyaJeerao Cotton Mills Ltd.
Vs CIT 85 EFT (supra) and McDowell and Co. Ltd. Vs CTO (supra) , held
that the appellant employed colorful
evasion in terms of the S.C. Judgment in the case of McDowell Co. Ltd. [1985] 154 ITR 148 ;
(b) That, if the assessee ... which the ratio of the Supreme Court judgment in the case of McDowell and Co. Ltd. v. CTO [1985] 154 ITR 148 is clearly applicable
Judgment of the Hon'ble Supreme Court in the case of McDowell & Co. Ltd. v. CTO [1985] 154 ITR 148/22 Taxman ... judgment of the Hon'ble Supreme Court in the case of McDowell & Co. Ltd (supra), would not apply. Moreover, the decision
judgement of the Hon'ble
Supreme Court in the case of Mcdowell & Co Ltd (154 ITR 148). However, it should be
noted that ... Court while further expounding of their
earlier judgement in the case of McDowell & Co have made the following pertinent topical
observations
Supreme Court in
the case of M/s McDowell & Co. Ltd. Vs. CTO [1958] 154
ITR 148 found that by incurring multiple transaction ... view of
Hon'ble Supreme Court decision in the case of McDowell
vs. CIT The appellant further submitted that the DCIT
has wrongly added
Durga Parsad More, 82 ITR 540
(SC), Mcdowell & Co Ltd, 154 ITR 148 (SC), and CIT vs. Durga Prasad More
decision of the Hon'ble Supreme Court in the case of McDowell