view of the Supreme Court in the case of McDowell & Co. Ltd. v. CTO [1985] 154 ITR 148, in case the assessee is intending ... expressed by the Hon'ble Supreme Court in McDowell & Co. Ltd.'s case (supra).
2. Somewhat similar circumstances were there before
Income-tax [1996] 222 ITR
831 at 850 where referring to McDowell's case [1985] 154 ITR 148
(SC), the court observed ... Tribunal apparently appears to have drawn from the
enunciation made in McDowell's case [1958] 154 ITR 148 (SC).
The ratio of any decision
M/S Agencies Rajasthan Pvt. Ltd., ... vs Income Tax Officer, Ward-6-2, Jaipur on
colourable transaction in view of Supreme Court decision in case of McDowell & Co. Ltd. v. CTO (1985) 154 ITR 148 (SC).
(g) The nature ... Taxman 226 (Nag)(Mag).
15. In respect of reliance of 'McDowell's case, it is submitted that it was held that the depreciation
Sumatı Dayal v Commissioner of Income tax/1995] 80 Taxman 89 (SC)
McDowell & Co. Ltd. v. Commercial Tax Officer ... Dayal v Commissioner of Income
tax[1995] 80 Taxman 89 (SC) and McDowell & Co. Ltd. v. Commercial Tax
Officer
baseless and without any
substance. The Supreme Court in McDowell's case 154 ITR 148 relied by the
AO has held that tax planning ... case of Azadi Bachao Andolan 263 ITR 706
after considering the McDowell's case held that one could not accept
applicable but the ratio of decision in the case of McDowell & Co. Ltd. v. CTO [1985] 154 ITR 148 (SC) was applicable. He submitted ... argued that so far as the applicability of ratio of decision of McDowell & Co. Ltd.'s case (supra) was concerned, it was totally
Rajesh Corpn. vs Income-Tax Officer on 12 April, 1988
Equivalent citations: [1988]25ITD420(JP
lower authorities and also
relied on following decisions:-
DCIT vs. Mcdowell & Co. Ltd. 291 ITR 0107 (KAR)
Onam Agarbathi Co. vs. DCIT
also taken into account the Apex court
judgement in the case of Mcdowell & Co. Ltd. It is worthwhile to
quote from the landmark judgement ... assessee. The
reliance placed by him in case of McDowell & Co. Ltd. is thus
misplaced and not applicable.
6. Reliance in this connection
