COMMISSIONER OF INCOME TAX Vs. SIEL HOLDINGS LTD

JUDGEMENT

(1.) This appeal by the Revenue under Section 260A of the Income Tax Act, 1961 ('Act', for short) in the case of SIEL Holdings Ltd., which is now merged with Usha International Ltd. pertains to the assessment year 2007-08.

(2.) The Assessing Officer had included/added an amount of Rs. 50,00,000/- to the taxable income under Section 41(1) of the Act inter alia recording as under: -

(3.) The CIT (Appeals) upheld the said addition after recording the following: -