CIT Vs. S NET FREIGHT INDIA PVT LTD

JUDGEMENT

(1.) (OPEN COURT) 1. In these two appeals following question of law arises:

(2.) ADMIT.

(3.) THE ITAT accepted the assessee's contentions and held that Dr. Prem Chand John and Mrs. Dakshayani Reddy were in fact holding the shares on behalf of foreign investors and the foreign investors fell within the description of "beneficial owner" under Section 79 of the Act. The reasoning of the Tribunal is to be found in the following extract of the impugned order: