(1.) THE Revenue has preferred this revision against the order of the Tamil Nadu Sales Tax Appellate Tribunal (Main Bench), Chennai dated October 25, 1999 made in T.A. No. 169 of 1998, in respect of assessment year 1993 -94, and the same was admitted on the following substantial question of law:
(2.) THE apex court in Commissioner of Income -tax v. Reliance Petroproducts Pvt. Ltd. : (2010) 322 ITR 158 (SC), while dealing with section 271(1)(c) of the Income -tax Act, 1961 which is similar to section 12(3) of the Tamil Nadu General Sales Tax Act, 1959, has held as follows (page 166 in 322 ITR):