EBR ENTERPRISES Vs. UNION OF INDIA

JUDGEMENT

(1.) Petitioners have made following prayers :

(2.) Brief facts are, as under:

(3.) The prayers made by the Petitioners in the Writ Petition, which have reproduced hereinabove, are in two parts. One part challenges the retrospective operation of Sub Section (5) of Section 80A of the Act. The learned Counsel for the Petitioners at the outset stated that the Petitioners do not press this challenge. We have therefore proceeded on such basis. Second part of the Petitioners' prayer though worded some what differently, it challenges the Revisional Order of the CIT. In this context, the Counsel for the Petitioners raised the following contentions :