S. R. DASS, VIVIAN BOSE, T. L. VENKATARAMA AYYAR, S. K. DAS, A. K. SARKAR
A. N. Lakshman Shenoy: Income Tax Officer, Bangalore: Income Tax Officer, Bangalore – Appellant
Versus
Income Tax Officer, Ernakulam: City Tobacco Mart ; K. Venkataswamy, Moola Rangappa: Dhondusa, Dhaktappa And Pros. K. N. Guruswamy – Respondent
S.K.DAS, J.
(1) THIS judgment relates to and governs eleven appeals which for convenience have been classified into two groups. The first group may be called the group of Travancore-Cochin appeals, and within this group fall Civil Appeals Nos. 143 to 145 of 1954. The, second group may be called the group of Mysore appeals and within this group are eight appeals, namely, Civil Appeals Nos. 27 to 30 of 1956 and 161 to 164 of 1956. By reason of the circumstance that certain common questions of law and fact arise in all these eleven appeals, they have been heard one after the other; but it will be convenient and will avoid confusion if we state the facts relating to the Travancore-Cochin group first and then deal with the questions arising therefrom. We shall then state the additional facts of the Mysore group of appeals, and answer the questions arising therefrom, in so far only as they have not been answered already in relation to the Travancore-Cochin group. It may be here added that in the Travancore-Cochin appeals (Civil Appeals 143 to 145 of 1954) the appellant is the assessee, A. N. Lakshmana Shenoy, of Messrs. New Guna Shenoy Company, Ernakulam, and the two respondents a
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