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2021 Supreme(Bom) 294

SUNIL P.DESHMUKH, ABHAY AHUJA
Piramal Enterprises Limited – Appellant
Versus
Additional/Joint/Deputy/Assistant Commissioner of Income Tax – Respondent


Advocates:
Advocate Appeared:
For the Petitioners: Mr. Percy Pardiwala, Mr. Madhur Agarwal, Ms. Priyanka Bore.
For the Respondent: Mr. Sham Walve.

JUDGMENT :

SUNIL P. DESHMUKH, J.

1. The petitioner - a registered company is before the court aggrieved by the draft assessment order dated 22.04.2021 (for the assessment year 2017-18) under Faceless Assessment System/e-Assessment.

2. Petitioner carries on various businesses including pharmaceuticals comprising manufacturing pharmaceutical formulations as well as trading in pharmaceutical goods. It purchases raw material for manufacturing its formulations as well as purchases goods for trading.

3. The petitioner had filed its original return of income for the assessment year 2017-18 in November 2017 declaring NIL income. The petitioner has filed a revised return of income in March 2019 for said assessment year electronically in the prescribed fixed format.

4. According to petitioner, in its profit and loss account, it breaks up expenditure in broad categories viz. cost of material consumed, purchase of stock in trade and change in inventory of finished goods, work in progress and stock in trade. Its details are disclosed in schedule to profit and loss account. In the balance-sheet, inventory (closing stock) comprises the items raw material, work in progress, finished goods, stock in tra

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