Harsha Devani, J.

1. Being highly aggrieved by the action of the respondent -Assessing Officer of ignoring a decision of the jurisdictional High Court directly covering the controversy in issue as well as the assessment orders passed in the previous years and making a high pitched assessment, the petitioner has directly approached this court challenging the assessment order dated 31.03.2015 passed by the respondent Assessing Officer in relation to assessment year 2012-13, to the extent he has made an addition of Rs. 116,43,00,000/- by way of disallowance of the final installment of the price paid for milk.

2. Against the assessment order, the petitioner has already preferred an appeal before the Commissioner of Income-tax (Appeals). However, considering the conduct of the Assessing Officer in disregarding the decision of this court in the case of Commissioner of Income-tax v. Mehsana District Cooperative Milk Producers Union Ltd., (2006) 282 ITR 24, the petitioner has thought it fit to challenge the impugned order to the extent of the above addition, as in its opinion, the Assessing Officer is answerable to this court.

3. Mr. J.P. Shah, learned advocate for the petitioner empha