IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/TAX APPEAL NO. 782 of 2025 ==========================================================

THE PRINCIPAL COMMISSIONER OF INCOME TAX 1 Versus M/S. P. C. PATEL AND CO.

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Appearance:

MR. MAUNIL YAJNIK, SENIOR STANDING COUNSEL for the Appellant(s)

No. 1 ==========================================================

CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MR. JUSTICE PRANAV TRIVEDI Date : 19/12/2025

ORAL ORDER

(PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA)

1 At the outset, learned Senior Standing Counsel Mr.Maunil Yajnik for the appellant has submitted that the issue is squarely covered by the order dated 06.10.2025 passed in Tax Appeal No. 1008 of 2024. We have also noticed that identical proposed question of law by the present appellant has been answered in negative in favour of the appellant department in the order dated 06.10.2025 in Tax Appeal No. 1008 of 2024.

2 In the present tax appeal, the following substantial questions of law has been proposed:

“(A) Whether on the facts and circumstances of the case, the Appellate Tribunal is right in law in defining the nature of business of the a