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Wrote on 25 December 2013  

Dear One, The order passed by ITAT is of 2009, which relies upon Union of India and Others v. Dharmendra Textile Processors and Others (2008) 13 SCC 369 in arriving at its decision. However, Dharmendra Textiles Processors was explained by the Supreme Court of India Union of India v. Rajasthan Spinning and Weaving Mills (2009) 224 CTR (SC)1. It would be useful to refer to the decision in CIT v. Reliance Petroproducts Pvt Ltd 322 ITR 158 . A.K.Sachdeva, Advocate

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