2012 (9) TMI 664

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..... out for facilitating mining at lignite project site at Rajpardi and Pandhro and that the assessee was merely a labour contractor. These findings of fact have been upheld by the Income Tax Appellate Tribunal and they have not even been discussed in the impugned judgment of the High Court [2006 (8) TMI 144 - GUJARAT HIGH COURT] - against assessee. - CIVIL APPEAL NO. 3207 OF 2007 - - - Dated:- 11-9 .....

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..... Page 37 of the Paper Book). 4. The Assessing Officer came to the conclusion that the assessee claimed to be in the business of mining; the only activity undertaken by it was removal of overburden/earth excavation work carried out for facilitating mining at lignite project site at Rajpardi and Pandhro; and that the assessee was merely a labour contractor. These findings of fact have been upheld .....

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