Reportable



                        In The Supreme Court Of India

                        Civil Appellate Jurisdiction

                 Civil Appeal No.     1699          Of 2012
                 (Arising out of Slp (C) No. 26558 Of 2010)

M/s Topman Exports                                       … Appellant

                                   Versus

Commissioner of Income Tax, Mumbai           … Respondent


                                    With

                      Civil Appeal No.   1700   Of 2012
                 (Arising out of Slp (C) No. 27418 of 2010),

                   Civil Appeal No.   1701         Of 2012
                 (Arising out of Slp (C) No.27552 of 2010),

                     Civil Appeal No.   1704     Of 2012
                 (Arising out of Slp (C) No.27583 of 2010),

                   Civil Appeal No.   1705         Of 2012
                 (Arising out of Slp (C) No. 27608 of 2010),

                     Civil Appeal No.   1706     Of 2012
                 (Arising out of Slp (C) No.27994 of 2010),

                     Civil Appeal No.    1707   Of 2012
                 (Arising out of Slp (C) No.28036 of 2010),

                      Civil Appeal No.  1708   Of 2012
                 (Arising out of Slp (C) No.28044; of 2010),

                     Civil Appeal No.   1709    Of 2012
                 (Arising out of Slp (C) No.28131 of 2010),


                      Civil Appeal No.   1710  Of 2012
                 (Arising out of Slp (C) No.28167 of 2010),

                   Civil Appeal No.   1711         Of 2012
                 (Arising out of Slp (C) No.28173 of 2010),

                      Civil Appeal No.  1728    Of 2012
                 (Arising out of Slp (C) No.27952 of 2010),

                   Civil Appeal No.   1729         Of 2012
                 (Arising out of Slp (C) No.28365 of 2010),

                    Civil Appeal No.   1730      Of 2012
                 (Arising out of Slp (C) No.29290 of 2010),

                   Civil Appeal No.   1731         Of 2012
                 (Arising out of Slp (C) No.29314 of 2010),

                   Civil Appeal No.       1732     Of 2012
                 (Arising out of Slp (C) No.29596 of 2010),

                   Civil Appeal No.   1733         Of 2012
                 (Arising out of Slp (C) No.30461 of 2010),

                   Civil Appeal No.   1734         Of 2012
                 (Arising out of Slp (C) No.30462 of 2010),

                   Civil Appeal No.  1735          Of 2012
                 (Arising out of Slp (C) No.30011 of 2010),

                    Civil Appeal No.   1736      Of 2012
                 (Arising out of Slp (C) No.30018 of 2010),

                     Civil Appeal No.   1737    Of 2012
                 (Arising out of Slp (C) No.30020 of 2010),

                     Civil Appeal No.    1738   Of 2012
                 (Arising out of Slp (C) No.30023 of 2010),

                     Civil Appeal No.     1739  Of 2012
                 (Arising out of Slp (C) No.30100 of 2010),


                      Civil Appeal No.    1740  Of 2012
                 (Arising out of Slp (C) No.30281 of 2010),


                   Civil Appeal No.   1741         Of 2012
                 (Arising out of Slp (C) No.30283 of 2010),

                  Civil Appeal Nos.   1712         Of 2012
                 (Arising out of Slp (C) No.30289 of 2010),

                   Civil Appeal No.        1713    Of 2012
                 (Arising out of Slp (C) No.30306 of 2010),

                      Civil Appeal No.  1714   Of 2012
                 (Arising out of Slp (C) No.30345 of 2010),

                   Civil Appeal No.   1715         Of 2012
                 (Arising out of Slp (C) No.30374 of 2010),

                     Civil Appeal No.   1716     Of 2012
                 (Arising out of Slp (C) No.30375 of 2010),

                     Civil Appeal No.    1717   Of 2012
                 (Arising out of Slp (C) No.30379 of 2010),

                      Civil Appeal No.   1718  Of 2012
                 (Arising out of Slp (C) No.30381 of 2010),

                       Civil Appeal No.  1719  Of 2012
                 (Arising out of Slp (C) No.30393 of 2010),

                       Civil Appeal No.  1720  Of 2012
                 (Arising out of Slp (C) No.30411 of 2010),

                      Civil Appeal No.   1721  Of 2012
                 (Arising out of Slp (C) No.30426 of 2010),

                      Civil Appeal No.   1722  Of 2012
                 (Arising out of Slp (C) No.30468 of 2010),

                   Civil Appeal Nos.  1723-1724   Of 2012
              (Arising out of Slp (C) No.30521-30522 of 2010),

                       Civil Appeal No.  1725  Of 2012
                 (Arising out of Slp (C) No.30549 of 2010),


                    Civil Appeal Nos.  1726-1727 Of 2012
              (Arising out of Slp (C) Nos.29853-29854 of 2010),

                   Civil Appeal No.       1742     Of 2012
                 (Arising out of Slp (C) No.30215 of 2010),

                  Civil Appeal No.    1743         Of 2012
                 (Arising out of Slp (C) No.30378 of 2010),

                   Civil Appeal No.   1744         Of 2012
                 (Arising out of Slp (C) No.30380 of 2010),

                     Civil Appeal No.  1745     Of 2012
                 (Arising out of Slp (C) No.30388 of 2010),

                     Civil Appeal No.   1746    Of 2012
                 (Arising out of Slp (C) No.30390 of 2010),

                     Civil Appeal No.    1747   Of 2012
                 (Arising out of Slp (C) No.30543 of 2010),

                      Civil Appeal No.  1748   Of 2012
                 (Arising out of Slp (C) No.30546 of 2010),

                     Civil Appeal No.   1749    Of 2012
                 (Arising out of Slp (C) No.30572 of 2010),

                      Civil Appeal No.  1750   Of 2012
                 (Arising out of Slp (C) No.30574 of 2010),

                      Civil Appeal No.  1754   Of 2012
                 (Arising out of Slp (C) No.30657 of 2010),

                      Civil Appeal No.  1755    Of 2012
                 (Arising out of Slp (C) No.30569 of 2010),

                   Civil Appeal No.    1756        Of 2012
                 (Arising out of Slp (C) No.32066 of 2010),

                   Civil Appeal No.    1757        Of 2012
                 (Arising out of Slp (C) No.32069 of 2010),


                  Civil Appeal Nos.  1758-1759     Of 2012
              (Arising out of Slp (C) Nos.30733-30734 of 2010),

                   Civil Appeal No.   1760         Of 2012
                 (Arising out of Slp (C) No.30597 of 2010),

                   Civil Appeal No.       1761     Of 2012
                 (Arising out of Slp (C) No.30626 of 2010),

                   Civil Appeal No.   1762         Of 2012
                 (Arising out of Slp (C) No.30634 of 2010),

                   Civil Appeal No.   1763         Of 2012
                 (Arising out of Slp (C) No.30644 of 2010),

                   Civil Appeal No.  1764          Of 2012
                 (Arising out of Slp (C) No.30665 of 2010),

                   Civil Appeal No.   1765         Of 2012
                 (Arising out of Slp (C) No.30671 of 2010),

                   Civil Appeal No.   1766         Of 2012
                 (Arising out of Slp (C) No.30680 of 2010),

                   Civil Appeal No.  1767          Of 2012
                 (Arising out of Slp (C) No.30684 of 2010),

                   Civil Appeal No.  1768          Of 2012
                 (Arising out of Slp (C) No.30689 of 2010),

                   Civil Appeal No.   1769         Of 2012
                 (Arising out of Slp (C) No.30721 of 2010),

                   Civil Appeal No.  1770          Of 2012
                 (Arising out of Slp (C) No.30902 of 2010),

                   Civil Appeal No.  1771          Of 2012
                 (Arising out of Slp (C) No.31085 of 2010),

                   Civil Appeal No.  1772          Of 2012
                 (Arising out of Slp (C) No.31107 of 2010),


                   Civil Appeal No.   1773         Of 2012
                 (Arising out of Slp (C) No.31131 of 2010),

                   Civil Appeal No.       1774     Of 2012
                 (Arising out of Slp (C) No.31134 of 2010),

                  Civil Appeal No.   1775          Of 2012
                 (Arising out of Slp (C) No.31304 of 2010),

                 Civil Appeal No.    1776            Of 2012
                 (Arising out of Slp (C) No.31385 of 2010),

                   Civil Appeal No.  1777          Of 2012
                 (Arising out of Slp (C) No.31450 of 2010),

                   Civil Appeal No.   1778         Of 2012
                 (Arising out of Slp (C) No.31849 of 2010),

                   Civil Appeal No.  1779          Of 2012
                 (Arising out of Slp (C) No.32531 of 2010),

                   Civil Appeal No.  1780          Of 2012
                 (Arising out of Slp (C) No.30628 of 2010),

                   Civil Appeal No.  1781          Of 2012
                 (Arising out of Slp (C) No.30635 of 2010),

                   Civil Appeal No.  1782          Of 2012
                 (Arising out of Slp (C) No.30646 of 2010),

                   Civil Appeal No.  1783          Of 2012
                 (Arising out of Slp (C) No.32532 of 2010),

                   Civil Appeal No.   1784         Of 2012
                 (Arising out of Slp (C) No.30647 of 2010),

                   Civil Appeal No.   1785         Of 2012
                 (Arising out of Slp (C) No.32533 of 2010),

                   Civil Appeal No.   1786         Of 2012
                 (Arising out of Slp (C) No.30653 of 2010),


                   Civil Appeal No.  1787          Of 2012
                 (Arising out of Slp (C) No.30673 of 2010),

                       Civil Appeal No.  1788  Of 2012
                 (Arising out of Slp (C) No.30674 of 2010),

                   Civil Appeal No.   1789         Of 2012
                 (Arising out of Slp (C) No.30675 of 2010),

                   Civil Appeal No.   1790         Of 2012
                 (Arising out of Slp (C) No.30677 of 2010),

                   Civil Appeal No. 1791           Of 2012
                 (Arising out of Slp (C) No.30686 of 2010),

                   Civil Appeal No.     1792       Of 2012
                 (Arising out of Slp (C) No.30708 of 2010),

                   Civil Appeal No.  1793          Of 2012
                 (Arising out of Slp (C) No.32534 of 2010),

                   Civil Appeal No.  1794          Of 2012
                 (Arising out of Slp (C) No.30906 of 2010),

                   Civil Appeal No.  1795          Of 2012
                 (Arising out of Slp (C) No.33218 of 2010),

                Civil Appeal Nos.     1796-1799       Of 2012
              (Arising out of Slp (C) Nos.34081-34084 of 2010),

                   Civil Appeal No.    1800        Of 2012
                 (Arising out of Slp (C) No.34078 of 2010),

                   Civil Appeal No.  1801          Of 2012
                 (Arising out of Slp (C) No.32228 of 2010),

                  Civil Appeal No.  1802           Of 2012
                 (Arising out of Slp (C) No.32256 of 2010),

                   Civil Appeal No.  1803          Of 2012
                 (Arising out of Slp (C) No.33925 of 2010),


                   Civil Appeal No.   1804         Of 2012
                 (Arising out of Slp (C) No.32308 of 2010),

                   Civil Appeal No.  1805          Of 2012
                 (Arising out of Slp (C) No.32339 of 2010),

                  Civil Appeal No.  1806           Of 2012
                 (Arising out of Slp (C) No.32384 of 2010),

                   Civil Appeal No.  1807          Of 2012
                 (Arising out of Slp (C) No.34046 of 2010),

                   Civil Appeal No.   1808         Of 2012
                 (Arising out of Slp (C) No.34047 of 2010),

                   Civil Appeal No.       1809     Of 2012
                 (Arising out of Slp (C) No.32946 of 2010),

                  Civil Appeal No.    1810          Of 2012
                 (Arising out of Slp (C) No.33708 of 2010),

                  Civil Appeal No.  1811           Of 2012
                 (Arising out of Slp (C) No.33692 of 2010),

                   Civil Appeal No.     1812       Of 2012
                 (Arising out of Slp (C) No.33084 of 2010),

                   Civil Appeal No.    1813        Of 2012
                 (Arising out of Slp (C) No.33157 of 2010),

                   Civil Appeal No.   1814         Of 2012
                 (Arising out of Slp (C) No.33265 of 2010),

                   Civil Appeal No.   1815         Of 2012
                 (Arising out of Slp (C) No.33504 of 2010),

                   Civil Appeal No.  1816          Of 2012
                 (Arising out of Slp (C) No.35013 of 2010),

                   Civil Appeal No.    1817        Of 2012
                 (Arising out of Slp (C) No.35016 of 2010),


                   Civil Appeal No.    1818        Of 2012
                 (Arising out of Slp (C) No.35028 of 2010),

                   Civil Appeal No.  1819          Of 2012
                 (Arising out of Slp (C) No.35029 of 2010),

                   Civil Appeal No.   1820         Of 2012
                 (Arising out of Slp (C) No.35030 of 2010),

                   Civil Appeal No.      1821      Of 2012
                 (Arising out of Slp (C) No.35031 of 2010),

                   Civil Appeal No.   1822         Of 2012
                 (Arising out of Slp (C) No.35032 of 2010),

                   Civil Appeal No.   1823         Of 2012
                 (Arising out of Slp (C) No.35129 of 2010),

                   Civil Appeal No.   1824         Of 2012
                 (Arising out of Slp (C) No.35865 of 2010),

                   Civil Appeal No.       1825     Of 2012
                 (Arising out of Slp (C) No.35866 of 2010),

                   Civil Appeal No.   1826         Of 2012
                 (Arising out of Slp (C) No.35867 of 2010),

                   Civil Appeal No.       1827     Of 2012
                 (Arising out of Slp (C) No.35868 of 2010),

                   Civil Appeal No.   1828         Of 2012
                 (Arising out of Slp (C) No.33644 of 2010),

                   Civil Appeal No.    1829        Of 2012
                   (Arising out of Slp (C) No.57 of 2011),
                   Civil Appeal No.  1830          Of 2012
                  (Arising out of Slp (C) No.136 of 2011),

                   Civil Appeal No.    1831        Of 2012
                  (Arising out of Slp (C) No.138 of 2011),


                   Civil Appeal No.   1832         Of 2012
                  (Arising out of Slp (C) No.131 of 2011),
                   Civil Appeal No.       1833     Of 2012
                  (Arising out of Slp (C) No.132 of 2011),
                   Civil Appeal No.    1834        Of 2012
                  (Arising out of Slp (C) No.376 of 2011),
                   Civil Appeal No.  1835          Of 2012
                  (Arising out of Slp (C) No.302 of 2011),
                   Civil Appeal No.    1836        Of 2012
                  (Arising out of Slp (C) No.428 of 2011),
                   Civil Appeal No.   1837         Of 2012
                  (Arising out of Slp (C) No.2755 of 2011),
                   Civil Appeal No.   1838         Of 2012
                  (Arising out of Slp (C) No.2756 of 2011),
                   Civil Appeal No.     1839       Of 2012
                  (Arising out of Slp (C) No.2757 of 2011),
                   Civil Appeal No.  1840          Of 2012
                  (Arising out of Slp (C) No.2759 of 2011),
                   Civil Appeal No.   1841         Of 2012
                  (Arising out of Slp (C) No. 2388 of 2011,
                   Civil Appeal No.   1842         Of 2012
                  (Arising out of Slp (C) No.2585 of 2011),
                   Civil Appeal No.   1843         Of 2012
                  (Arising out of Slp (C) No.2588 of 2011),
                   Civil Appeal No.   1844         Of 2012
                  (Arising out of Slp (C) No.2626 of 2011),
                   Civil Appeal No.   1845         Of 2012
                  (Arising out of Slp (C) No.2689 of 2011),
                   Civil Appeal No.  1846          Of 2012
                  (Arising out of Slp (C) No.2932 of 2011),

                    Civil Appeal No.    1847      Of 2012
                  (Arising out of Slp (C) No.2953 of 2011),
                   Civil Appeal No.   1848         Of 2012
                  (Arising out of Slp (C) No.2742 of 2011),
                   Civil Appeal No.   1850         Of 2012
                  (Arising out of Slp (C) No.2693 of 2011),
                   Civil Appeal No.   1851         Of 2012
                  (Arising out of Slp (C) No.5377 of 2011),
                   Civil Appeal No.  1852          Of 2012
                  (Arising out of Slp (C) No.5379 of 2011),
                   Civil Appeal No.   1853         Of 2012
                  (Arising out of Slp (C) No.5972 of 2011),
                   Civil Appeal No.  1854          Of 2012
                  (Arising out of Slp (C) No.7859 of 2011),
                Civil Appeal Nos.  1855-1856          Of 2012
               (Arising out of Slp (C) Nos.7868-7869 of 2011),
                   Civil Appeal No.   1858         Of 2012
                  (Arising out of Slp (C) No.8786 of 2011),
                   Civil Appeal No.  1859          Of 2012
                  (Arising out of Slp (C) No.9547 of 2011),
                   Civil Appeal No.  1860          Of 2012
                  (Arising out of Slp (C) No.9548 of 2011),
                   Civil Appeal No.  1861          Of 2012
                  (Arising out of Slp (C) No.9549 of 2011),
                   Civil Appeal No.   1862         Of 2012
                  (Arising out of Slp (C) No.9550 of 2011),
                   Civil Appeal No.   1863         Of 2012
                  (Arising out of Slp (C) No.9551 of 2011),
                   Civil Appeal No.  1864          Of 2012
                  (Arising out of Slp (C) No.7795 of 2011),
                   Civil Appeal No.  1865          Of 2012
                  (Arising out of Slp (C) No.9552 of 2011),
                   Civil Appeal No.   1866         Of 2012
                  (Arising out of Slp (C) No.9553 of 2011),
                   Civil Appeal No.   1867         Of 2012
                 (Arising out of Slp (C) No.11029 of 2011),
                   Civil Appeal No.   1868         Of 2012
                 (Arising out of Slp (C) No.10958 of 2011),
                   Civil Appeal No.  1869          Of 2012
                 (Arising out of Slp (C) No.13774 of 2011),
                   Civil Appeal No.  1870          Of 2012
                 (Arising out of Slp (C) No.11716 of 2011),
             Civil Appeal Nos.  1871-1872               Of 2012
              (Arising out of Slp (C) Nos.14068-14069 of 2011),
                   Civil Appeal No.  1873          Of 2012
                 (Arising out of Slp (C) No.14070 of 2011),
                   Civil Appeal No. 1874           Of 2012
                 (Arising out of Slp (C) No.14071 of 2011),
                   Civil Appeal No.    1875        Of 2012
                 (Arising out of Slp (C) No.14072 of 2011),
                   Civil Appeal No.  1876          Of 2012
                 (Arising out of Slp (C) No.14073 of 2011),
                   Civil Appeal No.   1877         Of 2012
                 (Arising out of Slp (C) No.14074 of 2011),
                   Civil Appeal No.  1878          Of 2012
                 (Arising out of Slp (C) No.14075 of 2011),
                   Civil Appeal No.  1879          Of 2012
                 (Arising out of Slp (C) No.14076 of 2011),
            Civil Appeal Nos.  1880-1881                  Of 2012
              (Arising out of Slp (C) Nos.14077-14078 of 2011),
            Civil Appeal Nos.  1882-1883                 Of 2012
              (Arising out of Slp (C) Nos.14079-14080 of 2011),
            Civil Appeal Nos.   1884-1885                Of 2012
              (Arising out of Slp (C) Nos.16937-16938 of 2011),
                   Civil Appeal No.  1886          Of 2012
                 (Arising out of Slp (C) No.16821 of 2011),
                   Civil Appeal No.  1887          Of 2012
                 (Arising out of Slp (C) No.16822 of 2011),
                   Civil Appeal No.    1888        Of 2012
                 (Arising out of Slp (C) No.16823 of 2011),
                   Civil Appeal No.   1889         Of 2012
                 (Arising out of Slp (C) No.16824 of 2011),
                   Civil Appeal No.   1890         Of 2012
                 (Arising out of Slp (C) No.16825 of 2011),
                   Civil Appeal No.  1891          Of 2012
                 (Arising out of Slp (C) No.15474 of 2011),
                   Civil Appeal No.  1892          Of 2012
                 (Arising out of Slp (C) No.16968 of 2011),
                   Civil Appeal No.  1893          Of 2012
                 (Arising out of Slp (C) No.16969 of 2011),
                   Civil Appeal No.  1894          Of 2012
                 (Arising out of Slp (C) No.17643 of 2011),
                   Civil Appeal No.   1895         Of 2012
                 (Arising out of Slp (C) No.16505 of 2011),
                   Civil Appeal No.   1896         Of 2012
                 (Arising out of Slp (C) No.17645 of 2011),
                   Civil Appeal No.   1897         Of 2012
                 (Arising out of Slp (C) No.17644 of 2011),
                   Civil Appeal No.  1898          Of 2012
                  (Arising out of Slp (C) No.16695 of 2011)
                   Civil Appeal No.     1899       Of 2012
                 (Arising out of Slp (C) No.22460 of 2011),
                   Civil Appeal No.   1900         Of 2012
                 (Arising out of Slp (C) No.22180 of 2011),
                   Civil Appeal No.   1901         Of 2012
                 (Arising out of Slp (C) No.22446 of 2011),
                   Civil Appeal No.    1902        Of 2012
                 (Arising out of Slp (C) No.22449 of 2011),
                   Civil Appeal No.   1903         Of 2012
                 (Arising out of Slp (C) No.22447 of 2011),
                   Civil Appeal No.  1904          Of 2012
                 (Arising out of Slp (C) No.22772 of 2011),


                   Civil Appeal No.  1905          Of 2012
                 (Arising out of Slp (C) No.26556 of 2011),
                   Civil Appeal No.   1906         Of 2012
                 (Arising out of Slp (C) No.27677 of 2011),
                   Civil Appeal No.   1907         Of 2012
                 (Arising out of Slp (C) No.28775 of 2011),
                   Civil Appeal No.  1908          Of 2012
                 (Arising out of Slp (C) No.27044 of 2011),
                   Civil Appeal No.   1909         Of 2012
                 (Arising out of Slp (C) No.27048 of 2011),
                   Civil Appeal No.  1910          Of 2012
                 (Arising out of Slp (C) No.28776 of 2011),
                   Civil Appeal No.   1911         Of 2012
                 (Arising out of Slp (C) No.28067 of 2011),
                   Civil Appeal No.   1912         Of 2012
                  (Arising out of Slp (C) No.28607 of 2011)
                                     And

                   Civil Appeal No.  1913          Of 2012
                  (Arising out of Slp (C) No.29542 of 2011)



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