Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
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The issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
The issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
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