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    <title>2006 (1) TMI 547 - ITAT MUMBAI</title>
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    <description>The 3 March 1987 CBDT settlement for non-resident film distribution companies provided a presumptive tax basis of 25% of gross film receipts, and the Department had long continued to assess member companies on that basis. Despite later clarification that the settlement was intended for pending assessments up to 31 March 1987, the Tribunal noted repeated acceptance of the same method in earlier cases and the absence of any workable alternative. Applying the rule of consistency, it treated the settlement as applicable to assessment years after 1987-88 and rejected the Revenue&#039;s attempt to depart from that method by mere estimation.</description>
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    <pubDate>Fri, 20 Jan 2006 00:00:00 +0530</pubDate>
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      <title>2006 (1) TMI 547 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=151808</link>
      <description>The 3 March 1987 CBDT settlement for non-resident film distribution companies provided a presumptive tax basis of 25% of gross film receipts, and the Department had long continued to assess member companies on that basis. Despite later clarification that the settlement was intended for pending assessments up to 31 March 1987, the Tribunal noted repeated acceptance of the same method in earlier cases and the absence of any workable alternative. Applying the rule of consistency, it treated the settlement as applicable to assessment years after 1987-88 and rejected the Revenue&#039;s attempt to depart from that method by mere estimation.</description>
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      <pubDate>Fri, 20 Jan 2006 00:00:00 +0530</pubDate>
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