https://www.taxtmi.com/caselaws?id=245164 The Tribunal dismissed both the Revenue's and the assessee's appeals. The CIT (Appeals)'s decision to delete the addition of Rs. 4,07,92,581/- was upheld, while the disallowance of Rs. 25,85,419/- was confirmed. The Tribunal emphasized the rule of consistency and the lack of new facts or circumstances to take a different stand. The Tribunal also held that the duty to deduct tax at source does not arise unless the remittance contains taxable income, and Circular No. 715 dated 8.8.1995 was not applicable to the present case. en-us Fri, 14 Mar 2014 00:00:00 +0530 Fri, 21 Mar 2014 14:41:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245164 The Tribunal dismissed both the Revenue's and the assessee's appeals. The CIT (Appeals)'s decision to delete the addition of Rs. 4,07,92,581/- was upheld, while the disallowance of Rs. 25,85,419/- was confirmed. The Tribunal emphasized the rule of consistency and the lack of new facts or circumstances to take a different stand. The Tribunal also held that the duty to deduct tax at source does not arise unless the remittance contains taxable income, and Circular No. 715 dated 8.8.1995 was not applicable to the present case. Case-Laws Income Tax Fri, 14 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245164