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    <title>1964 (10) TMI 1 - GUJARAT High Court</title>
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    <description>The Tribunal&#039;s power in an assessee&#039;s appeal is confined to the subject-matter of the appeal, and section 33(4) does not permit an adverse enhancement of liability without a Revenue appeal; section 33(5) is only consequential and cannot independently bring to tax in the partner&#039;s hands an amount earlier assessable only for rate purposes. On the evidentiary issue, a finding that the assessee&#039;s sixty per cent share of Kano firm profits was income from business controlled in India was supported by circumstantial evidence, including the assessee&#039;s residence, purchases made through India, and his connection with the purchasing concern. The text states that the first point favoured the assessee, while the second did not.</description>
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    <pubDate>Tue, 20 Oct 1964 00:00:00 +0530</pubDate>
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      <title>1964 (10) TMI 1 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6616</link>
      <description>The Tribunal&#039;s power in an assessee&#039;s appeal is confined to the subject-matter of the appeal, and section 33(4) does not permit an adverse enhancement of liability without a Revenue appeal; section 33(5) is only consequential and cannot independently bring to tax in the partner&#039;s hands an amount earlier assessable only for rate purposes. On the evidentiary issue, a finding that the assessee&#039;s sixty per cent share of Kano firm profits was income from business controlled in India was supported by circumstantial evidence, including the assessee&#039;s residence, purchases made through India, and his connection with the purchasing concern. The text states that the first point favoured the assessee, while the second did not.</description>
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      <pubDate>Tue, 20 Oct 1964 00:00:00 +0530</pubDate>
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