https://www.taxtmi.com/caselaws?id=11561 The court ruled that the inclusion of tax paid on behalf of the assessee by way of rectification was not within the jurisdiction of section 154 as it was a debatable issue. The Tribunal was justified in not admitting additional evidence not raised before lower authorities. Only 10 percent of the tax liability of the non-resident assessee paid by the ONGC could be taxed under section 44BB. The court discharged the rules and rejected the application under section 256(2) based on these findings. en-us Wed, 17 Sep 1997 00:00:00 +0530 Sat, 30 Jan 2010 12:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11561 The court ruled that the inclusion of tax paid on behalf of the assessee by way of rectification was not within the jurisdiction of section 154 as it was a debatable issue. The Tribunal was justified in not admitting additional evidence not raised before lower authorities. Only 10 percent of the tax liability of the non-resident assessee paid by the ONGC could be taxed under section 44BB. The court discharged the rules and rejected the application under section 256(2) based on these findings. Case-Laws Income Tax Wed, 17 Sep 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11561