https://www.taxtmi.com/caselaws?id=19605 The Income-tax Appellate Tribunal (ITAT) held that consultancy fees accrued only upon repatriation to India in the assessment year 1988-89, not during the remittance periods stated in agreements. The Tribunal's interpretation of agreements and letters indicated that the fee's accrual was contingent on repatriation. Rule 115 was deemed inapplicable, and the ITAT found due enquiry had been made into share application money and interest on London bank deposits. The Commissioner of Income-tax's jurisdiction under section 263 was acknowledged, with assessments to be reframed but without foreclosing further enquiry. The High Court directed specific questions for the Tribunal's opinion and awarded costs to the Revenue. en-us Mon, 23 May 1994 00:00:00 +0530 Sat, 07 Nov 2009 12:35:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19605 The Income-tax Appellate Tribunal (ITAT) held that consultancy fees accrued only upon repatriation to India in the assessment year 1988-89, not during the remittance periods stated in agreements. The Tribunal's interpretation of agreements and letters indicated that the fee's accrual was contingent on repatriation. Rule 115 was deemed inapplicable, and the ITAT found due enquiry had been made into share application money and interest on London bank deposits. The Commissioner of Income-tax's jurisdiction under section 263 was acknowledged, with assessments to be reframed but without foreclosing further enquiry. The High Court directed specific questions for the Tribunal's opinion and awarded costs to the Revenue. Case-Laws Income Tax Mon, 23 May 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19605