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    <title>1976 (10) TMI 18 - MADRAS High Court</title>
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    <description>On identical facts, a Tribunal cannot treat cross-gift transactions as genuine where an earlier Bench of the same Tribunal had already found the same arrangement to be a sham. The Court noted that the later Tribunal identified no new material and did not show that the earlier facts had been overlooked, so its contrary conclusion was unsustainable in the interests of consistency and institutional integrity. The Tribunal was therefore wrong in holding the gifts to be real, and the question was answered against the assessee and in favour of the revenue. The connected question, which assumed the gifts were real, became unnecessary and was left unanswered.</description>
    <language>en-us</language>
    <pubDate>Tue, 26 Oct 1976 00:00:00 +0530</pubDate>
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      <title>1976 (10) TMI 18 - MADRAS High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=38672</link>
      <description>On identical facts, a Tribunal cannot treat cross-gift transactions as genuine where an earlier Bench of the same Tribunal had already found the same arrangement to be a sham. The Court noted that the later Tribunal identified no new material and did not show that the earlier facts had been overlooked, so its contrary conclusion was unsustainable in the interests of consistency and institutional integrity. The Tribunal was therefore wrong in holding the gifts to be real, and the question was answered against the assessee and in favour of the revenue. The connected question, which assumed the gifts were real, became unnecessary and was left unanswered.</description>
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      <pubDate>Tue, 26 Oct 1976 00:00:00 +0530</pubDate>
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