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2014 (7) TMI 93

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....ENT:- PC: These income tax appeals are directed against the order dated 29.03.2007 passed by Income Tax Appellate Tribunal (for short 'the Tribunal') in ITA Nos. 1.094-1096/Bang/2006 pertaining to the Assessment years 2002-03 to 2004-05 whereby the Tribunal allowed all three appeals preferred by the respondent-assessee. 2. The revenue, in these appeals, has raised the following substant....

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....ies (for short "the Rules ). 4. Learned counsel appearing for the assessee fairly submits that it is not clear how many advertising agencies were in fact registered with the INS as contemplated under the said Rules. He submits that some of the advertising agencies were admittedly not registered with the INS. Though he could not give us the break-up, he submits that with all such advertising agenc....

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....gistered with INS, were to be governed by the terms and conditions stipulated in the agreements executed between such agencies and the respondent-assessee, and in which case the question of looking into format agreement (Appendix-IV) would not arise. 6. We are of the opinion that in all the cases, the substantial question of law, as formulated in the memorandum of appeals, will have to be address....

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....096/Bang/2006 are restored to file.      ii.  Tribunal shall consider the appeals afresh in the light of the observations made in this order and so also in the light of the judgments relied upon by the parties, and in particular the Judgment of the Allahabad High Court in Jagran Prakashan Ltd. v. Dy. CIT (TDS) [2012] 345 ITR 288(All). We, however, make it clear that, we h....