2016 (11) TMI 1019

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....ppeal, the appellant has challenged the judgment and order of the Tribunal whereby the Tribunal has allowed the appeal of the assessee and quashed the order of CIT under Section 263 of the Act. 2. Learned counsel for the appellant has raised the following substantial questions of law: "(i) Whether the Tribunal was legally justified in quashing the order of the CIT passed u/s 263 specif....

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.... find merit in the argument of the ld. Counsel for the assessee that M/s. BPCL awarded contract to the assessee subject to arrangement of dedicated tanker for supply of petroleum products. This was arranged by the assessee by way of a tanker owned by associate concern. BPCL paid the transportation to assessee which is credited by it in the a/c of AKHK only and TDS is claimed by it as per certifica....