2006 (7) TMI 124

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....e Department  Mr. S.D. Kapila  Present for the Applicant  Shri P. Mukherjee, ACA  RULING ORDER (By Mr. Justice Syed Shah Mohammed Quadri) - The applicant is an Indian company. It is engaged in the business of management of sports events. On the assertion that it entered into an agreement with M/s Taj Television Ltd. PO Box 502018, Dubai Media City, Dubai, UAE ....

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....11.2005 it became necessary to call for a copy of the UAE Tax Decree and the certificate of incorporation of M/s Taj Television Ltd. in Dubai. At that stage the applicant has come forward with the present petition under Rule 20 of the Authority for Advance Rulings (Procedure) Rules, 1996 (for short "the Rules") for amendment of records. 3. It is stated in the application, inter alia, that the R....

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.... applicant, strenuously contends that by substituting the name of the Taj TV Ltd. Mauritius for Taj Television Ltd. Dubai the facts will not be altered; indeed only the third question may not arise from the agreement, therefore he would give up that question. Mr. S.D. Kapila, the learned counsel for the Revenue, on the other hand, invited our attention to the agreement between the applicant and th....

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.... or material error in the records the same shall be amended after hearing the applicant and the Commissioner. A perusal of the Rule 20 of the Rules shows that what is permitted to be amended by way of amendment of records is any factual or material error and such a amendment can be made at any stage of the proceedings before the Authority. The real question, therefore, is whether on the facts a....