2017 (8) TMI 78

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....yal, Senior Standing Counsel For the Respondent : Deepak Aggarwal, Advocate JUDGMENT S. J. Vazifdar, CJ. 1. These appeals are filed against the order of the Tribunal dismissing the Revenue's appeals against the order of the Commissioner of Income-tax (Appeals) pertaining to the assessment years 2009-10 to 2011-12. 2. The question of law raised by the appellant is irrelevant. It ....

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....er was to build, operate and transfer roads. 4. The Revenue contends that the agreements were entered into by the assessee on its own behalf whereas the assessee contends that it is only a nodal agency for and on behalf of the Government of Punjab. The assessee also raised an alternate contention that even assuming that the provisions of section 206C(1C) are applicable, it is not liable under t....

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....oncession fee and not as a toll fee and that, therefore, the provisions of section 206C(7) could not be applied to the amount received. The Tribunal also upheld the order of the Commissioner of Income-tax without furnishing any reasons. 6. The construction/interpretation of the contract referred to by the parties as concessionaire agreement would be of vital importance in ascertaining whether t....