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Assessees can change their stance on receipt taxability at Tribunal if all facts are documented.

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Full Text of the Document

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....The assessee can change its stand at any point of time if it seems to him that the receipts are not taxable in his hand as per the provisions of law. - Assessee may raise that question before the Tribunal for the first time, so long as the relevant facts are on record in respect of that item.....