2019 (6) TMI 1101

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.....B.PARDIWALA) This Tax Appeal is admitted on the following substantial questions of law: "[A] Whether on the facts and in the circumstances of the case and in law, the Appellate Tribunal is right in dismissing the appeal of the Revenue without appreciating the fact that Section 201(3) of the Act was amended by the Finance Act, 2012 with retrospective effect from 01/04/2010 whereby the limitat....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....pany during the period under consideration, which was constituted as deemed dividend u/s. 2(22)(e) of the Act. [C] Whether on the facts and in the circumstances of the case and in law, the Appellate Tribunal is right in dismissing the appeal of the Revenue without appreciating the fact that the assessee had not deducted the tax at source as required under the provisions of Section 194 of the Ac....