2021 (2) TMI 1351

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....nil Kumar Pandey, DR ORDER PER BENCH This assessee's appeal for A.Y. 2014-15 is directed against the Commissioner of Income Tax (Appeals)-10 ['CIT(A)' for short], Hyderabad's order dated 19.04.2018 in case no. 0202/2016-17, involving proceedings u/s 143(3) of the Income Tax Act, 1961 [ 'the Act' for short]. Heard both parties. Case file perused. 2. It transpired at the outset that t....

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....f shall render the statutory provisions itself as redundant. We find no merit in Revenue's foregoing stand. Various judicial precedents hon'ble Bombay high court in CIT vs. Avtar Singh Wadhwan reported in 247 ITR 260 (Bom.) ; DIT vs. Prahlad V Rao 198 taxman 551 (Kar) and Utanka Roy vs. DIT WP no.369/2014 dated 15.12.2016 (Calcutta HC) hold that such an income derived by a non- resident for perfor....