2006 (8) TMI 178

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....ed by M. M. Kumar J.- This order shall dispose of six appeals, namely, ITA Nos. 608 to 613 of 2006. All these appeals emerge from common order dated July 14, 2006, passed by the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar, in ITA No. 14 (ASR)/2006 to ITA No. 19 (ASR)/2006 in respect of the assessment years 1999-2000 to 2004-05. Even the assessee in all these appeals is common, namel....

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....vidual investment for the respective properties were duly reflected in the hands of the individual/co-owners. The rental income from these properties have never been assessed in the hands of the "AOP". The contention of the Revenue that the asses-see is covered by section 194-I(b) of the Act for the purposes of deduction of tax at source on the premise that the rent is not paid to an individual or....

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....s placed reliance on two judgments of the Madhya Pradesh High Court in the case of CIT v. M. P. Agro Morarji Fertilizers Ltd. [1989] 176 ITR 282 and CIT v. Life Insurance Corporation [1987] 166 ITR 191. The Tribunal has also placed reliance on the judgment of the Bombay High Court in the case of CIT v. Mahindra and Mahindra Ltd. [2000] 242 ITR (St.) 187. 3. After hearing learned counsel, we fin....