2012 (11) TMI 1349

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....J. Pardiwala, Sr. Advocate with Mr. Sameer Chitnis i/by Crawford Bayley & Co. PC: Three questions of law are raised by the revenue read thus:- a) Whether on the facts and circumstances of the case and in law, the ITAT was right in directing the Assessing Officer to delete the addition made of Rs. 3,06,41,744/- computed at the rate of 2.09% of the turnover of Rs. 1,46,61,12....

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.... continued during the year under consideration and the activity of construction site would have continued for more than 6 months c) Whether on the facts and in the circumstances of the case and in law the Tribunal was right in holding that the assessee being a non resident, the entire income of the assessee was not subject to TDS u/s. 195 of the Income Tax Act, 1961 and no liability u/s. ....