2012 (11) TMI 1355

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..... Pardiwala, Sr.Advocate with Mr. Sameer Chitnis i/by Crawford Bayley & Co. PC: Three questions of law are raised by the revenue in this appeal read thus: a) Whether on the facts and in the circumstances of the case and in law the Tribunal was right in directing the A.O. to delete the addition made of Rs.49,26,023/- computed @ 5% of the turnover of Rs. 9,85,28,40,467/- arising from ....

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....e year under consideration and the activity of consideration 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. 234B would arise ig....