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2022 (3) TMI 1400 - AT - Income TaxNon accounting income - amount collected from punters for disbursement as dividend to punters stands diverted at source by virtue of overriding title - disallowance made by assessing officer by invoking the provisions of section 40A[3] - Treating the total receipts to be application of money as against diversion at source by overriding title as considered by the assessee - issue challenging the decision of the CIT(A) in treating the total receipts to be application of money as against diversion at source by overriding title as considered by the assessee - HELD THAT:- We remand these issues back to the Ld.AO to consider the submissions of assessee de novo in light of the Rules of Betting and the principles laid down by various Hon’ble Courts.
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