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2017 (8) TMI 78 - PUNJAB AND HARYANA HIGH COURTProvisions of section 206C(1C) - liability to collect tax at source as provided - Held that:- The construction/interpretation of the contract referred to by the parties as concessionaire agreement would be of vital importance in ascertaining whether the assessee entered into the same on its own account and for and on behalf of itself or whether it did so as a nodal agency for and on behalf of the Government of Punjab. That contract has not even been produced before us. Further the matter may not end by a mere reading of the contract. It may be necessary to consider the surrounding circumstances if the terms thereof are not clear. It is impossible, therefore, in these appeals to determine the issue. We have decided the alternate issue in certain other appeals against the assessee by a separate order and judgment passed by us in (CIT (TDS) v. Punjab Infrastructure Development Board [2016 (12) TMI 1534 - PUNJAB AND HARYANA HIGH COURT] which is also the assessee's case. It would, however, be necessary for the Tribunal to decide both the issues.
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