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2008 (6) TMI 205 - KERALA HIGH COURTAssociation of persons - During search, statements were recorded under Section 132 (4) of the I.T. Act. From the seized records it was found that these two persons were engaged in contract work for slaughter tapping and sale of rubber trees from two rubber estates - When Section 147 notice was issued for making income escaping assessment in the hands of association of persons constituting T George and M. Syed Alavi, both of them filed individual returns denying existence of association of persons. Therefore separate assessments were made as protective measure in the hands of both the persons – Before CIT(A) they claimed the existence of AOP – CIT(A) assessed in the hand of AOP – ITAT reversed the order of CIT(A) - held that – AOP was inexistence – Agreement is not required to proved AOP – ITAT order reversed – Assessment to be made in the hands of AOP
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