TMI Blog2016 (2) TMI 692X X X X Extracts X X X X X X X X Extracts X X X X ..... 8.11.2011 and has been filing the Income Tax as well as Service Tax Returns from time to time during all these years. According to the Department, therefore, this is not a proposed activity. The second objection raised by the Revenue is that there is a sister concern of the applicant which shares with the applicant an e-mail addresses as also the postal address and in case of that concern, some or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as raised the questions in respect of the 'proposed services' that the applicant proposes to offer to its foreign clients. Those services will be regarding the analysis of the drugs and market survey etc. 2. The Revenue takes objection to the admissibility on the ground that it is not a proposed activity as covered under Section 96(D), since the company is incorporated on 18.11.2011 and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Income Tax Authorities, it is showing zero income meaning thereby that the applicant had not commenced any activity whatsoever. The applicant has also come out with the copies of the Returns and a clear-cut statement in reply to the Department's objections to this effect. 4. As regards the other objection regarding sister concern, the learned counsel relies on the Gujarat High Court Jud ..... X X X X Extracts X X X X X X X X Extracts X X X X
|