TMI Blog2018 (4) TMI 1369X X X X Extracts X X X X X X X X Extracts X X X X ..... OURT] as held the assessees have various avathars in various establishments - each of the unit has different composition. Each unit has varied number of members. Under such circumstances, the acceptability of the finding given by the Income Tax Appellate Tribunal has to be considered that the amounts paid by the company towards personal expenses of the assessee cannot be taxed in its hands under S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee? 2.Whether on the facts and circumstances of the case, the Tribunal was right in remanding the matter back to the assessing officer on the issue of receipt of commission, when the entity which is supposed to have received the commission was formed only after the survey was conducted. 3. In respect of identical issue in the case of other related assessees, the Revenue challenged th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that it is a case to be investigated by the Assessing Officer. It is also relevant to point out that the assessee in all these cases did not file any return in their individual capacity and notices under Section 147 were issued only on the ground that they did not file any return disclosing the perquisites and benefits received by them from the company and that they are guilty of omission to file ..... X X X X Extracts X X X X X X X X Extracts X X X X
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