In the result, the ITA No
Bench: Shri George Mathan & Shri Inturi Rama Rao
section 167B only will be applicable in the appellant’s case. 3.4 The CIT (Appeals) has also failed to consider the submissions made by the Appellant with respect to the amounts transferred to the members of the AOP over the years, wherein also the determinate share of profits of the members of the AOP are clearly established. 4. The Appellant