M/S SHREE BALAJI CONCEPTS,MARGAO vs. INCOME TAX OFFICER (INTERNATIONAL TXATION), WARD -1, PANAJI
The appeal of the assessee is allowed in the terms indicated as above
ITA 73/PAN/2018[2012-13]Status: DisposedITAT Panaji13 May 2022AY 2012-13
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 73/Pan/2018 Assessment Year: 2012-13
For Appellant: Shri M. R. Hegde, CA &For Respondent: Smt. Rijula Uniyal, Sr. DR
Section 156Section 191Section 195Section 201Section 201(1)Section 205
u/s 195(2) and 195(3) and procedure for assessment persuade us to say that certainly the rights as available to the payee to defend itself in an income tax assessment proceedings are not available to the assessee as payer in equal force. The learned Counsel for the Revenue has rightly pointed that provisions of DTAA would not automatically attract