9911796707
TMI Blog1977 (8) TMI 84X X X X Extracts X X X X X X X X Extracts X X X X ..... nwar Singh took excise contract of deshi liquor for Bhadra for the period 1st May, 1972 to 31st March, 1973. Shri Alisher had no finances and as such he entered into sub-partnership agreement with Shaffi Mohd., contractor. According to the agreement Shaffi Mohd. was to provide necessary finance for and on behalf of Shri Alisher. In consideration of his doing so, the said Shaffi Mohd. was to be pai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income of the original firm has been taxed, the share will be taxed in the hands of the partner and not again the hands of the sub-partnership. Taxing the share from the original firm in the hands of the sub-partnership, it will be double taxation. Accordingly, the tax levied on this sub-partnership firm is not justified. The ITO can only tax the share income which is 50 per cent each in case of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed the material available on record. Sri Alisher and Sri Bhanwar Singh entered into partnership. They took contract of liquor. After the completion of the contract, the assessment of the main firm was completed. The share income of both the partners were determined and the firm paid tax as required under the Act. Sri Alisher was not financially sound. As such he entered into sub-partnership with S ..... X X X X Extracts X X X X X X X X Extracts X X X X
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