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TMI Blog2017 (8) TMI 78X X X X Extracts X X X X X X X X Extracts X X X X ..... ing whether the assessee entered into the same on its own account and for and on behalf of itself or whether it did so as a nodal agency for and on behalf of the Government of Punjab. That contract has not even been produced before us. Further the matter may not end by a mere reading of the contract. It may be necessary to consider the surrounding circumstances if the terms thereof are not clear. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... order of the Commissioner of Income-tax (Appeals) pertaining to the assessment years 2009-10 to 2011-12. 2. The question of law raised by the appellant is irrelevant. It is probably on account of having copied the question of law from certain other appeals which we in fact disposed of by a separate order and judgment passed today. The question of law that arises in these appeals is as follows : ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... overnment of Punjab. The assessee also raised an alternate contention that even assuming that the provisions of section 206C(1C) are applicable, it is not liable under the provisions thereof on account of the concessionaire having paid the taxes after having taking into account, the amounts payable by it to the assessee. In these appeals, the Commissioner of Income-tax (Appeals) and the Tribunal h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sons. 6. The construction/interpretation of the contract referred to by the parties as concessionaire agreement would be of vital importance in ascertaining whether the assessee entered into the same on its own account and for and on behalf of itself or whether it did so as a nodal agency for and on behalf of the Government of Punjab. That contract has not even been produced before us. Further ..... X X X X Extracts X X X X X X X X Extracts X X X X
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