TMI Blog2019 (3) TMI 584X X X X Extracts X X X X X X X X Extracts X X X X ..... under Section 260A of the Income Tax Act, 1961 (Act) challenges the order dated 01/12/2015 passed by the Income Tax Appellate Tribunal ("the Tribunal" for short). This Appeal relates to Assessment Year 2006-2007. 2. Although multiple questions have been raised in the memo of appeal, the essence of these questions is in the following question pressed by the Revenue : "Whether, on the facts and c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... retirement from the said partnership firm M/s. D. S. Corporation. 4. Being aggrieved, the Respondent filed an Appeal to the Commissioner of Income Tax (Appeals) ("CIT(A)" for short), but without success. 5. On further appeal by the Respondent, the Tribunal by the impugned order noted the fact that in view of Section 45(4) of the Act the amounts received by a partner on his retirement from a part ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rtner on 06/09/2005 in the previous year relevant to the subject Assessment Year and during the same Assessment Year i.e. on 27/03/2006 the Respondent retired from the firm and received a sum of Rs. 30.87 crores on her retirement. In these facts it is submitted that the Respondent is liable to pay the tax on the amounts received by her on her retirement from the partnership firm. 6. We find that ..... X X X X Extracts X X X X X X X X Extracts X X X X
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