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TMI Blog2019 (12) TMI 1316X X X X Extracts X X X X X X X X Extracts X X X X ..... tion of the materials placed before the authority or upon consideration of the rival submissions. It shall be open to the AO and the other statutory authorities to arrive at their own findings upon appreciation of the evidence and the materials placed on record and they should be not bound by the prima facie findings. While so observing, we also make it clear that we have not ourselves examined ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y adjournments. - W.P.(C) 13401/2019 and W.P.(C) 13405/2019 - - - Dated:- 19-12-2019 - HON'BLE MR. JUSTICE VIPIN SANGHI HON'BLE MR. JUSTICE SANJEEV NARULA Petitioner Through: Mr. Arvind Datar, Sr. Adv. with Mr.Atul Shankar Mathur, Mr. Prabal Mehrotra and Mr.Swapnil Tripathi, Advs. Respondents Through: Ms. Sunny Shangloo, Govt. Pleader with Mr. Shubham Gandhi, Adv. Mr. Ruchi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mpugned order dated 10.10.2019 by the Authority for Advance Ruling (Income Tax) in AAR 1373 and 1374 of 2012 , the Assessing Officer (AO) has issued notices dated 23.10.2019 and 05.12.2019 for the purpose of carrying out the assessment. He submits that that the petitioner is willing to join the assessment proceedings. He, however, expresses an apprehension that the AO would feel bound by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... said prima facie findings returned by the authority on the aspect of the tax avoidance. 7. Mr. Datar, submits that the issue that remains to be determined is whether the petitioner would be entitled to the benefit of the Indian-Mauritius Double Taxation Avoidance Treaty, and consequently to refund of tax deducted and paid by the purchaser of the shares in the year 2011. He, therefore, submits ..... X X X X Extracts X X X X X X X X Extracts X X X X
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