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Point of taxation - Controversies galore!


Rule 5B and Section 67A operated simultaneously

It is interesting to note that Rule 5B of STR was omitted from 01.07.2012 and Sec. 67A was introduced from 28.05.2012. Between 28.05.2012 to 30.06.2012, both Rule 5B and Sec 67A were in operation. Obviously sec will prevail over rule and to that extent deeming fiction in the rule is not ultravires.

Ravi Raghavan 16/06/2015

 

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