Section 67A and Point of Taxation Rules

As rightly pointed out by the author, Section 67A and the POT Rules seem to be travelling in opposite directions. Since Section 67A was introduced later, one would have expected the Government to effect suitable amendments in Rule 4, but as usual, the Babus are in a state of slumber.

If the assessee would be benefited by the Rule 4, he can still take the benefit under Rule 4 despite that, it contradicts Section 67A.

The assessee cannot be faulted for the Government not amending Rule 4 of POT Rules, after the introduction of Section 67A.

S Sivakumar, Advocate, Bangalore

SUBRAMANI SIVAKUMAR 11/07/2015