Assessee not required to inform ITO as to what legal inference should be drawn from facts disclosed by him

IN THE ITAT MUMBAI BENCH ‘L’ Calyon Bank Versus Deputy Director of Income-tax (International Taxation) IT APPEAL NOS. 4294 (MUM.) OF 2005 and 5030 & 5145 (MUM.) OF 2006 [ASSESSMENT YEARs 1993-94 & 1997-98] SEPTEMBER 21, 2012 ORDER Amit Shukla, Judicial Member For the assessment year 1997-98, cross appeals have been filed against the impugned order dated 26th June 2006, passed by the learned Commissioner (Appeals)-XXXI, Mumbai, for the quantum of assessment under section 143(3) r/w 147 of the Income Tax Act, 1961 (for short “the Act”). For the ...