Revenue not permitted to take a contradictory stand before HC

CIT Vs Bangalore Metro Rail Corporation Ltd. (Karnataka High Court)

Specific case of the Revenue before the ITAT is that the Contract is a composite one. Shri. Chaitanya is right in his submission that the dominant purpose of the Contract is supply of the passenger rolling stock. Thus, having taken a specific stand before the ITAT that the Contracts is a composite one, the Revenue cannot be permitted to take a contradictory stand before this Court. In ONGC Ltd. cited by Shri. Chaitanya, it is held as follows:

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