said to be linked when these
transactions emanate from a common source being an order or a contract or an
agreement or an arrangement ... terms of these
transactions are substantially flowing from the said common source. For example, a
master purchase order is issued stating the various terms
closely linked', if they emanate
from a common source, being an order or contract or an agreement or
an arrangement, and the nature, characteristic ... terms of such
transactions substantially flow from the said common source. The
following extract from the said Guidance Notes is worthy of notice
said to be linked when these transactions
emanate from a common source being an order or a
contract or an agreement or an arrangement ... terms of these transactions
are substantially flowing from the said common
source. For example, a master purchase order is
issued stating the various terms
said to be „closely linked‟,
if they emanate from a common source, being an order or contract or an
agreement or an arrangement ... characteristic and terms of
such transactions substantially flow from the said common source. The
following extract from the said Guidance Notes is worthy of notice
closely linked', if they emanate from a common source, being
an order or contract or an agreement or an arrangement, and the
nature, characteristic ... terms of such transactions
substantially flow from the said common source. The following
extract from the said Guidance Notes is worthy of notice
accepted
by Shivaji Chumble. Moreover, there appears to be a common
source of fund. Thus, according to the AO the assessee is solely
and completely ... where the AO has observed that there appears to be a
common source of funds and that the assessee himself has
admitted that this business
closely linked', if they emanate
from a common source, being an order or contract or an agreement or an
arrangement, and the nature, characteristic ... terms of such transactions
substantially flow from the said common source. The following extract from the
said Guidance Notes is worthy of notice
cases.
For common Management: Facts, documents
and statements establish that all units were
controlled by Sh. Gaurav Gupta.
34
There is common source of procurement ... like bills were raised on
different entities and documents/statement
proves common source of procurement and all
activities were controlled by Sh. Gaurav
Gupta;
There
promoter group entity, Scimitar and presence of a common broker and a common source of funds for trading can not be overlooked as a matter
basis of gross receipts from both the sources. The method of distribution of common expenses would vary depending upon the facts of each case. Recently ... approved the method of apportionment of common expenses between the exempt and taxable sources of income on the basis of gross receipts of these
