The writ petitions are disposed of setting aside the aforesaid impugned orders leaving it open for the respondents to initiate fresh proceedings, for each assessment year separately

The tribunal noted that the CIT(A) had not verified whether the service tax was actually received or routed through accounts and had not obtained a remand report from the AO

These doctors themselves also do not treat the remuneration received from the Assessee Hospital as a salary, as contended by the Assessing Officer