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    <title>2019 (1) TMI 888 - BOMBAY HIGH COURT</title>
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    <description>The High Court dismissed the tax appeal as both issues regarding the allowance of foreign commission expense and treatment of sale of shares were factually determined by the CIT(A) and Tribunal, with no legal grounds for challenge. The Tribunal found evidence supporting the foreign commission expense and deemed the foreign agents to have been involved in sales procurement. Regarding the sale of shares, no colorable device was detected, and an independent valuer assessed the shares as &#039;Nil&#039; before the sale due to the company&#039;s status as a sick undertaking.</description>
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      <description>The High Court dismissed the tax appeal as both issues regarding the allowance of foreign commission expense and treatment of sale of shares were factually determined by the CIT(A) and Tribunal, with no legal grounds for challenge. The Tribunal found evidence supporting the foreign commission expense and deemed the foreign agents to have been involved in sales procurement. Regarding the sale of shares, no colorable device was detected, and an independent valuer assessed the shares as &#039;Nil&#039; before the sale due to the company&#039;s status as a sick undertaking.</description>
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