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    <title>2024 (6) TMI 68 - ITAT DELHI</title>
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    <description>ITAT Delhi allowed assessee&#039;s appeal on multiple grounds. Regarding royalty payment disallowance, the tribunal ruled in favor of assessee citing Delhi HC precedent, noting genuine agreement with unrelated party MPL for trademark use with sales-linked royalty. For TDS on commission to non-resident agent, CIT(A)&#039;s deletion was upheld based on consistent favorable rulings in assessee&#039;s previous years. Section 14A disallowance was rejected as no dividend income existed. ESI payment issue was restored to CIT(A) following SC ruling in Checkmate Services. Income understatement addition of Rs. 6,671 was deleted as income was already declared in previous assessment year despite TDS being deducted in current year. Revenue&#039;s appeal was partly allowed.</description>
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    <pubDate>Thu, 30 May 2024 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=753461</link>
      <description>ITAT Delhi allowed assessee&#039;s appeal on multiple grounds. Regarding royalty payment disallowance, the tribunal ruled in favor of assessee citing Delhi HC precedent, noting genuine agreement with unrelated party MPL for trademark use with sales-linked royalty. For TDS on commission to non-resident agent, CIT(A)&#039;s deletion was upheld based on consistent favorable rulings in assessee&#039;s previous years. Section 14A disallowance was rejected as no dividend income existed. ESI payment issue was restored to CIT(A) following SC ruling in Checkmate Services. Income understatement addition of Rs. 6,671 was deleted as income was already declared in previous assessment year despite TDS being deducted in current year. Revenue&#039;s appeal was partly allowed.</description>
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