2013 (5) TMI 220

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.... Appeal by the Revenue directed against the Order by the Commissioner of Income Tax (Appeals)-4, Mumbai ('CIT(A)' for short) dated 29.09.2010, allowing the assessee's appeal contesting its assessment for the assessment year (A.Y.) 2006-07 u/s.143(3) of the Income Tax Act, 1961 ('the Act' hereinafter) vide order dated 19.12.2008. 2.1 At the very outset it was submitted by the ld. AR, the assesse....

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.... disallowance in the sum of Rs.47.27 lakhs, effected u/s. 36(1)(vii) r.w.s. 36(2), he would draw our attention to order by the tribunal in the assessee's case for A.Ys. 2003-04 to 2005-06 (supra), and which in turn follows an order by it for A.Y. 2002-03 (in ITA No. 500/Mum/06 dated 29.10.2007/PB pgs. 11-13). The same, he would further submit, also forms the basis of the deletion by the ld. CIT....

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.... relief to the assessee following the decision in the case of CIT vs. Standard Polygraph Machines Pvt. Ltd. [2000] 243 ITR 788 (Mad). As would be apparent from the foregoing, this is a recurring feature in the assessee's case. As such, there is no merit in the Revenue's argument that the assessee had not supplied it with the copy of the relevant agreements. Further, when the TDS is grossed-up and ....