2015 (8) TMI 910

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.... return of income for the AY.2008- 09 on 16-09-2008 admitting income of `1,97,53,442/-. The case of the assessee was selected for scrutiny and notice u/s. 143(2) was issued to the assessee on 03-09-2009. The Assessing Officer vide order dated 08-10-2010 made addition/dis-allowance on account of foreign travel expenses in the income returned by the assessee. 3. The Commissioner of Income Tax-I, Coimbatore initiated proceedings u/s.263 of the Act on the ground that the assessee had claimed `2,19,15,480/- towards commission paid to non-resident foreign companies without deduction of tax at source. The Commissioner of Income Tax concluded that since the assessee has failed to deduct tax at source from the commissions paid to the overseas agen....

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....iii. ACIT Vs. M/s.Farida Shoes Private Ltd., in ITA No.359/Mds/2013 (AY.2008-09) decided on 11th April, 2013. 5. On the other hand, Shri B. Arulappa, appearing on behalf of the Revenue vehemently supported the order of Commissioner of Income Tax and prayed for the dismissal of the appeal of the assessee. 6. We have heard the submissions made by the representatives of both the sides and have also perused the impugned order as well as the orders relied upon by the ld. Counsel for the assessee. The brief facts of the case are that: assessee is engaged in the trading of yarn with various countries. In order to sell its products, the assessee appointed agents on sales commission basis in various countries. The relationship between the assessee....