2001 (9) TMI 68

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....84. While counsel for the assessee contended that the law laid down by this court in the case of CIT v. Sivanandha Steels Ltd. [2000] 243 ITR 770 applies to the facts of this case, learned counsel for the Revenue submitted that it is the law laid down by the apex court in the case of Aravinda Paramila Works v. CIT [1999] 237 ITR 284 that is applicable. In the decision of this court in CIT v. Siva....

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....l that was asserted by the assessee was that he had paid one per cent. commission to the agents abroad, who had procured orders. That commission was paid on the sales effected in the countries in which those agents had functioned. In the decision of this court in [2000] 243 ITR 770 as also in the judgment of the apex court in Aravinda Paramila Works v. CIT [1999] 237 ITR 284, it has been laid down....