2019 (7) TMI 1096

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....RAL ORDER (PER : HONOURABLE MR.JUSTICE J. B. PARDIWALA) 1 This Tax Appeal under Section 260A of the Income Tax Act, 1961 (for short, "the Act, 1961") is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Ahmedabad 'A' Branch, Ahmedabad dated 22nd October 2018 in the ITA No.2143/Ahd/2014 for the assessment year 2009-10. 2 T....

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....wance of Rs. 23,14,214/under Section 40(a)(ia) of the Act for nondeduction of the tax of the source of commission payable to the foreign agent. The question as proposed by the Revenue is no longer res integra in view of the decision of this Court in the case of PR CIT vs. MGM Exports rendered in the Tax Appeal No.309 of 2018 dated 11th April 2018. 3 The ratio of the decision of this Court refer....

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....in first appellate proceedings, there is obviously no point in challenging the conclusions arrived at in the first appellate proceedings based on vague generalities. No specific issues are raised in appeal before us. We have also noted that the learned CIT(A) has granted impugned relief on the basis of specific explanations of the assessee which have remained uncontroverted. In the light of these ....