2019 (8) TMI 1347

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....SH J SHAH (1320) ORAL 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, Surat Bench, Surat dated 27.09.2018 in the ITA No.1556/Ahd/2015 for the Assessment Year 2011-12. 2. The Revenue ha....

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.... and on facts in deleting the disallowance u/s. 40(a)(ia) in respect of commission payment to dealers of Rs. 4,38,56,790/- without appreciating that considering the nature of services rendered by the dealers to the assessee Company, the Assessing Officer had correctly made disallowance u/s. 40(a)(ia) of the Act by invoking the provision of Explanation (i) to section 194H of the Act?" 3. So far a....