2019 (8) TMI 1347

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....02) For The Opponent (s) : MR MANISH 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 Ass....

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....circumstances of the case, the learned ITAT has erred in law 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 o....