2021 (3) TMI 1102

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....IT-DR representing Revenue and Shri KC Devdas, learned AR appearing at assessee's behest. Case file perused. 2. The Revenue has raised the following substantive grounds in the instant appeal. 2. Whether in the facts and circumstances of the case, the Ld. CIT(A) is correct in allowing the appeal of assessee by completely ignoring the fact that a Government authority viz. the Chief Engineer, Maharashtra State Electricity Distribution Company has clearly spelled out the process of e-tender, design, specification of a public utility product and confirmed that no third party was involved in any of the services as mentioned in the relied upon agreement? 3. Whether in the facts and circumstances of the case, the Ld. CIT(A)....

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.... In the case of M/s. Rolex Meters Pvt. Ltd., Hyderabad -AY 2015-16 - Submission of - Reg. Ref:- Letter of CIT(A)-3, Hyd in F. No. Remand Rep/CIT(A)-3/2018-19 dated 30-07-2018. --------------- Kind attention is Invited to the above cited subject and reference. In this connection, it is submitted that vide letter under reference, this office was asked to submit a factual report. After examining the additional evidences submitted by the assessee, the report called for is submitted as under: During the course of assessment proceedings, the AO made an addition of Rs. 16,78,07,963/- being commission payments to two agents namely M/s. Ghankun Steel Pvt. Ltd. and M/s. Nutan Ispat and Power Pvt. Ltd. trea....

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....e two agent companies were verified. It is seen that these amounts paid by M/s. Rolex Meters Pvt. Ltd. were duly reflecting in the Form No. 26AS of these two agent companies and were included in their respective returns. Further, the agreements entered into by M/s. Rolex Meters Pvt. Ltd. with these two agent companies clearly mentions about what all are the services to be rendered by them and for what consideration. Further, the assessee company vide letter dated 07-09-2018 submitted as under: "... With their assistance we were able to secure contract of approx. Rs. 138.09 Crores during AY 2015-16 from Maharashtra State Electricity Distribution Company Limited (MSEDCL), a Government of Maharashtra undertaking..... " ....