Dispute over Payments: Commissioner Rules as Managerial Remuneration, Assessee Provides Evidence u/s 263 to Challenge.

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....Revision u/s 263 - nature of payment received by the assessee- As per CIT-A amount received by the assessee is managerial remuneration and not professional fees - during the course of the proceedings before the Ld.PCIT the assessee had submitted various evidences including the service agreement dated 30/08/2008 and also the board resolution of the company and TDS certificate U/s.194J to justify his claim and the Ld.PCIT could not draw any negative inference from the same. Further there is also nothing on record to suggest that the assessee has received managerial remuneration. - AT....