2025 (12) TMI 1227

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....hajed, A.R. For the Revenue : Shri Rameshwar P. Meena, Sr. D.R. ORDER PER SUCHITRA KAMBLE, JUDICIAL MEMBER: This is an appeal filed against the order dated 20-03- 2025 passed by National Faceless Appeal Centre(NFAC), Delhi for assessment year 2017-18. 2. The grounds of appeal are as under:- 1." Whether, on the facts and circumstances of the case and in law, Id. CIT(A) has e....

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....se to notices issued, the assessee filed reply on various dates along with details. The Assessing Officer observed that the assessee company paid commission to non-resident amounting to Rs. 3,42,79,595/- during the year and had not deducted TDS on commission payment to non-resident. The said details were asked by issuing notice u/s. 142(1) and further a show cause notice dated 15-11-2019 as to why....

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....u/s. 37 to the extent of Rs. 3,42,39,594/-. 4. Being aggrieved by the assessment order, the assessee filed appeal before the ld. CIT(A). The CIT(A) allowed the appeal of the assessee. 5. The ld. D.R. submitted that the assessee has not proved the genuineness of the commission expenses as the details filed before the Assessing Officer was not registered document or signed document in presence....

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....he assessee on identical issue. The ld. A.R. relied upon the order of the CIT(A) and the order of the Tribunal in assessee's own case. 7. We have heard both the parties and perused the material available on record. The Assessing Officer made addition under the head commission expenses paid to non-resident but the assessee company is in the line of exports and commission paid to essential and in....