1980 (12) TMI 77

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....y the ITO u/s. 273(c). The assessee is a commission agent in respect of products manufactured by M/s. Birla Jute Mfg. Co. Ltd. at Calcutta. Under the agreement entered into with them the commission income is due and payable only after the sale proceeds have been fully realised or received by the principals. The assessee sends letters to the principals mentioning amount of commission every quarter ....

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.... that the assessee is entitled to commission though it pertained to the year under consideration. This plea was not accepted by the ITO but the CIT (Appeals) accepted it. 2. In our opinion, no interference is called for. The assessee have given substantial reasons as to why it was not able to file the revised estimate u/s 212(3A). The assessee cannot confidently say that it was entitled to a pa....