TMI Blog2014 (4) TMI 635X X X X Extracts X X X X X X X X Extracts X X X X ..... customers which have been sourced by ICICI Bank Ltd. - Once there is no formula for such services or facilities and for which payment is made nor has the revenue brought on record any material to show that the expenditure in question was excess or unreasonable, no substantial question of law arises for consideration in that case – Decided against Revenue. - Income Tax Appeal No. 1800 of 2011 - - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on No.4(C) has not been answered in favour of the revenue and particularly in the light of retrospective operation to Section 234D of the Income Tax Act, 1961. He also relies upon a Division Bench judgment of this Court in Income Tax Appeal No.2012 of 2011 delivered on 12th September, 2012. 3 Having heard Mr.Gupta and Ms.A. Vissanjee at some length and finding that the Division Bench of this Co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gh the ICICI Bank Ltd. and that is how there is increase in brokerage income. The increase is because of number of customers which have been sourced by ICICI Bank Ltd. Once there is no formula for such services or facilities and for which payment is made nor has the revenue brought on record any material to show that the expenditure in question was excess or unreasonable, we are of the view that t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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