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2007 (5) TMI 617 - HC - Income TaxDisallowance in respect of Commission - commercial expediency - Payments on account of commission to any person for doing the liaison work - details of services rendered not established - notice sent by the Assessing Officer remained unserved - HELD THAT:- From the record it is apparent that the assessee was required by the Income-tax Authorities to file the requisite particulars and produce the concerned person for verification/examination. The assessee did not submit any confirmation from the DOT and MTNL because DOT and MTNL were not directly involved. With regard to the names and addresses of the persons with whom the assessee interacted, it was stated by the assessee that there has been a lot of changes in the structure of M/s. SFL Industries Ltd. and details and whereabouts of the employees of M/s. SFL Industries were not available with the assessee. The assessee even did not file the copy of relevant bank account of M/s. SFL. The assessee also failed to explain as to what was the nature of the services provided by M/s. SFL, and no correspondence in this regard has been produced by the assessee in spite of specific opportunities granted. No fault can be found with the view taken by the Tribunal. Thus, the order of the Tribunal does not give rise to a question of law, much less a substantial question of law, to fall within the limited purview of section 260A of the Act, which is confined to entertaining only such appeals against the order which involves a substantial question of law. There are concurrent findings of the facts in the present case given by the three statutory authorities and in view of the fact that assessee has failed to provide the requisite information to the Assessing Officer, we do not find any infirmity in the order passed by the Tribunal. Accordingly, the present appeals filed by the assessee are, hereby, dismissed.
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