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2012 (5) TMI 203 - ITAT MUMBAITDS on the activity of super stockist of Chemists & Druggists - Principal to Principal relationship or Principal to agent relationship - held that:- the assessee company has not paid even a single penny to its super stockiest. - Rather, it is just the opposite. - The super stockist is paying to the assessee company for the produce of Drugs. In turn, it is selling those goods at the rate of 80% of MRP and is earning income of 10% of MRP which is stipulated in the Memo of Understanding dated 12-05-2009. - Therefore, the relationship between the assessee company and its super stockiest is on a Principal to Principal basis. The A.O. as well as the CIT(A) totally misinterpreted the agreement, misread the facts and have come to wrong conclusions. - Decided in favor of assessee.
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