Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2017 (11) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (11) TMI 1713 - HC - Income TaxAddition u/s 68 - claim towards trade credit unexplained - Held that:- The Court is of the opinion that the question urged is purely factual. Since the findings recorded by the CIT(A) and the ITAT are concurrent, they reflected that the trade advances received by the applicant were adjusted against the sales made to them in the subsequent years. As such, no question of law arises. For enhancement of licence fee is concerned, the facts are that the Assessee was originally paying ₹ 50 lakhs per months licence fee to M/s. Flex Group of Companies. During the Assessment Years in question, the fee was revised mid-term to ₹ 2 crores per month. The A.O. add ₹ 9 crores, upon an understanding that the licence fee increased was arbitrary. The CIT(Appeals), however, deleted this entire amount. The Revenue’s Appeal succeeded substantially to the extent of ₹ 6 crores. No justification to interfere with the ITAT’s findings, which are also factual as far as this issue goes.
|