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2022 (2) TMI 1309 - HC - Income TaxDisallowance u/s 14A r.w.r. 8D - disallowance of foreign travel expenses, claim for additional depreciation and commission to foreign and Indian agents - HELD THAT:- With regard to the commission paid to four entities abroad, the discussion on the said issue - After noting the details of the overseas commission paid to four parties, the tribunal has referred to the documents and certificates in the form of paper book and came to the conclusion that the documents conclusively proved that the commission agent has rendered services to the assessee outside India. Commission paid to the other agents abroad were considered and after taking note of the facts the tribunal was satisfied that the commissioner was right in granting relief to the assessee. With regard to the commission paid to the Indian agents for export sales - After noting the facts, the tribunal held that the commission is not paid to any related party of the assessee. We find that no substantial question of law arises for consideration on the three issues. Restriction of disallowance u/s 14A the tribunal has discussed the said issue and after noting the facts, directed the assessing officer to disallow only a sum u/s 14A on the ground that the disallowance under the said provision cannot exceed the exempt income.
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