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2019 (1) TMI 888 - HC - Income TaxCommission paid to foreign agents - allowable business expenses - evidence on record to show that such foreign agent had worked on behalf of the Assessee in procuring sales - Held that:- The entire issue is based on an appreciation of evidence on record. The CIT(A) and the Tribunal on facts came to the conclusion that the commission paid to the foreign agents was for having worked on behalf of the Assessee in procuring sales. No question of law arises. Loss claimed by the Assessee upon sale of shares - AO noticed that Assessee had purchased the shares at ₹ 30 Crores but sold the same for an amount as low as ₹ 30 lakhs - Held that:- CIT(A) and the Tribunal, found that there was no colourable device employed by Assessee in the process. The Tribunal noted that before sale of shares, the Assessee had obtained the valuation report of an independent valuer, who had shown the value as 'Nil'. The Company concerned was a sick undertaking and was before BIFR. Inter alia on such ground, Tribunal dismissed Revenue's Appeal and confirmed the decision of the CIT(A).
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