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TMI Blog2019 (7) TMI 645X X X X Extracts X X X X X X X X Extracts X X X X ..... , Senior Advocate with Mr. A. D. Bhobe, Ms. C. Mashelkar and Ms. K. Govekar, Advocates for the Respondent. P.C. :- Heard learned Counsel for the Appellant-Revenue and the Respondent-Assessee. 2. This Tax Appeal, filed by the Revenue, concerns addition of expenditure as commission on export of goods, paid on behalf of the Assessee to its overseas agents for facilitating its export business. 3. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r facilitating its export business and recovery of export proceeds. When the matter was carried by the Assessee before the Commissioner of Income Tax (Appeals), the latter held that the non-resident foreign commission agents had provided services to the Assessee outside India and no part of their income was assessable in India as the agents had no operations in India and, therefore, the provision ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was before this Court in Tax Appeal No. 4 of 2019 (The Principal Commissioner of Income Tax, Panaji v/s. M/s. Rajaram Bandekar (Sirigao) Mines Pvt. Ltd.). This Court, after considering the case law cited by the Revenue and, in particular, the case of Goetze (India) Ltd. Vs. Commissioner of Income Tax, 284 ITR 323 (SC), held that there was no question of the Assessee claiming any deduction by filin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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