TMI Blog2022 (4) TMI 912X X X X Extracts X X X X X X X X Extracts X X X X ..... - DELHI HIGH COURT] and Asian Mills Pvt. Ltd [ 2021 (12) TMI 232 - GUJARAT HIGH COURT] the Courts dismissed the appeals filed by the Revenue on the ground that no substantial question of law arose in the said matters as the issue as to whether any agent had rendered any service or not was a question of fact. In the present case, the authorities below have given a concurrent finding of fact th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd the present appeal is dismissed. - ITA 85/2022 - - - Dated:- 13-4-2022 - HON'BLE MR. JUSTICE MANMOHAN AND HON'BLE MR. JUSTICE DINESH KUMAR SHARMA Appellant Through: Mr. Himanshu Sinha with Mr. Bhuwan Dhoopar, Advocates. Respondent Through: Mr. Puneet Rai, senior standing counsel for the Revenue with Ms. Adeeba Mujahid and Mr. Karan Pandey, Advocates. J U D G M E N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rm of emails filed by the Appellant in support of the transaction of commission expenditure incurred in connection with Railway contracts. In support of his submissions, he relies upon the judgments of this Court in Commissioner of Income Tax vs. Conimeters Electricals (P) Ltd., (2010) taxmann.com 302 (Delhi) as well as Principal Commissioner of Income Tax-1 vs. Asian Mills Pvt. Ltd. decided ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iven a concurrent finding of fact that the Appellant had failed to produce any evidence to prove that service had been rendered by Mr. D.N. Pandey to the appellant. The Tribunal in its order has also concluded that merely producing some emails exchanged between Mr. D.N. Pandey and the Appellant/assessee is not sufficient to prove that Mr. Pandey had provided any kind of service. The Profit and Los ..... X X X X Extracts X X X X X X X X Extracts X X X X
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