TMI Blog2008 (5) TMI 279X X X X Extracts X X X X X X X X Extracts X X X X ..... Income-tax (Appeals). This is because the Commissioner of Income-tax (Appeals) has clearly mentioned in his order that it is only to confirm the stand taken by the assessee that the certificate was required. It appears to be quite clear that the Commissioner of Income-tax (Appeals) merely wanted to play safe and, therefore, required the certificate from Musco clarifying the stand of the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on of a project. The project was for lighting the cricket stadium at Mohali. Musco had entered into an independent agreement with the Punjab Cricket Association for this purpose. In terms of the agreement between the assessee and Musco, the assessee was to act as an intermediary and a local supervisor for execution of the project. Any amounts that were to be paid by the Punjab Cricket Association ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sco and the Punjab Cricket Association and that its income was only limited to Rs. 8 lakhs for the services rendered by it. 4. To clear the controversy and confirm the stand of the assessee, the Commissioner of Income-tax (Appeals) directed the assessee to produce a certificate from Musco to the effect that the only remuneration that it was entitled to was a sum of Rs. 8 lakhs. On the basis of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... opinion that the production of the certificate cannot strictly be treated as additional evidence having been produced on the direction of the Commissioner of Income-tax (Appeals). This is because the Commissioner of Income-tax (Appeals) has clearly mentioned in his order that it is only to confirm the stand taken by the assessee that the certificate was required. It appears to be quite clear that ..... X X X X Extracts X X X X X X X X Extracts X X X X
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