TMI Blog2008 (5) TMI 279X X X X Extracts X X X X X X X X Extracts X X X X ..... der dated March 3, 2006, passed by the Income-tax Appellate Tribunal, Delhi Bench "G", in I. T. A. No. 2338/Del/2001 relevant for the assessment year 1996-97. 2. The assessee had entered into an agreement with an American company called Musco to assist in the execution of a project. The project was for lighting the cricket stadium at Mohali. Musco had entered into an independent agreement with th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and the appellate order was upheld by the Income -tax Appellate Tribunal ("the Tribunal"). The Commissioner of Income-tax (Appeals) noted the contention of the assessee that it was merely an intermediary and it had no dominion over the contractual amount between Musco and the Punjab Cricket Association and that its income was only limited to Rs. 8 lakhs for the services rendered by it. 4. To clea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tional evidence. 5. We find that it is not as if additional evidence was produced by the assessee on its own. The certificate was produced by the assessee as a result of a direction given by the Commissioner of Income-tax (Appeals). 6. We are also of the opinion that the production of the certificate cannot strictly be treated as additional evidence having been produced on the direction of the C ..... X X X X Extracts X X X X X X X X Extracts X X X X
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