9911796707
TMI Blog2010 (1) TMI 889X X X X Extracts X X X X X X X X Extracts X X X X ..... ere based merely on surmises and conjectures, order of the first appellate authority upheld and dismiss this ground of the revenue. Import agency commission - assessee company is only an agent and the assessee accounted its agency income as per the agency agreement with IALCL, UK at the rate of 2.5 of basic import freight and 5% of basic import freight. order of the CIT(Appeals) upheld, appeal of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... import agency commission at Rs.3,40,793/-. 2. At the time of hearing both parties submitted that similar issue has come up before the L-Bench of the Tribunal in the assessee's own case for the assessment years 2001-02 to 2003-04 in ITA Nos. 3910/Mum/2005, ITA No. 7070/Mum/2005 and ITA No. 257/Mum/2007 order dated 27th August, 2008 wherein identical grounds raised by the Revenue were dismissed by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hus, on these factual matrix and as the learned departmental representative could not refute the findings of the first appellate authority, we uphold his findings and hold that the assessee companies in these cases are mere agents of the UK company and the assessing officer had no evidence whatsoever to hold otherwise and the decisions of the assessing officer were based merely on surmises and con ..... X X X X Extracts X X X X X X X X Extracts X X X X
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