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TMI Blog2013 (3) TMI 98X X X X Extracts X X X X X X X X Extracts X X X X ..... l capacity, the amount of commission which is alleged tohave been paid to M/s Ratandeep Polymers (P) Ltd., has to be assessed on substantive basis in the hands of Dr. Shashi Kant Garg. There is no question of holding that the Assessing Officer had not made a detailed inquiries in this behalf. The order of Commissioner of Income Tax (Appeals) under Section 263 of the Act has been righly set asid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... posed the following substantial question of law said to be arising out of the order of the Tribunal. The substantial question of law in all these four appeals is similar : - " Whether on the facts and circumstances of the case, the Ld. ITAT is legally correct in stating that Ld. CIT was not justified in invoking the provisions of Section 263 of the I.T. Act whereas D.C. (Asstt.), Spl. Range whil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mpany had claimed payment on behalf of Company. The Income Tax Officer had found that Divisional Ayurvedic and Unani Officer, Muzaffarnagar, Principal/ Superintendent, Swamy Kalyan Dev Rajkiya Ayurvedic College, Rampur, Divisional Ayurvedic and Unani Officer, Narendra Nagar, Tehri Garhwal, Divisional Ayurvedic and Unani Officer, D.M. Colony, Bulandshahar, Divisional Ayurvedic and Unani Officer, Mo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ervices have been rendered for which commission was to be paid. He accordingly, set aside the order and directed the Assessing Officer to pass a fresh order in accordance with law in the light of the observation made under Section 263 of the Act. On the basis of the inquiry made for the Assessment Year 1991-92, the aforesaid order was made applicable for the subsequent assessment years. However, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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