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TMI Blog2017 (5) TMI 367X X X X Extracts X X X X X X X X Extracts X X X X ..... a reasonable token disallowance. The tribunal found that its earlier order of 30th December, 2005 was thus violated. It deleted the retention of disallowance of 10% made by the Commissioner of Income Tax (Appeals). As far as the Revenue's appeals are concerned, from the discussion and from para 7 onwards, it is apparent that the tribunal found that such dis-allowances as were made cannot be susta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment year in question is 2002-03. 2. It is submitted that the questions proposed at pages 3 and 4 (para 4) are all substantial questions of law arising out of this order of the tribunal. 3. The respondent assessee was merged with ICICI Securities Ltd. It is engaged in stock broking operations. In the original assessment order, the payment of procurement expenses by the assessee amountin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... st was concerned, the tribunal found that all the three grounds of appeal cannot be entertained. The two assessment years, namely, 2001-02 and 2003-02 raised these issues. The tribunal found that this is a second round of appeal before the tribunal. Earlier, the assessee had filed its return of income declaring a certain total income. The assessing officer disallowed the payment of commission and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ty was satisfied with the submission of the assessee that the services were actually rendered by the I-Cap to the assessee. However, he disallowed the 10% of the commission as reasonable disallowance. The assessee filed an appeal against this retention of 10% dis-allowance. On the other hand, the Revenue preferred an appeal against the dis-allowance being set aside and as made by the assessing off ..... X X X X Extracts X X X X X X X X Extracts X X X X
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