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TMI Blog2018 (2) TMI 1597X X X X Extracts X X X X X X X X Extracts X X X X ..... ount of commission being shown as discount does not arise. In fact, it was pointed out that in its Revenue recognition policy as disclosed in its accounts, sales are recognised net of discounts. Thus, no expenditure/deduction is claimed on account of discount in respect of sales of its goods made to its stockists. The aforesaid fundamental objection of the Petitioner on facts has not been dealt by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... anga Co., for the Petitioner. Mr. Suresh Kumar, for the Respondent. ORDER : 1. Heard. 2. Rule. 3. This Petition challenges notice dated 31 March 2017 issued by the Assessing Officer under Section 148 of the Income Tax Act, 1961 ( the Act for short) seeking to reopen the assessment for the assessment year 2010-11. The Regular assessment proceedings for the subject asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the difference between MRP and selling prices to the stockist was in the nature of commission on which there was a failure to deduct the tax at source of ₹ 11.19 Crores. It is on the basis of the above information that the reasons in support state that the amount of ₹ 111.95 Crores was the commission given to its stockist. The Reasons in support only state that the amount of ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... objection of the Petitioner on facts has not been dealt by the order disposing of the objections. Thus, rendering the entire process of taking a second look, particularly on facts, before proceeding to reassess, futile. Even before us the Revenue has not been able to show that in its accounts the Petitioner had claimed any amount of expenditure as discount on sales of its products to stockists. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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