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TMI Blog2018 (4) TMI 406X X X X Extracts X X X X X X X X Extracts X X X X ..... ed in the Profit & Loss Account of the sister concern. Besides, the particulars of the transaction which formed the basis of the compensation having been produced before the lower authorities. It also found that the sister concern had offered the aforesaid amount of ₹ 7.57 lakhs for tax. Consequently, it allowed the Appeal of the respondent, assessee by holding that the payment of compens ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al under Section 260-A of the Income Tax Act, 1961 (the Act), challenges the order dated 22nd April, 2015 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order dated 22nd April, 2015 is in respect of Assessment Year 2008-09. 2 Revenue has urged the following two questions of law, for our consideration : (1) Whether on the facts and in the circumstance of the case a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7.57 lakhs on the ground that it is brokerage and no evidence in support of the same was produced. This resulted in addition of the above amount to determine income in the Assessment Order dated 28th December, 2010 for Assessment Year 2008-09. (b). Being aggrieved, the respondent filed an appeal to the Commissioner of Income Tax (Appeals) (CIT (A)). By order dated 21st February, 2012 the CIT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... received by the sister concern. It found that, receipt of amount of compensation was reflected in the Profit Loss Account of the sister concern. Besides, the particulars of the transaction which formed the basis of the compensation having been produced before the lower authorities. It also found that the sister concern had offered the aforesaid amount of ₹ 7.57 lakhs for tax. Consequ ..... X X X X Extracts X X X X X X X X Extracts X X X X
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