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TMI Blog2018 (9) TMI 802X X X X Extracts X X X X X X X X Extracts X X X X ..... nst the judgment of the Income Tax Appellate Tribunal, Rajkot Bench ["Tribunal" for brevity] dated 4th January 2018, raising following question for our consideration: "Whether the Appellate Tribunal has erred in law and on facts in deleting the disallowance made under Section 40 [a](ia) of the Incometax Act, 1961 ?" For AY 20062007, the Assessing Officer made addition of Rs. 82.63 lakhs [rounde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ors' Association v. Union of India, reported in [2002] 257 ITR 202. The Tribunal was of the opinion that there was no relationship of principal and agent between the assessee and the travel agents, to whom such commission was paid. Before the Tribunal, assessee had pointed out that she was a member of International Air Transport Association. She was engaged in booking the air tickets for domestic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unal accepted such explanation, referring to the judgment of this Court in the case of Ahmedabad Stamp Vendors' Association v. Union of India [Supra] in which the Court was of the opinion that the principal agent relationship was essential for applying Section 194 H of the Act.
We are broadly in agreement with the view of the Tribunal. No question of law arises. Tax Appeal is dismissed. X X X X Extracts X X X X X X X X Extracts X X X X
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