2019 (5) TMI 1393

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..... LD THAT:- One of the issues that arose was the agreement entered into between the Assessee and the aforementioned M/s Devki Devi Foundation on 10th December 2011, where the profit sharing percentage for the period of 30 years was 10%. The Assessee pointed out that for the AYs in question on account of the business exigencies the profit sharing percentage had been reduced from 10% to 8%. Although, .....

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..... unsel for Revenue. Respondent Through: Mr. Rahul Chaudhary, Advocate. O R D E R 1. These are appeals by the Revenue against the common order dated 13th September 2017 passed by Income Tax Appellate Tribunal ( ITAT ) in ITA No. 4050 and 4051/Del/2014 for Assessment Years 2010-11 and 2011-12. 2. The common question sought to be urged by the Revenue is whe .....

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..... ing percentage had been reduced from 10% to 8%. Although, the AO did not accept the explanation offered by the Assessee, it has been found to be acceptable both by Commissioner of Income Tax CIT (A) in the order dated 22nd April 2014 and the ITAT in the impugned order. 4. The impugned order in fact discusses the relevant clauses of the agreement and concludes that the explanation offere .....

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