9911796707
TMI Blog2007 (6) TMI 192X X X X Extracts X X X X X X X X Extracts X X X X ..... owing its own earlier order, which remained unchallenged while dismissing the revenue’s appeal - no substantial question of law arises for our consideration - these revenue appeals are dismissed - 734 to 741 of 2007 - - - Dated:- 20-6-2007 - P.D. DINAKARAN P.P.S. JANARTHANA RAJA JJ Mrs. Pushya Sitaraman for the appellant. JUDGMENT The judgment of the court was delivered by P. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the amount had been paid by the assessee-firm not for any real services rendered by the said Balaji Siva, but to reduce the profits of the assessee-firm, the assessee had set it off against the accumulated losses of Balaji Siva and accordingly, disallowed the payment of commission in respect of the assessment years 1986-87 to 1993-94 by even dated orders dated March 27, 1998. Against the said ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nged and therefore become final, dismissed the appeals. 3. Aggrieved by the same, the Revenue has preferred the above appeals raising the following substantial questions of law : "1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in merely following its own earlier order, and dismissing the appeal without considering any of the grounds raised by the R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the assessee-company to its sister concern for the services rendered by it was allowable as deduction and the same cannot be interfered with. 6. Again in CIT v. Print Systems and Products [2006] 285 ITR 337 (Mad) wherein the commission paid to a sister concern was found to be reason able by the Commissioner of the Income-tax (Appeals) and the Income-tax Appellate Tribunal, this court he ..... X X X X Extracts X X X X X X X X Extracts X X X X
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