TMI Blog1980 (12) TMI 77X X X X Extracts X X X X X X X X Extracts X X X X ..... anufactured by M/s. Birla Jute Mfg. Co. Ltd. at Calcutta. Under the agreement entered into with them the commission income is due and payable only after the sale proceeds have been fully realised or received by the principals. The assessee sends letters to the principals mentioning amount of commission every quarter and that is confirmed by the principals if it is found correct. The assessee was a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... consideration. This plea was not accepted by the ITO but the CIT (Appeals) accepted it. 2. In our opinion, no interference is called for. The assessee have given substantial reasons as to why it was not able to file the revised estimate u/s 212(3A). The assessee cannot confidently say that it was entitled to a particular commission merely because the sales took place. It all depended upon the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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