these reasoning,
the Ld. AO disallowed the commission payment.
13. The Ld. CIT(A), however, deleted the disallowance by observing as
under:
"Commission ... commission. The appellant has given full details of
commission paid, the sales in respect of which commission is
paid, the rate at which commission
confirming the order of learned assessing officer with respect to
disallowance of commission expenses of Rs.97,30,774/- as not admissible to be
claimed ... confirming the order of learned assessing officer with respect to
disallowing commission expenses of Rs 1,24,80,859/- as not admissible to be
claimed
foreign commission expenditure of Rs.1,56,17,547/-. He directed the assessee to
explain as to why this commission be not disallowed. In response ... deducted
head Commission expenses from such commission
paid.to nori residents is payment to nonresidents for
disallowed and added back to export sales.
income
confirming the
disallowances of the following expenses.
S.N. Head of expenses Disallowed by Sustained by the
AO ld. CIT(A)
7.1 Electricity connection ... CIT(A) (PB 151), and those reproduced at pg 9 of the order of
CIT(A).
2. Before the ld. CIT(A) it was submitted
same relates to the order of the Ld. CIT(A) in
deleting the disallowance of Rs.6,79,704/- made ... facts and circumstances of the
case, the learned CIT (Appeals) erred in deleting
proportionate disallowance of interest of
Rs.2,53,61,633/- on account
fact of the case is that the A.O. disallowed commission
paid to foreign agents amounting to Rs. 2,17,30,116/- by holding that ... commission paid to the 11 commission agents
common with the preceding year, we see no reason to interfere in the order of
the Ld.CIT
2015 Page No. 3
ACIT vs. Pradeepkumar B. Jha
disallowed. Ld. CIT (A) ought to have granted deduction of expenses
incurred for fulfilling contract with ... before CIT(A) supported by evidences, which were
duly analyzed and appreciated by Ld. CIT(A). The AR further submitted that
from the CIT
upheld the disallowances made by the
learned AO for lack of documentary evidences supporting
the claim.
9. Disallowance of Commission expenditure ... learned CIT(A) has erred in concluding that the
payment of commission is chargeable to tax in India.
9.3 The learned CIT(A) failed
orders
of the Ld. CIT(A)-XIV, Ahmedabad, Ld. CIT(A)-XVI, Ahmedabad, CIT(A)-XIV,
Ahmedabad, & Ld. CIT(A)-8, Ahmedabad dated ... depreciation on interest converted into loan amount. Ld. CIT (A) ought to have deleted
disallowance. It be so held now.
2 Ld. CIT (A) erred
ground of appeal pertains to the action of Id. CIT(A) in
restricting the disallowance on account of peripheral development expenses ... ground of appeal pertains to the action of ld. CIT(A) in
restricting the disallowance on account of community development and
welfare expenses
