respect of the addition of the
commission paid to sub-agents. The A.O. made the addition in
respect of the commission paid ... summons issued to the agents same
timing is given to all. He further submitted that all the agents / sub-
agents have declared the commission received
sub-agency agreement clearly
states that the activities performed by
German Express in its capacity as
Hapag India‟s sub-agent
Further, the freights collected ... commission as per sub agency agreement. Out of the total
services provided by the assessee a part is performed through
sub-agent and the remaining
appointment of assessee as an agent, GESA was sole agent of
whole territory of India and after sub agent agreement, sub-agent was performing
exactly ... commission as per
sub agency agreement. Out of the total services provided by the assessee a part is
performed through sub-agent and the remaining
further submitted that the entire air
freight business was booked by sub agent namely M/s Jupiter Air India Pvt Ltd
which comes to about ... passed on the commission of Rs. 59,78,684/- to the sub agent namely M/s
Jupiter Air India P Ltd., which constitutes about
marketing and sales related services world
over through its network of sub-agents. The commission paid by the
assessee to them for the year under ... deals with the principle agent and the responsibility
of the execution is with the principle agent not with the sub agents.
Moreover, the assessee
appeal are reproduced as
under:-
"1. ADDITION OF SUB AGENT COMMISSION UNDER SECTION
4Q(a)(ia):
On the facts and in the circumstance ... deducting tax
cess and supervision fee and sub-agent
at sources on market cess
commission paid to Member Co operative
Co-operative Societies, (ii)
disallowance
second hand cars. His
major clients were out stationed. His sub agents were also out of Mumbai.
The assessee would derive information regarding the second ... Mumbai. The assessee would further pass
on that information to his sub agents who would contact the buyers, who
would deposit cash from the said
that the assessee was engaged as a sub-agent in the business
of providing services for distribution of channels to Fox International
Channels Asia Pacific ... explained that the functions performed by SIPL as sub-agent
are as follows:
Advertisement & publicity of channels
Collection of distribution fees
Purchase of Integrated
progression, yielding
sufficient material to exhibit the involvement of the sub-agents. This is, as this would
only eliminate or at least reduce the scope ... agent. This is also crucial from the stand point of the sub-agent, as it is
only on that basis that it could claim commission
domestic travel
which are normally booked by the assessee or the sub agents on an e-commerce
platform (in short 'CRS') which ... countries
which serves to simplify the process which enables the assessee/sub-agent to verify
the availability of air tickets of different airlines
