power to appoint sub-agents / representatives.
However, it is the responsibility of the agents to pay the sub-
agents. The assessee can ask the agent ... appoint sub-agents
does not mean that they (agents) have the authority to
conclude contracts. The terms of appointment of sub-agents
given at page
payment made by the assessee-company of ocean freight to sub-
agents and Indian beneficiaries.
12. As noted by the Assessing Officer during the course ... freight was paid
either to NRI shipping owners or their resident sub-agents. The said details
customer
business segment") and to the AE ("Related-party/ Sub-agent business segment")] based
purely on own conjectures and surmises. The consequential ... only that of
agent and no more. In sub-agent segment, assessee merely acts on behalf of the AE
and all the risk is that
offices of their agents for remitting money from to friends/relatives in India. The service being provided by the agents and sub-agents is delivery ... sub-agents, not the persons receiving money in India.
(v) The consumer of the service provided by the agents and sub-agents
commission which ranges between 9.70% to 28.24% and through chain
of sub-agents i.e. overriding commission which ranges between 3.25% to
0.11%. The said ... commission which ranges between 9.70% to 28.24% and through chain
of sub-agents i.e. overriding commission which ranges between 3.25% to
0.11%. The said
assessee's claim that the said sum was
received from sub-agents (who in turn had received it from aspirants seeking
jobs abroad ... travel abroad and allegedly gave money to the
assessee through 5 sub. Agents.
(i) Specific denial of 2 persons for giving money
194G of the Act on commission paid to sub-
agents.
5. On appeal, the CIT(A) allowed the appeal of the assessee by placing reliance ... 194G of the Act are not applicable to payments made to sub-agents by
the assessee.
6. Against this, the Revenue is in appeal before
commission, market cess and supervision
fees paid to sub-agent.
14. The Assessing Officer while completing the assessment noticed that
as per clause ... Counsel for the assessee submitted that the
payments made to sub-agents towards commission, market cess and
supervision fees are "for and on behalf
nature of transaction between the registered IATA Agents and the subsequent sub-agent, is that of sale and purchase, and accordingly, held that service ... agent. In such situation, it could not be said that the appellant is promoting the business of another travel agent, in their capacity as sub
broker as there is no independent agreement
either with the sub brokers or sub agents who are selling SIM
Card or Recharge Coupons on behalf ... case of the department that
assessee has deputed any sub agents and charging
commission from them. It is also seen that the assessee has
purchased
