under section 194H on
discount given by it to its sub-agents. Further, the Ld. AR relied
upon the decision of Hon'ble Allahabad
appropriate relief."
2.2 The Appellant Shri Sunil Sethi is a sub-agent of
ICICI Bank for provision of vehicle loans. He is also
related
level because of business
exigencies through such contractors who act as his agent within the
5
ITA No.3347/Del/2016
meaning of rule ... order of the CIT (A) as to who are the agents or sub
contractors of the assessee at the sites, whether the payment has
been
under this Act 'f, or an
intimation under sub-section (1) or sub-section (1B) of
section 143 , where the assessee objects ... section 163 treating the assessee as
the agent of a non-resident:
(e) an order under sub-section (2) or sub-section (3) of section
contract work allowed by M/s. PACL Ltd.
rather it was sub-contracted to M/s. Rajesh Projects India P. Ltd.
and M/s. Gupta ... around 1 %, has made
available agreements for contract and sub contract. The
said agent got those agreement signed from both the parties.
That agent managed
Ge Nuovo Pignone Spa, Gurgaon vs Dcit (International Taxation), ... on 1 January, 2019
IN THE
animals, cattle or birds brought for sale of sold
in the market/sub-market;
(o) disseminate information about the benefits of regulation, the
system ... question along
with other property of the commission agent or purchaser if no
commission agent is involved in the transaction ;
(q) make arrangement for weighmen
Agents with all or any
of the powers vested in them under those present and from time to
time remove such Attorneys or agents ... frame Rules and Regulations and/ or to appoint
committee or sub-committees to carry out and to give effect to the
objects and purposes
reproduced as under:
Dated: 19.03.2016
"The ACIT,
Circle 26,
New Delhi,
Sub: In the case of Bharat Kumar, for the assessment year ... instructions of Purchaser and
sometimes under the instructions of Real Estate Agents. I do not remember as to
under whom instruction I drafted the document
Learned AR that the
assessee had made payment to his agent Mr. Arnit Dutta for purchase
of sim cards and others and hence would fall ... Rule 6DD(k) of the IT Rules 1962 6DD. No disallowance under sub-
section (3) of section 40A shall be made and no payment shall