That before penalty can be imposed, it was incumbent that the A.O., must record  a finding, as to the ingredients of satisfaction of Section 11AC.

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2.         M/S. TEXTOOL CO. LTD. (MHC) [Related to section 37 of Income Tax Act, 1961] 

The Tribunal was pleased to confirm the order of CIT appeal, inasmuch as even in the earlier year, such a claim of additional commission came to be allowed which was also affirmed by the Tribunal.

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 CA. Kapil Goel, Moderator-Direct Taxes, Mob:9910272806, cakapilgoel@gmail.com

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