M/S. SRC AVIATION PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI
The appeal of the assessee is dismissed
ITA 1065/DEL/2016[2011-12]Status: DisposedITAT Delhi28 Feb 2019AY 2011-12
Bench: Shri H.S.Sidhu & Shri Prashant Maharishiacit, Vs. Src Aviation Pvt. Ltd, Circle-22(2), 507, G-5, Building, New Delhi Terminal1, Igi Airport, New Delhi Pan: Aabcs2455F (Appellant) (Respondent) Src Aviation Pvt. Ltd, Vs. Acit, 507, G-5, Building, Circle-22(2), Terminal1, Igi Airport, New Delhi New Delhi Pan: Aabcs2455F (Appellant) (Respondent)
For Appellant: Shri Atul Puri, CAFor Respondent: Ms Rinku Singh, Sr. DR
Section 143
…the capacity of the shareholder as dividend. Therefore, the facts of that case are quite different from the facts before us. 31. Further more in special bench decision of „Dalal Broacha Stock broking V. Additional Commissioner of Income Tax, Mumbai‟ – (2011) 10 ITR (Trib) 357 (Mumbai) (SB) the assessee company during the relevant year had paid commission to the tune of Rs.40 lakhs to the three working directors. They are the only shareholders of the company and owned the entire share capital. During the assessment proceedings, the Assessing Officer asked the assessee to explain as to why the claim of expenditure…