ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, AMRITSAR vs. SHRI RAJDEEP SINGH UPPAL PROP, AMRITSAR
In the result, the appeal of the revenue is dismissed and the CO of
ITA 643/ASR/2019[2010-11]Status: DisposedITAT Amritsar16 Nov 2022AY 2010-11
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
For Appellant: Sh. Jatinder Nagpal, AdvFor Respondent: Sh. Rajiv Wadhera, Sr. DR
Section 133(6)Section 148
…fee as brokerage or even as commission. But the fee—or to use a generic expression ‘receipt’—could not be regarded as turnover proper. Asstt. CIT v. Rajdeep Singh Uppal RELIED ON IN - The above circular was relied on in ITO v. Shantilal Chunilal & Co. [1993] 45 ITD 581 (Pune - Trib.), with the following observations: ". . . Further, reference was made by assessee to pages 52 to 54 which contains Board’s Circular No. 452, dated 17-3-1986 which has been issued in connection with section 44AB of the Income-tax Act. 1961 Reliance was placed on para 4 of the said circular according to which the Board were advised th…