In the result, the assessee's appeal is allowed
Bench: Shri R. K. Panda & Shri Vinay Bhamore
penalty under section 271(1)(c) can be levied. The appellant has also argued that the claim of commission payment was made on the basis of agreements and TDS deductions. and the disallowance arose only because the authorities did not accept the evidence as sufficient. It has further been contended that the disallowance relating to commission expenses is tax neutral