Bench: Shri Waseem Ahmed & Ms. Madhumita Roy
3. Ground No. 1 relates to addition of Rs. 1,47,94,267/- made on account of export sale commission under Section 40(a)(ia) of the Act as no TDS was made. 4. The assessee engaged in the business of Trading of Agricultural Products and exporting the same, following mercantile system of accounting filed its return of income