1 IN THE HIGH COURT OF JUDICATURE AT BOMBAY NAGPUR BENCH : NAGPUR Income Tax Appeal No. 132 of 2006 [Commissioner of Income Tax-IV, Nagpur Vs. Govt. Milk Scheme, Nagpur] With Income Tax Appeal No. 135 of 2006 [Commissioner of Income Tax-IV, Nagpur Vs. Govt. Milk Scheme, Nagpur] Office Notes, Office Memoranda of Coram, appearances, Court's orders Court's or Judge's orders or directions and Registrar's orders. Income Tax Appeal No. 132 of 2006 : Mr. Anand Parchure, Adv., for the appellant. Mr. K.P. Dewani, Adv., for respondent. ----- Income Tax Appeal No. 135 of 2006 : Mr. Anand Parchure, Adv., for the appellant. Mr. K.P. Dewani, Adv., for respondent. ----- CORAM : B.P. DHARMADHIKARI AND F.M. REIS, JJ. DATE : 18th September, 2009. Heard Adv. Mr. Parchure for the appellant and Adv. Mr. K.P. Dewani for the respondent. 2 Findings of Income Tax Appellate Tribunal show that respondent-assessee sold milk to milk kiosk owners and charged and recovered entire price in advance. The said milk was then sold by kiosk owners to their customers at more rate and they kept the profit. Both the agreements between parties are also looked into by the Income Tax Appellate Tribunal to find out whether any relation of principal and agent is established on record. The facts disclosed transaction between two independent principals. In the circumstances, we do not find any payment of commission by respondent to said owner and as such there was no question of any TDS. The concurrent findings on record are basically the findings of fact. No Substantial Question of Law arises. Appeals are, therefore, dismissed. Judge Judge |Hedau| 3