Sell of business to broker by sub-broker with tangible assets would not make sale agreement to that of agency

IN THE ITAT MUMBAI BENCH ‘D’ Assistant Commissioner of Income-tax V/s. Devang N. Kamdar IT APPEAL NO. 3857 (MUM.) OF 2009 [ASSESSMENT YEAR 2006-07] MARCH 22, 2012 ORDER T.R. Sood, Accountant Member In this appeal, revenue has raised the following grounds: 1.  “On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in treating the agreement between the assessee and Sharekhan as on principal to principal basis in spite of the fact that the assessee was only a sub broker of Sharekhan and hence was only an agent of Sharekhan.” 2...