Exception to Monetary Limit for filing Appeal not applies if Assessee discloses all about foreign income

JCIT Vs ADF Foods Ltd. (ITAT Ahmedabad) In this case, the assessee himself has claimed that certain payments are covered in provisions of Section 5, 9, 195 of the Act and also under DTAA. Therefore, tax was not applicable. As per this letter, the assessee has explained that it is engaged in the business of processing and packaging various food items and its turnover is mainly from exports to foreign countries. Hence, to improve its international market it had paid the said payment to the persons who were non residents and they provided all business and marketing related services abroad. These ...