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2014 (4) TMI 668 - AT - Income TaxAddition of commission - Deletion of compensation charges – Held that:- CIT(A) was of the view that the expenditure of commission payment was incurred by the assessee wholly and exclusively for the purpose of its business and therefore was allowable as an expenditure and accordingly deleted the addition - CIT(A) agreed with the assessee that office/infrastructure and other facilities of holding company were used for the purpose of its business - The CIT(A) was convinced that the payment of compensation charges to the holding company was wholly and exclusively for the purpose of business - the total income computed by the holding company for the year under consideration is at Rs. 84,09,900 - The returned income of the assessee is at Rs. 11,99,832 - Both the assessee and its holding company come within the same tax brackets - there is no benefit to the assessee by inflating its expenditure and diverting it towards its holding company as both parties are subject to same rate of tax and both parties are showing positive income - The entire exercise is tax neutral – thus, there is no reason to interfere with the findings of the CIT(A) – Decided against Revenue.
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