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2014 (10) TMI 111 - HC - Income TaxAllowability of expenses – Payment made to M/s. Akerrald Investments Ltd. – nexus between the payment made for the services rendered by them and the consultancy services for which they received the payment - Held that:- In order to render consultancy services and achieve performance parameters, all of them entered into an agreement with M/s. Akerrald Investments Ltd. who in turn submitted a report giving analyses about the biscuit market in Pakistan, Nepal, Srilanka, Bangladesh and Maldives - The sizes of the various markets have been estimated broadly on the available data on population and consumption and GDP per capita figures - All of them have paid a sum as the fee for the services rendered by M/s. Akerrald Investments Ltd. - all the three authorities have concurrently held in the first place, there was no obligation on the part of the assessees to have such a report from M/s. Akerrald Investments Ltd. - even if they have obtained report, there is no nexus between the said report and a consultancy service they were expected to render under the agreement between them and BIL - the consultancy service was only for the period from 1.10.2000 to 30.9.2001 - The report of M/s. Akerrald Investments Ltd. is dated 28.9.2001, two days prior to the expiry of the period of consultancy service – the order of the Tribunal is upheld – Decided against assessee.
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