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2019 (1) TMI 1690 - ITAT MUMBAIDeduction u/s 80-O - services rendered to MLINT - HELD THAT:- No addition would be sustainable in law merely on the basis of suspicion, conjectures or surmises. The assessee had placed on record sufficient documentary evidences to substantiate its claim u/s 80-O with respect to services rendered to MLINT. The claim was duly supported by the confirmatory letter of MLINT as well as RBI approval letter which specifically prohibited devolvement of foreign exchange to the assessee. On the contrary, except for mere suspicion & allegation, nothing was brought on record by Ld. AO to counter the assessee’s claim. It is beyond doubt that the assessee was acting as co-lead manager in the aforesaid issues but the allegations of Ld.AO that the fee was received in that capacity through MLINT is without any corroborative evidences. Therefore, the conclusion of Ld. CIT(A) could not be faulted with and hence concurring with the same, we dismiss the appeal filed by the revenue.
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