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2017 (1) TMI 1334 - AT - Income TaxAllowability of business expenditure - Held that:- There is not even the list of marketing services vis-à-vis the corresponding sales along with the commission payments in question so as to prove the argument that the former assessee had in fact availed marketing services of the latter assessee as per the relevant agreements on record and therefore, the impugned commission disallowances are liable to be deleted. No merit in Shri Devatia’s last argument that the department itself has been allowing these assessees’ claims regarding rendering of marketing services in all earlier assessment years. We observe in these peculiar facts that each and every assessment year is a separate unit and merely because an assessee has proved some expenses in earlier assessment year does not ipso facto lead to a conclusion that the very payee has rendered in fact the very services in all latter assessment years as well.
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