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2017 (8) TMI 31 - HC - Income TaxDisallowance of consultancy charges paid to Jeevan suraksa Medicare Services Ltd - whether the expenditure was not incurred wholly and exclusively for the purpose of business - Held that:- Commissioner granted additional opportunity to the assessee to produce documents and called for remand report from the Assessing Officer. After considering such additional materials, the Commissioner reversed the decision of the Assessing Officer on the ground that the expenditure was not in doubt and that the same was also made for the purpose of business. How the assessee should arrange his business would not be the concern of the department. This view of the Commissioner of Income Tax (Appeals) was confirmed by the Tribunal. No reason to interfere whether the certain expenditure is made for the purpose of business is essentially a question of fact. Commissioner (Appeals) and Tribunal have been concurrently come to certain findings.No question of law arises. Addition by way of commission to different agents - Held that:- Commissioner (Appeals) noted that the commission was paid to large number of persons and the assessee could produce enough evidence to establish majority of his payments. It was this view of the Commissioner of Income Tax (Appeals) which was confirmed by the Tribunal. Once again this question is purely one of facts. No question of law arises. Revenue appeal dismissed.
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