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2019 (2) TMI 370 - ITAT MUMBAIDenial of deduction u/s 10AA - activities being carried out by the assessee, in the opinion of AO did not involve any export outside India - Held that:- The assessee undertook to provide services of varied nature as specified therein. Against the same, it was entitled to receive certain monthly management fees in US Dollars. The invoices raised by the assessee during impugned AY has been placed on record, upon perusal of which, it appears that the nature of services being rendered by the assessee were not warehousing services simpliciter rather the assessee was providing comprehensive services in the nature of repair/maintenance services and incurred cost under various heads. Both the lower authorities, in our opinion, have missed out this vital factual aspect and examined the assessee’s claim by treating these services as warehousing services. Therefore, after due consideration of facts and circumstances, the bench formed an opinion that, keeping all issues open, the matter was to be restored back to the file of AO to re-appreciate the factual matrix and re-adjudicate the issues after ascertaining the true nature of services being rendered by the assessee.
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