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2022 (2) TMI 757 - AT - Income TaxDisallowance u/s 14A r.w.r 8D - HELD THAT:- We observed that it is fact on record that assessee has not earned any exempt income during the year, therefore no disallowance can be made u/s. 14A of the Act when assessee has not earned any exempt income. Accordingly, ground raised by the revenue is dismissed. Disallowance of foreign travelling expenses to foreign countries from where assessee was not deriving any revenue - HELD THAT:- We observed that assessee has submitted capital account of the Directors and other relevant information before the Ld.CIT(A) as the additional evidences which clearly indicates that the expenses relating to two sons who were travelled with the Directors were not charged to Profit and Loss Account and were charged to personal account of the Directors. Further, he brought to notice that there is business connection in Singapore for the Directors to visit there. These are all details relating to the expenses and disallowed by the AO. CIT(A) having coterminous powers is empowered to verify the simple documents submitted before him. Therefore, it need not be remitted to Assessing Officer for further verification. Hence, the information placed before the Ld.CIT(A) and before us clearly indicate that assessee has not claimed personal expenditure relating to the family travelled in foreign trip and also there is business connection for the directors to visit Singapore. Therefore, we do not find any reason to interfere with the findings of the Ld.CIT(A). Accordingly, grounds raised by the revenue are dismissed. Addition made on account of informer information expenses - HELD THAT:- From the record submitted before us this is a relevant expenditure incurred by the assessee during the year and also assessee is claiming this expenditure from the past several years. We also observed that Assessing Officer has not disputed the revenue or services offered by the assessee which is the services offered to rendering the services to multinational companies in the field of investigation of violation in the utilization of IPR. In our view once nature of business of the assessee is accepted, the unique aspect of informants expenses is also to be accepted, which is relevant for carry out the functions of the company. And when assessee takes services of informants certainly they will demand compensation without incurring such expenses assessee will not be able to provide effective services and continue similar services to other clients. In this case, details of informants have to kept secret and the assessee has supplied enough information to substantiate the actual payment but only kept the identity of the informants. After going through detailed finding of the Ld.CIT(A) we do not find any reason to interfere with the finding of the Ld.CIT(A). Accordingly, ground raised by the revenue is dismissed and also involvement of provisions of section 69C of the Act in the case of the assessee is farfetched and accordingly, this aspect also dismissed. Ground raised by the revenue is dismissed.
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