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2023 (12) TMI 348 - DELHI HIGH COURTAllowable business expenses - Supervisory and risk management expenses - addition made expenses were not incurred by the respondent/assessee for its business purposes - CIT(A) deleted addition - HELD THAT:- The record shows that the assessee is in the insurance brokerage business concerning both life and non-life products offered by various insurance companies. Assessee is said to have incurred, according to the stand taken before the AO, the aforementioned amount vis-à-vis prospective clients. Concededly the said amount was paid by the respondent/assessee to its sister concerns, namely M.M. Carpets & Industries Ltd. and Trinity Global Enterprises Ltd. The fact that the expenses were incurred for prospective clients should be good enough for the respondent/assessee to claim deduction qua the same, as every expense does not necessarily translate into corresponding income. Since, as noticed above, the appellant/revenue has treated the amount expended by the respondent/assessee as revenue receipt in the hands of its sister concerns, in our opinion, the same transaction cannot be treated differently in the hands of payer i.e., respondent/assessee. Besides, as noted above, in AY 2010-11, the AO had allowed deduction vis-à-vis amounts expended towards supervisory and risk management charges. CIT(A), in AY 2013-14, as noticed above, had deleted the addition made by the AO. Thus, we are not inclined to interfere with the impugned order, since, according to us, no substantial question of law arises for our consideration.
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