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2018 (12) TMI 37 - BOMBAY HIGH COURTClaim of deduction u/s. 37 in respect of amounts paid to GVF - whether these amounts were paid on account of commercial expediency and were revenue expenses wholly and exclusively for the purposes of business? - Held that:- As seen that two Revenue authorities and the Tribunal, concurrently came to the conclusion that, Assessee failed to establish the connection between the expenditure and its business activities. We further find that, there is nothing on record to suggest that trademark in question, had any marketable value and that the Assessee used said trademark for purpose of its products. We are informed that the Assessee is engaged in the business of manufacturing scientific instruments. The issue is purely factual. No question of law arises. Disallowance u/s. 14A r/w Rule 8D - absence of any recorded satisfaction of the assessing officer as to how, having regard to the accounts of the assessee, the assessee's calculation of disallowance was incorrect? - Held that:- Tribunal has also considered this issue in detail and noted that Assessee had made investments in shares which had also yielded considerable amount of tax free dividends. Allotment of small expenditure for earning tax free income, therefore, would not give rise to any question of law. Claim of expenditure in respect of traveling expenses of customers and consultants - expenditure incurred wholly and exclusively for the purposes of business - addition u/s 37 - Held that:- Assessee's claim of expenditure which was incurred for traveling of persons/ customers, who are not in the employment of the Assessee. The CIT(A) and the Tribunal examined the material on record and came to the conclusion that, same could not have been allowed as a business expenditure. No question of law arise.
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