TMI Blog2015 (1) TMI 148X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee is directed against the order dated 21.01.2014 passed by the AO u/s 143(3) read with section 144C of the Income-tax Act, 1961 (hereinafter also called 'the Act') in relation to the assessment year 2009-10. 2. The additional ground raised by the assessee challenging the validity of the impugned order on the basis that the same was made in a wrong name, was not pressed by the ld.AR. The sam ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng Officer. The assessee is aggrieved against this addition. 5. After considering the rival submissions and perusing the relevant material on record, it is observed that the assessee made payment of the above amount on receipt of technical services pursuant to an Agreement dated 26.04.2006, a copy of which has been placed on page 196 of the paper book. Such payment was made in consideration of re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion in accordance with law, after allowing a reasonable opportunity of being heard to the assessee. 6. The only other ground is against the addition of Rs. 60 lac made by the AO u/s 14A of the Act. Here again, we find that similar disallowance was made by the AO. When the matter came up before the Tribunal, this issue was also sent back for a fresh examination in the light of certain directions. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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