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Commissioner of Income Tax-08 Versus Study Overseas Global Pvt Ltd

2015 (6) TMI 250 - DELHI HIGH COURT

Disallowance of management fee - CIT(A) allowed the claim - Held that:- As to whether the expenditure was wholly laid out for the business purpose and was driven by commercial expediency cannot be viewed from a narrow lens of revenue officer's perspe .....

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he ITAT reconsidered these aspects, no question of law arises - Decided against revenue.

Disallowance of advertising expenditure - CIT(A) allowed the claim - Held that:- AO allowed depreciation only to the tune of 25% and disallowed ₹ .....

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was of the opinion that the relief as claimed was warranted. So the ITAT too confirmed these findings. No substantial question of law is made out. - Decided against revenue. - ITA No. 311/2015 - Dated:- 22-5-2015 - S Ravindra Bhat And R K Gauba,JJ. .....

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2014 whereby it refused to interfere with the decision of the CIT(A) on two issues. It is contended that the disallowance of management fee made by the AO to the tune of ₹ 1,34,35,168/- was not justified. Likewise, the ITAT's reasoning with .....

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Act, 1961 on account of payment to the tune of ₹ 1,34,35,168/- on account of management fee expenditure towards use of infrastructure etc. The AO conceded that the expenditure was revenue in nature. However, he doubted its genuineness on the gr .....

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rn to it and also demonstrated that the management fee had been incurred only for business purpose. The CIT (Appeals) also took note of the relevant authoritites under Section 37. On these grounds, the said expenditure was allowed. The ITAT confirmed .....

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