TMI Blog2015 (10) TMI 1441X X X X Extracts X X X X X X X X Extracts X X X X ..... to Malaysia and UK with the business purpose. Except for filing a tour report of one of the directors, which is an simply an internal evidence, the ld. AR could not place on record any external evidence to suggest that any business meetings were held in Malaysia or UK, which were attended by these three directors. On being called upon to file any correspondence with the Japanese company to sup ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 015 - R S Syal, AM And C M Gag, JM For the Petitioner : Shri Siddhanth Gupta, Adv For the Respondent : Shri Anil K Misra, CIT, DR ORDER Per R S Syal, AM This appeal by the assessee is directed against the order passed by the CIT(A) on 31.3.2004 in relation to the assessment year 1999-2000. 2. In this case, an order u/s 254(1) of the Act was earlier passed by the Tribunal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... anda for visits to Malaysia and UK. Similarly, Shri K. Minami and Shri Vimal Langer, other two directors, were found to have visited UK. The assessee was required to explain the business connection of the visits of these three directors of the assessee company to Malaysia and UK. No evidence was filed substantiating the claim of such expenses having any business connection. This led to the making ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d have discussed the matter at length if it was accepting the version of the assessee by stating the reasons and on what basis it held the aforesaid view, more particularly, when the orders of the Assessing Officer as well as CIT(A) disclosed detailed reasons rejecting same very version. 4. A perusal of the above observations made by the Hon ble High Court divulges that the Tribunal has been c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... usiness meetings were organized by the Japanese company in Malaysia and UK, there is no evidence worth the name to support such a claim. When the position is such, the natural conclusion which follows is that there is no positive evidence to the effect that these foreign trips were undertaken by the three directors for any business purpose. Under such circumstances, the view taken by the authoriti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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