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PR. COMMISSIONER OF INCOME TAX-5 Versus LE PASSAGE TO INDIA TOURS & TRAVELS PVT. LTD.

2015 (12) TMI 968 - DELHI HIGH COURT

Disallowance under Section 40 (a) (i) - ITAT deleted the addition - whether the services rendered by the agents to the Assessee were in the nature of fee for technical services - Held that:- ITAT has analysed the agreements in question entered into b .....

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services. Consequently, it was held that the consideration paid by the Assessee to such agents could not be classified as fee for technical services.

The Court finds that the view taken by the ITAT on the interpretation of clauses of the a .....

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. Consequently, this Court finds no substantial question arises for determination on this issue.- Decided in favour of assessee.

Whether the payments could have been made by the Assessee to the foreign entities towards tour expenses withou .....

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ded in favour of assessee. - ITA 489/2015 & ITA 491/2015 - Dated:- 10-8-2015 - DR. S. MURALIDHAR & MR. VIBHU BAKHRU JJ. For the Appellant: Mr. Rohit Madan, Senior Standing counsel with Mr. Akash Vajpai, Advocates. O R D E R 1. In these appeals un .....

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irst question projected by the Revenue is whether the ITAT has erred in deleting disallowance of ₹ 2,77,62,022 made by the Assessing Officer ( AO ) under Section 40 (a) (i) of the IT Act in AY 2007-08 on the ground that the services rendered by .....

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red by the agents were purely in the nature of advancement of the business of the Assessee which could not be categorized as managerial/technical or consultancy services. Consequently, it was held that the consideration paid by the Assessee to such a .....

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