2019 (5) TMI 200

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..... Pardiwalla, Senior Advocate a/w Mr. Atul K. Jasani for Respondent in all Appeals.   P. C. : 1. These Appeals arise in the common background. They have been heard together and would be disposed of by this common order. For convenience, we may record facts from Income Tax Appeal No.342 of 2017.   2. This Appeal is filed by the Revenue to challenge the Judgment of the Income Tax Appellat .....

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..... es for which the said expenditure was incurred. This was towards payment of salary to technical, administrative staff and marketing staff as also towards advertisement and marketing staff training, sales promotion, audit fees. etc. When questioned by the Assessing Officer, the Assessee produced necessary evidence such as copy of the agreement and the email correspondence between the two companies. .....

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..... ayment was made. The Tribunal held that the expenditure was incurred for legitimate needs of the business.   7. We do not find any error in the view of the Tribunal. As pointed out by the learned Counsel for the Assessee, the Assessee and such other sister concerns would proportionately internally allocate administrative expenditure which allocation would be based on scientific distribution. .....

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