TMI Blog2019 (5) TMI 200X X X X Extracts X X X X X X X X Extracts X X X X ..... buted to the Assessee and also on the ground of excessive payment in terms of Section 40A(2) - Tribunal was of the opinion that the business expediencies for incurring such expenditure cannot be questioned by the Revenue and in relation to Section 40A(2)(b) and there was no material on record to suggest that such expenditure was excessive or unreasonable having regard to the market value of the se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , 343 OF 2017, 354 OF 2017, 358 OF 2017 - - - Dated:- 30-4-2019 - AKIL KURESHI SARANG V. KOTWAL, JJ. Mr. Charanjeet Chanderpal for Appellant in all Appeals. Mr. P. J. 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Crores. The Assessee was engaged in the business of manufacturing and selling aluminum radiators, coolants and other automobile related machinery. The Assessee had entered into an agreement with one Tata Autocomp Ltd. for providing certain services for which the said expenditure was incurred. This was towards payment of salary to technical, administrative staff and marketing staff as also towards ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ned by the Revenue. In relation to Section 40A(2)(b) of the Act, the Tribunal was of the opinion that there was no material on record to suggest that such expenditure was excessive or unreasonable having regard to the market value of the services for which the payment was made. The Tribunal held that the expenditure was incurred for legitimate needs of the business. 7. We do not find an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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