9911796707
TMI Blog2021 (4) TMI 570X X X X Extracts X X X X X X X X Extracts X X X X ..... h Dubey, Senior DR ORDER PER KULDIP SINGH, JUDICIAL MEMBER : Appellant, M/s. VLCC Health Care (P) Ltd. (hereinafter referred to as 'the assessee') by filing the present appeal sought to set aside the impugned order dated 25.01.2017 passed by the Commissioner of Income-tax (Appeals)-9, New Delhi qua the assessment year 2010-11 on the ground that :- " The CIT (A) erred in law and on facts in co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gnored the facts and evidences brought on record by the assessee qua qualification and responsibility undertaken by Ms. Pallavi Luthura in the business of the assessee. 3. Assessee carried the matter before the ld. CIT (A) by way of filing the appeal who has confirmed the addition made by the AO by partly allowing the appeal. Feeling aggrieved by the order passed by the ld. CIT (A), the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der passed by the ld. CIT (A) which is the submissions made by the assessee highlighting qualifications and work assigned to her, it is surprising to note that the Revenue has accepted working of Ms. Pallavi Luthura as a Director and allowed 65% of the amount paid to her but it is beyond comprehension as to how they had reached the conclusion that out of the 100% of the work assigned to Ms. Pallav ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation for the work assigned to her during the year under assessment. So, we are of the considered view that merely on the basis of conjectures and surmises, provisions contained u/s 40A(2)(b) cannot be allowed to be invoked particularly when genuineness of the services rendered are not in dispute. So, we are of the considered view that AO as well as ld. CIT (A) have erred in disallowing the remune ..... X X X X Extracts X X X X X X X X Extracts X X X X
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