TMI Blog2022 (2) TMI 979X X X X Extracts X X X X X X X X Extracts X X X X ..... ittance were furnished before the Assessing Officer and are also placed in the paper book. As submitted that one payment has been made to subscribe for information online for Iron Steel prices from China. The subscription was paid earlier for two years. It is a renewal of subscription and claimed in the A.Y. 2009-10 and A.Y. 2010-11 which was accepted by the revenue. The copy of the party's invoice and payment advice of HDFC bank have been perused. On examination of the facts and evidences before us, we hold that this cannot be treated u/s. 40(a)(ia). With regard to reimbursement of travelling expenses from the Germany based company, the accounts have been reimbursed by the vendor in connection with the visit of the employees wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... elhi dated 06.03.2018. 2. Following grounds have been raised by the assessee: 1. On the facts and circumstances of the case, the order passed by the learned Commissioner of Income Tax (Appeals) [CIT(A)] is bad both in the eye of law and on facts. 2(i) On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in confirming the addition of ₹ 8,49,814/- made by the Ld. AO on account of legal and professional charges under section 40(a)(i) of the Act. (ii) That the disallowance has been confirmed holding the payment to be fee for technical services, misinterpreting the provision of section 9 as well as that of the DTAA between India and USA. 3. On the facts and circumstances of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... no. 15CB along with the information by the assessee in form no. 15CA as required to be filed before making any foreign currency remittance were furnished before the Assessing Officer and are also placed in the paper book. It was submitted that one payment of ₹ 52,560/- has been made to subscribe for information online for Iron Steel prices from China. The subscription was paid earlier for two years. It is a renewal of subscription and claimed in the A.Y. 2009-10 and A.Y. 2010-11 which was accepted by the revenue. The copy of the party's invoice and payment advice of HDFC bank have been perused. On examination of the facts and evidences before us, we hold that this cannot be treated u/s. 40(a)(ia). 5. With regard to reimburse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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