TMI Blog2018 (2) TMI 2081X X X X Extracts X X X X X X X X Extracts X X X X ..... o the file of AO limited to the extent of making such verifications in respect of payments made to Dr. May Pharma Consult GMBH, which are claimed as expenditure incurred for the purpose of business. After conducting necessary verification, the AO is directed to decide this issue in accordance of law after giving the assessee a reasonable opportunity of hearing. Assessee s appeal stands allowed for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ground raised by the assessee reads as under:- 1. On the facts and circumstances of the case and in law, Ld. CIT(A) was not justified in confirming the order of the learned Assessing Officer of making a disallowance of Legal Professional charges of Rs.18,70,718/- treating the same as Capital expenditure and not allowing it as revenue expenditure. 2. Facts leading to the same are that durin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d, the assessee is in further appeal before us. 4. The Ld. Authorized Representative for Assessee [AR], at the outset, drew attention to the fact that the assessee suffered similar disallowance in AYs 2008-09 2009-10 which was contested up-to the level of this Tribunal vide ITA No.7056/Mum/2011 ITA No.5782/Mum/2012 dated 27/04/2015 where the matter was restored back with certain directions ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... k done by the said party which were supported by emails and other documentary evidence. However, it was submitted that this matter may be restored back to the file of AO for verification of the purpose of business as well for determining the services rendered by the said party to the assessee. Accordingly, after hearing both the parties, we restore the issue to the file of AO limited to the extent ..... X X X X Extracts X X X X X X X X Extracts X X X X
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