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TMI Blog2023 (12) TMI 348X X X X Extracts X X X X X X X X Extracts X X X X ..... bh Nangia, Advs. For the Respondent Through: None. RAJIV SHAKDHER, J. (ORAL): CM No.59054/2023 [Application filed on behalf of the appellant seeking condonation of delay of 448 days in re-filing the appeal] 1. This is an application moved on behalf of the appellant/revenue seeking condonation of delay in re-filing the appeal. 1.1 According to the appellant/revenue, there is a delay of 448 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (A)] deleted the addition; a view which has been sustained by the Tribunal. 9. Mr Puneet Rai, learned senior standing counsel, who appears on behalf of appellant/revenue, says that the deletion of the addition concerning the amount said to have been spent by the respondent/assessee towards supervisory and risk management, was flawed. 9.1 According to Mr Rai, the aforementioned expenses were not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome amounting to Rs. 5,58,09,177/-. 13. It is not in dispute that the appellant/revenue has treated the amounts received by the respondent/assessee's sister concerns as revenue receipts. Furthermore, it is also not in dispute that rate of tax levied on the amounts received by the respondent/assessee's sister concerns is the same as that which the respondent/assessee is subjected to. 14. It appea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sion of Mr Rai is founded on the rationale that while the said expenses were incurred for prospective clients it did not result in the respondent/assessee earning a matching income. 17. According to us, this argument is flawed. The fact that the expenses were incurred for prospective clients should be good enough for the respondent/assessee to claim deduction qua the same, as every expense does n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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