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TMI Blog2011 (6) TMI 495X X X X Extracts X X X X X X X X Extracts X X X X ..... ears 1990-91 and 1992-93 is whether the Tribunal was justified in sustaining the first appellate authority's order limiting the deduction claimed by the assessee towards payment made to a group company for "corporate service" rendered to it at 50 per cent. of the actual payment. The assessee paid Rs.16 lakhs in one year and around Rs. 37 lakhs in the other year to another company within the same g ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ls. However, the Tribunal sustained the order of the Commissioner of Income-tax (Appeals) by dismissing the appeals filed by both sides. It is against these orders, the assessee has come up in further appeal before us. 3. The counsel appearing for the appellant/assessee relied on a decision of the Supreme Court in J. K. Woollen Manufacturers v. CIT [1969] 72 ITR 612 (SC) and a decision of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... im amount. The finding of these authorities is that the appellant did not furnish specific details about the services rendered and what is stated is about the broad support and help received by the appellant from the group company to justify payments. We do not know why the appellant could not furnish brake up details of the payments made with reference to the corresponding service rendered for pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l approach is taken by the officer and still more liberal were the first appellate authority and the Tribunal because the claim made is sustained at 50 per cent. without proof for the service rendered justifying allowance of even so much of the claim.
5. We, therefore, do not find any merit in these appeals and the same are accordingly dismissed. X X X X Extracts X X X X X X X X Extracts X X X X
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