9911796707
TMI Blog2013 (11) TMI 136X X X X Extracts X X X X X X X X Extracts X X X X ..... any evidence to show that the said relatives have not provided any services as claimed by assesse - Commissioner of Income-tax (Appeals) has not examined the plea raised or services rendered by the persons – The two employees rendered services and treating salary payment as genuine and reasonable – Decided in favour of assesse. - - - - - Dated:- 5-10-2012 - Order The order of the Bench was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ised following ground: "(1) For that in the facts and circumstances of the case, the learned Commissioner of Income-tax (Appeals) was not justified in sustaining the disallowance of the sum of Rs. 98,000 out of salary paid to managers (being persons specified under section 40A(2)(b) of the Act) incurred wholly and exclusively for the purpose of the carrying out the business." We have heard t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ppeals) confirmed the action of the Assessing Officer by stating that the Assessing Officer disallowed one-third of the salary paid to these persons after considering various aspects of the business of the assessee. We find that before the Commissioner of Income-tax (Appeals) the assessee's contention was that "Mr. Panja looks after marketing, procurement, collection of the concern. Mrs. Panja loo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lower authorities and considering the explanation submitted before the Commissioner of Income-tax (Appeals) and even now before us that these two employees rendered services, we treat the salary payment as genuine and reasonable. This view of ours is also supported by the facts that the Assessing Officer has not brought out any comparative case to show that the salary paid is unreasonable or any e ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
