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TMI Blog2014 (10) TMI 111X X X X Extracts X X X X X X X X Extracts X X X X ..... d GDP per capita figures - All of them have paid a sum as the fee for the services rendered by M/s. Akerrald Investments Ltd. - all the three authorities have concurrently held in the first place, there was no obligation on the part of the assessees to have such a report from M/s. Akerrald Investments Ltd. - even if they have obtained report, there is no nexus between the said report and a consultancy service they were expected to render under the agreement between them and BIL - the consultancy service was only for the period from 1.10.2000 to 30.9.2001 - The report of M/s. Akerrald Investments Ltd. is dated 28.9.2001, two days prior to the expiry of the period of consultancy service – the order of the Tribunal is upheld – Decided against ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncurred in relation to such income. One such expenditure was a payment made to M/s. Akerrald Investments Ltd. which was disallowed on the ground that there is no nexus between the payment made for the services rendered by them and the consultancy services for which they received the payment. Aggrieved by the said order, the assessees preferred appeals to the Commissioner of Income Tax (Appeals). The appeals were dismissed. The second appeals preferred by the assessees to the Tribunal also met the same fate. It is thereafter that they have preferred these appeals. 3. The two substantial questions of law which arise for consideration in all these appeals are as under: (1) Whether the Tribunal was right in upholding the disallowance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... estimated broadly on the available data on population and consumption and GDP per capita figures. The analysis of each market encapsulates its estimated size, factors inhibiting or promoting growth, the major suppliers, key success factors, and barriers to development presented for manufacturers of biscuits and confectionery products in each of the countries. Local customs tariffs and other regulations, including investment incentives, foreign ownership limitations, and other relevant measures are also discussed. It is their specific case, on the basis of the said report, they inturn submitted their report. Each Director has submitted a separate report for manufacture and sale of biscuits and confectionery in South-east Asian countries and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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