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TMI Blog2018 (11) TMI 122X X X X Extracts X X X X X X X X Extracts X X X X ..... 28 out of expenses incurred on support service. The facts in brief are that assessee company has paid support services expenses to M/s. Geoworks Realty Pvt. Ltd. for sums amounting to Rs. 7,79,328/-. Ld. AO required the assessee to furnish the details / nature of services provided by the said company and also to justify the said payment in respect of carrying out the business activities. In response, the assessee submitted that it had utilized various services of M/s. Geoworks Realty Pvt. Ltd. like infrastructure and support services including part of office space, reception, printing, phone expenses, documentation work and other misc. expenses. However, the Ld. AO noted that under 'fixed assets schedule', M/s. GRPL has assets only for sum ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs. 17,309/-. Therefore, it is beyond belief that assessee company has availed support services from MIs GRPL. v. The assessee company has provided bifurcation of revenue received during the year and the details is as under.- Interest income Rs. 7,83,065/- Amount forfeited Rs. 30,00,000/- Other Rs. 45,091/- On perusal of above receipts, it is observed that for the above activities no particular support service is required. " After making aforesaid observations, he has disallowed the entire claim of the assessee. 3. Before the Ld. CIT (A) the assessee placed the entire material and facts on record and pointed out that M/s. GRPL has taken premises on lease from another company, M/s. NCPL Developers Pvt. Ltd. to whom M/s. GRPL is p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... their Day to day work. 5 Documents writing and support services were also being rendered by GRPL. 6 Rendering Staff support services of Receptionist, Accounts, HR, Marketing and Field Executive. 7 It is also includes day to day tea, snacks and other. misc. expenses borne by GRPL 8. Fee:Rs: 60,000/- + Service Tax as applicable. 9 Confidentiality: Both the parties are agreed that they will not disclose any of the terms .and condition of this work order to the other party or its representatives or affiliates without the written consent of M/s HPL Infrastructure Pvt. Ltd 10 Resolution of Disputes: In case of any conflict, terms& conditions of work under the jurisdiction wilol be held in Delhi office and decision of Authorized Signa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee was running its office. If the service has been rendered as per the 'work order' and assessee has incurred the expenditure in the course of its business, then such an expenditure cannot be disallowed simply on the ground that payment has been made to a sister concern or there was no necessity for incurring such expenditure or it does not have much infrastructure in the form of fixed assets. Once it has been brought on record that M/s. GRPL has taken a lease on rent and also maintaining the office, who in turn is providing such office space and other infrastructure facilities to the assessee, then it cannot be held that it is a make believe arrangement, unless any contrary material is brought on record or any inquiry has been done f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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