9911796707
TMI Blog2018 (12) TMI 37X X X X Extracts X X X X X X X X Extracts X X X X ..... question, had any marketable value and that the Assessee used said trademark for purpose of its products. We are informed that the Assessee is engaged in the business of manufacturing scientific instruments. The issue is purely factual. No question of law arises. Disallowance u/s. 14A r/w Rule 8D - absence of any recorded satisfaction of the assessing officer as to how, having regard to the accounts of the assessee, the assessee's calculation of disallowance was incorrect? - Held that:- Tribunal has also considered this issue in detail and noted that Assessee had made investments in shares which had also yielded considerable amount of tax free dividends. Allotment of small expenditure for earning tax free income, therefore, would not give r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the facts and in the circumstances of the case and in law, the Tribunal ought to have allowed the assessee's claim of expenditure of ₹ 5,53,470/in respect of traveling expenses of customers and consultants incurred wholly and exclusively for the purposes of business and duly supported by evidence which the Tribunal completely failed to consider?" 2. The first question pertains to the Assessee's claim for deduction under Section 37 of the Income Tax Act, 1961 (the Act) of ₹ 50 lakhs paid by the Assessee to one Global Vipasana Foundation (GVF). The Assessee under an agreement dated 8th October, 2008, paid sum of ₹ 60 lakhs to the GVF, out of which, sum of ₹ 50 lakhs was stated to have been paid for the purpo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The assessee may pay any amount of anyone but the relevancy with the business is liable to be viewed. If assessee donated certain fund to the charitable institution then he can raise the claim under section 80G. The alternate claim of the assessee u/s. 80G of the Act has rightly been allowed by the learned CIT(A) in his order. Therefore, in the said circumstances, we are of the view that the learned CIT(A) has passed the order in question rightly and correctly which does not require to be interfered with at this stage. Accordingly, we uphold his order on this count and dismiss ground No.1 of the appeal of the assessee." From the material on record, it can be seen that two Revenue authorities and the Tribunal, concurrently came to the con ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
