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TMI Blog2019 (9) TMI 852X X X X Extracts X X X X X X X X Extracts X X X X ..... ut any fallacy in the findings of Ld.CIT(A). Further the Tribunal s decision in the case of Tata Johnson Automotive Ltd., (supra) has been upheld by Hon ble Bombay High Court INDO SAUDI SERVICES (TRAVEL) P. LTD. [ 2008 (8) TMI 208 - BOMBAY HIGH COURT] . In view of the aforesaid facts, ground of the Revenue is dismissed. - ITA No.1128/PUN/2016 (Assessment Year : 2009-10) - - - Dated:- 12-7-2019 - SHRI ANIL CHATURVEDI, AM AND SHRI PARTHA SARATHI CHAUDHURY, JM Assessee by: Shri Ketan Ved. Revenue by: Shri Vishwas Mundhe. ORDER PER ANIL CHATURVEDI, AM : 1. This appeal filed by the Revenue is emanating out of the order of Commissioner of Income T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e., GS Yuasa International Limited, Japan. AO noted that the amount paid towards the administrative service charges of ₹ 2,83,21,427/- was from parties covered by Sec.40A(2)(b) of the Act. The assessee was asked to justify the same in relation to the reasonableness and nature of services. Assessee inter-alia submitted that the amount was paid pursuant to the administrative support service agreement entered between Assessee and TACO. AO on perusing the agreement noted that TACO was providing services at the start-up phase and operating phase. He noted that the services mentioned in operating phase were general in nature and requires no specialized services requiring high technical and professional knowledge. AO also noted that the fee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion of Hon ble Bombay High Court in the case of CIT Vs. Indo Saudi Services (Travel) (P.) Ltd., and other decisions cited in the order has decided the issue in favour of the assessee. Aggrieved by the order of Ld.CIT(A), Revenue is now in appeal before us. 4. Before us, Ld. D.R. reiterated the submissions made before AO and Ld.CIT(A). Ld.A.R. on the other hand reiterated the submissions made before AO and Ld.CIT(A) and further submitted that Ld.CIT(A) had decided the issue in favour of the assessee by following the decision of Pune Bench of Tribunal in the case of Tata Johnson Automotive Ltd., (supra) and submitted that against the aforesaid order of the Tribunal, Revenue had preferred appeal before the Hon b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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