9911796707
TMI Blog2020 (3) TMI 1248X X X X Extracts X X X X X X X X Extracts X X X X ..... 238 - DELHI HIGH COURT] given that the issue has not reached finality, as the Hon'ble Supreme Court in case of Godrej Boyce Manufacturing Co. Ltd., [ 2017 (9) TMI 1689 - SUPREME COURT] is yet to pronounce its order in the question of Whether provision of Section 14A of the Act are applicable even when no exempt income is earned? - THAT:- We find from the order passed in [ 2019 (4) TMI 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o.541/VIZ/2018 vide order dated 30/04/2019 on the ground that ground Nos. 5 6 are not adjudicated. 2. The Revenue has raised the following grounds of appeal:- 1. The order of the Ld. CIT(A)-1, Guntur is erroneous to law, facts and circumstances of the case. 2. Ld.CIT(A) out to have appreciated the fact that given the nature of trade of the assessee, it is essential for, foreign agent t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to prove that the amount paid to foreign agents was not in the nature of 'Fee for Technical Services'. 5. Ld.CIT(A) erred in not relying on the ratio of the Hon'ble Supreme Court in the case of Rajendra Prasad Moody [115 ITR 519 (SC) where it was held that earning of income is not essential for incurring expenditure. 6. The Ld. CIT(A) has incorrectly relied on Delhi High Court de ..... X X X X Extracts X X X X X X X X Extracts X X X X
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