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TMI Blog2022 (2) TMI 979X X X X Extracts X X X X X X X X Extracts X X X X ..... er The present appeal has been filed by the assessee against the order of the ld. CIT(A)-20, New Delhi dated 06.03.2018. 2. Following grounds have been raised by the assessee: "1. On the facts and circumstances of the case, the order passed by the learned Commissioner of Income Tax (Appeals) [CIT(A)] is bad both in the eye of law and on facts. 2(i) On the facts and circumstances of the case, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the case, learned CIT(A) has erred both on facts and in law in confirming the disallowance despite the fact that no expenditure has been incurred by the assessee in relation to the exempt income earned." 3. The assessee filed return of income on 20.09.2011 declaring income of Rs. 446,16,34,115/-. The assessee company is engaged in the business of manufacturing of Seamless, ERW Pipes & Tubes and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... before making any foreign currency remittance were furnished before the Assessing Officer and are also placed in the paper book. It was submitted that one payment of Rs. 52,560/- has been made to subscribe for information online for Iron & Steel prices from China. The subscription was paid earlier for two years. It is a renewal of subscription and claimed in the A.Y. 2009-10 and A.Y. 2010-11 whic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... amount thus reimbursed was Rs. 7.63 lacs. We find that the inspection and examination of the goods before shipment is a common practice and it cannot be treated as a technical service. The inspection with regard to quality, quantity and weight of the product pre-shipment of rolling coils, non-alloy steel rolls cannot be treated as technical and managerial services as per the provisions of the DTAA ..... X X X X Extracts X X X X X X X X Extracts X X X X
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